a) What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Singapore`s Personal Data Protection Act 2012 (“PDPA”) and the General Data Protection Regulation (“GDPR”).
b) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
c) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
d) Who is responsible for data processing?
The responsible party within the meaning of the PDPA and the GDPR is Straits Agriculture of 511 Upper Jurong Road, d’Arena, Block A Level 2 (Rooftop), Singapore 638366 (“Straits Agriculture”, “we”, “us”, or “our”). If you have any questions about this Policy or our data protection practices, please contact us using our Contact Form or email us at email@example.com.
e) What are the legal bases of processing?
In accordance with the PDPA and GDPR, we have to have at least one of the following legal bases to process your Personal Data:
you have given your consent,
the data is necessary for the fulfillment of a contract / pre-contractual measures,
the data is necessary for the fulfillment of a legal obligation or
the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
DATA WE COLLECT AUTOMATICALLY
a) Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
To provide our website, we use the services of GoDaddy.com, LLC who processes all data to be processed in connection with the operation of this website on our behalf. The legal basis for processing is our legitimate interest.
c) Content Delivery Network
We use Wix.com LTD`s Content Delivery Network (CDN) to distribute our online content. Wix.com LTD`s CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.
d) Provision of the Shop
We also use the store system of Wix.com LTD, for the purpose of hosting and displaying the website and shop on the basis of processing on our behalf. All data collected on our website is processed on Wix.com LTD's servers. The legal basis for the data processing is our legitimate interest in providing an appealing website and shop.
We use Google LLC`s reCAPTCHA to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for the data processing is our legitimate interest in operating a secure and spam free website.
DATA WE COLLECT DIRECTLY
a) Contacting us
Personal Data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data.
For the Chat, we use Ascend by Wix.com Ltd. We have no influence on the processing of data by Wix and no possibility to influence it.
We are present on social media (currently Facebook and Instagram) on the basis of our legitimate interest. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement.
The Personal Data collected when you contact us is used to process your request and the legal basis is your consent.
b) Order processing
When you place an order in our online shop, we store your full name, your e-mail address, your address (billing address and, if applicable, different delivery address). In order to fulfill that contract, we will also process your data for delivery and use your telephone number so that we can deliver your order and contact you before delivery for the purpose of delivery notification or coordination.
c) Account Creation
If you create an account, we will collect and store the data you enter during registration (e.g., your email and password). At the same time, we also store your IP address and verify the creation of your account by sending you an activation e-mail.
Alternatively, you are able to sign up using the convenience log in and sign up from Google LLC or Facebook. For convenience log in and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture) linked to your account. If granted, your username and password will be auto generated to fill in the rest of required user data. When registering via our convenience function, you agree to the relevant terms and conditions and consent to certain data from your respective profile of being transferred to us.
In both cases, the legal basis for the processing is your consent. You may withdraw your consent by deleting your account by contacting us.
d) Payment Data
e) Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
f) Contractual notifications and Newsletter
By making a purchase, we will need to send you because of our legal obligation an invoice and other contractual documents and for this purpose we will use your e-mail address. Equally, you may also sign up for our newsletter. Those typically include administrative information as well as service and product updates. Our newsletter is sent as part of processing on our behalf by Wix.com Ltd to whom we pass on your e-mail address for this purpose.
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
We may also use Facebook Remarketing by Meta Platforms Inc to advertise on social media. If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).
h) Market Research
For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors, and users of our shop.
The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarized data).
PRINCIPLES OF PROCESSING PERSONAL DATA
a) Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
c) Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
e) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
f) Do Not Sell
We do not sell your Personal Data.
g) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services including our overseas fulfillment and shipping forwards, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
h) International Transfer
YOUR RIGHTS AND PRIVILEGES
a) Privacy rights
Under the PDPA and GDPR, you have the following rights:
Right to information
Right to rectification
Right to object to processing
Right to deletion
Right to data portability
Right of objection
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
b) Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Singapore is the Personal Data Protection Commission, 10 Pasir Panjang Road, #03-01 Mapletree Business City, Singapore 117438 www.pdpc.gov.sg.
CHANGES AND QUESTIONS
Wednesday, 03 May 2023