- Who we are
(collectively the ” LOOP Group“).
- You have been directed to this Policy because an entity within the LOOP Group is collecting, using or disclosing your personal data.
- In this Policy, when we use “we“, “us” or “our“, we refer to the entity (within the LOOP Group) which is collecting your personal data, or which is operating the website which you are accessing or using.
- We own and/or operate website(s) such as https://www.loopnewsletter.com and/or any mobile apps that may be published by us (the said website and mobile apps may be collectively or individually referred to as the “Website”).
- Rainmarxker is registered in Singapore (Co. Reg. 53377080K) at 21 Woodlands Close #05-41 Singapore 737854.
- What is the purpose of this Policy?
- We are committed to safeguarding the privacy and security of your personal data. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
- The Website is not intended for use by any person below the age of 18. We do not and do not intend to, transact through the Website directly with anyone we know to be under the age of 18.
- This Policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the applicable Website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the relevant Website(s) and/or service(s) and DO NOT provide any personal data to us.
- What personal data is collected
- “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
- When you use our Website, any service we provide or in your interaction with us, the personal data we may collect include but is not limited to :-
(a) Data collected directly from you. This may be done through our Website, over the phone, by email, or in person when you meet our staff or representatives. The personal data collected may include, but is not limited to:
- your contact information, including your (first and last) name, (billing and/or delivery) address, birthdate and email address and/or your telephone number. We need your e-mail address and/or telephone number so that we may contact you if we have questions or information for you regarding your order or the service that we are providing or will provide to you;
- other information required to be able to process your order or to provide you with the service, such as information concerning the products you have ordered or the service we are providing to you, the billing and/or delivery address, banking and/or credit/debit card details;
- if you have created an online profile or account, the preferences and interests stored in such profile or account (please see below for further information concerning the profiles); and/or
- if you have contacted customer service, the details of this contact and the contact history.
- Click-stream data. A visit to one of our Websites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
- the visitor’s IP address
- the date and time of the visit
- the referral URL (the site from which the visitor has come)
- the pages visited on our website
- information about the browser used (browser type and version, operating system, etc).
- Flash cookies. A particular form of cookie is the flash cookie. In contrast to normal cookies, these cookies are not created and saved by the web browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted or disabled via the browser; this is only possible if you follow instructions available from the Adobe Flash Player website. You can also obtain more information about these cookies on that website.
- Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or our (mobile) applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
- Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. You can find out more information about the processing of web analytics data by Google Analytics in paragraph 9 below.
- home address
- images and/or photographs
- credit/debit card information
- location Information of yourself and/or your computer or device
- contact Information
- transactional information
- usage and preferences
- your purchase and/or your transactions with us
- LOOP and associated entitis, will/may collect, use, disclose and/or process your personal data for one or more of the following purposes :
(a) processing and/or dealing with your interest in our products and/or services;
(b) considering, processing, dealing with and/or managing, your booking, reservation, request/application for, of or your purchase of, our products and/or services (the “Transaction”);
(c) facilitating, processing, dealing with, administering and/or managing Transaction(s) by or with you;
(d) administering, facilitating, managing, processing and/or dealing with your relationship with us, your transaction(s) with us,, any transactions or activities carried out by you on the Website or at our premises/establishments or with us, your requests, including but not limited to dealing with your adhoc queries, requests or bookings, dealing with your preferences, dealing with your membership needs, processing orders and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a reservation or transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you, to the said third party individual(s) (such as but not limited to your name);
(e) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Website, including identifying you for login to the Website, our portals and other online services provided by or on behalf of us. Without limiting the generality of the foregoing, if you:
(i) gain access to or sign in to the Website, using your login credentials of a Social Networking Site, or
(ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Website,it may result in information or your personal data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your personal data;
(f) monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;
(g) administering, facilitating, processing and/or dealing in any transactions, payments, debt collection, or activities carried out by you on the Website or at our premises or with us; or when requested by you; dealing with or administering your participation in contests, gamification, social events organised by us;
(i) registering you as a customer of any of our products or services, and/or to deal with, process and/or administer the account that you may open with us, whether a membership account or otherwise, including to facilitate your transactions or activities at our premises, the Website, or your transactions or activities with us;
(j) carrying out your instructions or responding to any enquiry or complaint given by (or purported to be given by) you or on your behalf including responding to your enquiries and complaints; or responding to or dealing with your interactions with us or your requests; or responding to or dealing with your feedback, comments or reviews. If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal data (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity;
(k) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(l) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively “Feedback”) that you provide through Social Networking Sites, to the Website or to us (including at our premises), with other users of the Website or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business, products or services of LOOP (and/or of any member of the LOOP Group), and/or to acquiring customers, and/or for the purpose of providing the public with your Feedback which may be useful for the public’s patronage decision or for the public’s information or otherwise. This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our affiliates’) annual reports (if any) etc., and/or incorporated as part of LOOP’s (and/or of the LOOP Group companies/entities’) marketing collaterals/materials or corporate video to be disclosed to the public, and you hereby consent to the same. Do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately contact our Customer Department at email@example.com and head the subject of your feedback content with the word “Confidential”;
(m) understanding and/or managing your interests, concerns and preferences;
(n) carrying out due diligence, statutorily required activities or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations applicable to us or any LOOP Group (whether Singapore or other countries), the requirements or guidelines of governmental authorities which we determine are applicable to us (whether Singapore or other countries) or any LOOP Group, and/or our risk management procedures that may be required by law (whether Singapore or other countries) or that may have been put in place by us or our affiliates/associated companies;
(o) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(p) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or our affiliates/associated companies are expected to comply;
(q) complying with or as required by any request or direction of any governmental authority (whether Singapore or other countries) which we or any LOOP Group entity are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
(r) conducting research, (including customer research), surveys, market surveys, analysis and development activities (including but not limited to data analytics, and/or profiling), obtaining your feedback to our products, services or facilities, to :
(i) improve or develop our products, services and/or facilities in order to enhance any continued interaction between yourself and us connected or in relation to your relationship with us, the Website, or your Transaction(s);
(ii) improve any of our products or services or facilities, whether now or in the future; or
(iii) improve our understanding of your interests, concerns and preferences.
Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey or request your feedback, by way of email or postal mail.
In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your shopping behaviour in e-shops, your use of LOOP programmes, your ratings and reviews of products, your contact history with our customer service, your newsletter clicks/ opening results, your surfing behaviour (web tracking), the newsletter types you are subscribed to, your participation in promotions or events, your interactions with us and your use of (mobile) applications);
(s) the conduct of training or training purpose, so as to develop or improve our products or services and/or our staff’s and agents’ services and/or service quality. Without limiting the generality of the foregoing, such training may involve collection, use, disclosure or processing of your personal data including your feedback or comments or reviews;
(t) to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security, crime prevention and/or quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, we wish to bring to your attention that there are surveillance cameras installed throughout our premises and/or our offices, for security, crime prevention, safety and training reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently;
(u) for marketing purpose and in this regard, LOOP (and/or any member of the LOOP Group) would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including products, services and/or events of third party organisations with which LOOP (and/or any member of the LOOP Group) may collaborate with) that we (including any member of the LOOP Group) or such third party organisations may be selling, marketing, offering, organising, involved in or promoting, whether such products, services and/or events exist now or are created in the future, :
(ii) if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of the PDPA; and/or
(iii) Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, LOOP or the LOOP Group entity, as the case may be, reserves its right to send a specified fax message (as defined in Singapore’s Personal Data Protection (Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified text message (as defined in the Exemption Order) (i.e. a marketing fax message or marketing text message) to your Singapore telephone number, if:
(1) there is an ongoing relationship between LOOP (or the LOOP Group entity, as the case may be), and you, and the purpose of the message is related to the subject of the ongoing relationship, pursuant to the requirements and conditions of the Exemption Order; or
(2) the law permits
For the avoidance of doubt, this subparagraph is without prejudice to subparagraph (r) above for which you have hereby consented to us contacting you for a survey, which you may subsequently opt out of by sending our Data Protection Officer notice;
(v) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(w) maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
(x) creating reports with respect to your Transaction(s) and/or transactions that we have with our customers;
(y) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of LOOP and/or of the LOOP Group, Transaction(s), and/or our transactions with our customers;
(z) anonymisation of your personal data. In this regard, you acknowledge that personal data that has been anonymised is no longer personal data and the requirements of the PDPA would no longer apply to such anonymised data;
(aa) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves LOOP as a participant or involves only a related corporation or affiliated entity of LOOP as a participant or involves LOOP and/or any one or more of LOOP’s related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
(bb) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of LOOP or of its affiliates/related corporations;
(cc) LOOP’s or LOOP Group’s reporting purposes including but not limited to reporting on LOOP’s business performance; and
(dd) to deal with the or as part of a bankruptcy, winding up, reorganisation, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of LOOP.
(the purposes set out in this paragraph 4.1 above shall be collectively referred to as the “Purposes”)
- You may withdraw your consent for us to process your personal data for marketing purpose mentioned at paragraph 4.1(u) above at any time via one the following relevant methods:
- clicking the Unsubscribe button located at the bottom of our emailers
- contacting us or our Data Protection Officer through the contact details listed at paragraph 13.1
(a) our associated or affiliated organisations or related corporations, or any member of the LOOP Group;
(b) any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, data centres, hosting and maintenance service providers, analysis services service providers, e-mail messaging services service providers, delivery service provider, handling of payment transactions service providers, marketing service providers, delivery services, handling of payment transactions and debt collection, solvency check and address check;
(c) our professional advisers, for example, our auditors and lawyers, as well as our insurers;
(d) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes. Without limiting the generality of the foregoing, such third parties to which we may/will disclose your personal data include payment, debt collection, finance companies or banks including credit card companies; and
(e) any actual or proposed assignee or transferee of the business of LOOP, or a merged entity in the event LOOP is merged to create the said merged entity.
- Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that :
(a) for any personal data of individuals that you disclose to us, you would have prior to disclosing such personal data to us obtained consent from the individuals whose personal data are being disclosed, to :
(i) permit you to disclose the individuals’ personal data to LOOP and the LOOP Group for the Purposes; and
(ii) permit LOOP and the LOOP Group to collect, use, disclose and/or process the individuals’ personal data for the Purposes;
(b) at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
(c) any personal data of individuals that you disclose to us are accurate; and
(d) for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to LOOP and the LOOP Group and for LOOP and the LOOP Group to collect, use, disclose and process such personal data for the Purposes.
- This Policy only applies to our Website and information that we collect from you. Our Websites may contain links to other websites which are not owned or maintained by us. When visiting these third party websites or disclosing your personal data to third parties (including buyers or sellers on our website), you should read their privacy policies, or ask relevant questions before you disclose your personal data. We are not responsible for the collection, use or disclosure of your personal data by such third parties.
- Our Website and mobile or web-based applications may provide you with social plug-ins from various social networks (such as Facebook and Twitter). If you choose to interact with a social network, your activity on our Website or via our mobile or web-based applications will also be made available to social networks such as Facebook and Twitter.
- If you are logged in on one of the social networks during the visit of one of our Websites or mobile or web-based applications, the social network might add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter one of our Websites or mobile or web-based applications.
- We cannot influence this data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.
- Our Website and mobile or web-based applications may offer location-enabled services, such as Google Maps and Bing Maps. If you use those mobile or web-based applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You will/may be asked if the geo-location service can be activated and you can also object to this geo-location service within the respective mobile or web-based application.
- In some instances, your IP address may be used to direct you to the most relevant version of the site.
- Our Website and mobile or web-based applications may contain web analytic services provided by Google Analytics and Hubspot. This means that when you visit our Website or use any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies.
- This further means that when you visit our Website or use any mobile or web-based applications, the personal data described above in paragraph 3.1 – including the “click-stream data”, the data from “web beacons and tracking links” and information stored in Google Analytics and/or Hubspot’ cookies will be sent to Google Analytics and/or Hubspot for analysis for and on behalf of us. Please note that if you have created an online profile at our Website or mobile or web-based application and if you are logged on in this profile, a unique number identifying this profile will also be sent to Google Analytics and or Hubspot in order to be able to match the web analytics data to this profile.
- Our Website and mobile or web-based applications may use retargeting technologies within the internet. This enables us to show our visitors, who were already interested in our shop and our products, advertisement from us on partner websites.
- We also work with other companies who use tracking technologies to serve advertisements on our behalf across the Internet. These companies may collect non-personally identifiable information about your visits to our websites or mobile or web-based applications and your interaction with our communications, including advertising.
- Retargeting technologies analyse your cookies and display advertisements based on your past surfing behaviour. For further information on cookies, please refer to paragraph 3 of this Policy.
- We do not store any personal data about you with this technology.
- Security of your personal data is important to us. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
- We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
- If you have any questions about the processing of your personal data or about our Policy, if you do not accept the amended Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your personal data, you are welcome to contact us through the contact details listed at paragraph 13.1.
- You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by contacting us through the contact URL at paragraph 12.1. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. All requests for correction or for access to your personal data must be in writing. We will endeavour to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
- We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
- In many circumstances, we need to use your personal data in order for us to provide you with products or services which you require or have requested. If you do not provide us with the required personal data, or if you do not accept an amended Policy or withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require or have requested.
- We may charge you a fee for responding to your request for access to the personal data which we hold about you, or for information about the ways in which we have (or may have) used your personal data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
- You may send complaints regarding our handling of personal data in writing.
Such complaints must:
– be addressed to the LOOP Group Data Protection Officer at:
(ii) Address: 21 Woodlands Close #05-41 Singapore 737854
– provide the name, contact number and address of the person submitting the feedback
– provide the relevant details required such as the relevant time period, our employees or who involved, or copies of relevant documents.
- All complaints will be evaluated by LOOP in a timely manner. After LOOP has completed its evaluation, the LOOP Group Data Protection Officer (or a duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.
- This Policy is prepared pursuant to the PDPA and governed by the laws of Singapore.
- For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.
Last Updated on 09 Aug 2020