The types of Customer Data that RN collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.
There are two broad categories of Customer Data that RN collects depending on the circumstances:
(i) personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;
(ii) contact information e.g., address, phone number, email address;
(iii) payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
(iv) order information e.g., order information, product purchased or other service preferences;
(v) technical information e.g., IP address; and
For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.
The provision of Customer Data relevant for the transaction or service request at hand, (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for RN to carry out its services to you. The failure to supply such Customer Data may result in (i) RN being unable to provide you with the services and/or products requested; (ii) RN being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by RN.
Generally, RN collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., our service provider), or from publicly available sources, through our website, mobile services, and other channels including our roadshow counters in order to fulfil the following purposes, which include but are not limited to:
RN may also use and disclose your Customer Data with and to third parties in order to fulfill the purposes listed above. In connection with the above, we may disclose your Customer Data to third parties, such as our freight service providers and logistics partners.
RN may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.
RN may disclose your Customer Data to law enforcement agencies and government for security, customs purposes. For example, in cases where you send a product from RN to family and friends overseas.
In addition, RN may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. RN also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual. Further, RN may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
Data may be transferred to the RN’s office and appointed agents in Singapore or other countries in connection with RN’s performance of the contract with you.
Statistical Data is not linked to a customer record and RN does not need to seek consent for the collection, use or disclosure of Statistical Data. For more information on the collection and usage of Customer Data obtained from RN’s websites and through RN’s mobile services facility, please refer to Part B.
RN will, upon your written request to our Personal Data Protection Officer (see Section 10), allow you to access your stored Personal Data. Where permitted by law, RN reserves the right to charge a reasonable administrative fee for this service. Where permitted by law, RN reserves the right to deny you access to your Personal Data and may provide an explanation.
RN will retain Customer Data for as long as it is necessary to fulfill the purpose for which it was collected, the legal or business purposes of RN, or as required by relevant laws.
When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.
RN needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform RN of changes to your Personal Data by contacting RN and submitting your updated particulars to RN in writing (see Section 10). RN may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Use and Disclosure” sub-section, your order information may be disclosed to the appropriate customs and immigration authorities (for overseas purchases) as required by law. As such, it is important to ensure that the Personal Data contained in your order information is current, complete and accurate.
RN takes the security and protection of your Customer Data very seriously. As such, RN makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure.
As an example of a procedural safeguard, RN has implemented various authentication procedures internally and with our external service providers that may involve RN requesting various personal particulars from you in order to verify your identity (or that of your duly authorised agent) before RN processes your request for a particular service, product or transaction.
Examples of technical safeguards include encryption, “firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through RN’s website and RN’s mobile services facility are set out at Part B below. If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, RN will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact RN (see Section 10).
Personal Data Protection Officer
20 Sin Ming Lane
#06-55 Midview City
RN takes the protection of your Customer Data collected on RN’s websites and through RN’s mobile services facility very seriously. All Customer Data collected through RN’s websites, e.g., http://www.renewlifes.com and through RN’s mobile services facility are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems.
For example, when you transmit sensitive information such as credit card details through RN’s websites, such information will be encrypted before being dispatched over the internet.
To further strengthen the integrity of your internet transactions on our websites, RN also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies without notice to you.
You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (like internet explorer). There are also software products available that can manage cookies for you. Please be aware though that when you have set your computer to reject cookies, it can limit the functionality of the website you visit and it’s possible then that you do not have access to some of the features on the website.
In order to improve your online experience, RN may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.
RN cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided RN with Customer Data without parental or guardian consent, the parent or guardian should contact RN to remove the relevant Customer Data and unsubscribe the minor.