Privacy policy

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This privacy policy (Privacy Policy) describes how Personal Data (as defined below) may be processed, collected, used, disclosed and processed by Remy Cointreau International Pte Ltd (company registration number 200805520G) (the Company) in the framework of our professional activities with you as Business Partners (as defined below), in line with the Personal Data Protection Act 2012 (the PDPA) and other regulations pertaining to the same when processing Personal Data. This Privacy Policy applies to all our business partners including but not limited to our suppliers, vendors, B2B clients, distributors, commercial agents, individual clients and all other users who utilise and/or access our services (Business Partners).

1. INFORMATION WE COLLECT
   1. In this Privacy Policy, Personal Data refers to any data which enables an individual to be identified, which includes, but is not limited to:
      1. (a)   personal identification data (such as names, address, e-mail address, telephone number, internal code (as may be assigned by the Company), passport numbers, passport expiry dates);
      
      
      1. (b)   professional data of an economic and financial nature (such as orders, billing and payment conditions, bank details, credit or debit card information);
      
      
      1. (c)   data relating to the management and evaluation of the commercial relationship with the Company;
      
      
      1. (d)   information technology data (such as connection logs, recording of your phone calls, emails and other records of any contact with the Company); and
      
      
      1. (e)   information that you may disclose when you contact or interact with us.
      
      
   2. Where you provide Personal Data as required by, pursuant to, or in connection with the services the Company provides to you or other professional activities as Business Partners (collectively, the Services), you confirm, represent and warrant to the Company that:
      1. (a)   where you are a corporate entity providing information of any individual, you have notified the relevant individual of the purposes for which data will be collected, processed, used or disclosed, and obtained the relevant individual’s consent in accordance with this Privacy Policy, and hereby consent on behalf of the relevant individual to the collection, processing, use and disclosure of his/her personal data by the Company, and confirm that you are authorised by the relevant individual to provide such consent on his/her behalf;
      
      
      1. (b)   you understand the purpose for which data will be collected, processed, used or disclosed and the other terms of this Privacy Policy; and
      
      
      1. (c)   you consent to the collection, processing, use and disclosure of such Personal Data by the Company.
      
      
   3. The Company must promptly be informed upon your withdrawal of consent to the collection, process, use and/or disclosure by the Company of any Personal Data provided to the Company. The withdrawal of such consent may affect the Services.
   4. Any consent given in relation to Personal Data shall, subject to all applicable laws and regulations, survive death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of any account in connection with the Services.
   5. You shall ensure at all times that any information provided (including any Personal Data) to the Company is correct, accurate and complete.
   6. The Company shall be entitled to combine information provided to the Company in any manner, and with information from any third party.

1. PURPOSES OF PROCESSING
   1. The Company may collect, store, process, disclose, access, review and/or use Personal Data in accordance with the PDPA or any other written law.
   2. Without prejudice to the foregoing, the Company may use Personal Data for any of its business purposes, which include, and is not limited to, the following:
      1. (a)   to manage our commercial relationship;
      
      
      1. (b)   to carry out or respond to feedback, questions, requests, complaints or orders from you;
      
      
      1. (c)   for the marketing of products and services, including but not limited to sending you relevant information about our events, news announcements or promotions (such as newsletters);
      
      
      1. (d)   for internal administrative management as well as billing and payment management;
      
      
      1. (e)   to conduct background check and due diligence procedures;
      
      
      1. (f)   to facilitate statistical analysis, product development, service refinements and market research;
      
      
      1. (g)   to prevent fraud and ensure compliance;
      
      
      1. (h)   to comply with any applicable laws, rules or regulations in any country;
      
      
      1. (i)   for legal purposes in enforcing the Company’s rights, procuring legal advice and dispute resolution; and
      
      
      1. (j)   purposes reasonably related to the aforesaid.
      
      
   3. We will only use your Personal Data for the purposes for which we collected the same, and in the circumstances in which the Company may use Personal Data without the consent of the individual as provided under the PDPA, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Where the reason is not compatible with the original purpose, we will obtain your separate consent prior to such usage of your Personal Data. To the extent necessary, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
   4. You consent to receiving communication (through any medium whatsoever) from the Company, which may include marketing materials such as newsletters, updates and promotions about our products and services and may opt out of receiving such communication by informing the Company in writing.

1. DATA RECIPIENTS
   1. The Company may from time to time also disclose Personal Data to any of the Company’s shareholders, directors, officers and employees and the following parties (whether in or outside Singapore):
      1. (a)   service providers who provide operation, administrative or other services to the Company in connection with the Company’s business operations and/or website(s) (such as providers of web hosting and maintenance services or communication agencies);
      
      
      1. (b)   any person or entity employed by or on behalf of the Company or is a part of or related to any group of companies of which the Company forms part of or is affiliated to, including but not limited to the other entities of the Rémy Cointreau Group;
      
      
      1. (c)   any actual or proposed assignee of the Company or transferee of the Company’s rights in respect of all or any part of the assets or business of the Company;
      
      
      1. (d)   any person or entity for the purposes of meeting or complying with the Company’s internal policies and procedures and any applicable rules, laws, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (both national and international) (including but not limited to disclosures to regulatory bodies, conducting auditing checks or any investigations); and
      
      
      1. (e)   any person or entity for the purposes of ensuring the protection against, and prevention of harm (collectively, the Third Parties).
      
      
   2. As the Company continues to develop its business, the Company may sell or purchase assets. If another entity acquires or merges with the Company, your Personal Data may be disclosed to such entity.
   3. The Company shall not be liable for the manner or care in which any Third Party maintains, protects or utilises your Personal Data.

1. SECURITY MEASURES
   1. The Company will use all reasonable endeavors to secure the Personal Data and prevent it from abuse, misuse, interference, loss and against unauthorised access, alteration or disclosure.
   2. The Company will use reasonable and appropriate information security safeguards to help keep the Personal Data secure. Among others, the Company will utilise the following security measures:
      1. (a)   pseudonymisation of certain categories of your Personal Data;
      
      
      1. (b)   encryption of your Personal Data in transit and in rest;
      
      
      1. (c)   regular vulnerability scanning and penetration testing;
      
      
      1. (d)   the Company’s organisational measures (access control, restriction of access); and
      
      
      1. (e)   conduct of periodical data protection impact assessments and privacy audit.
      
      
   3. Whilst the Company will utilise reasonable security arrangements (in line with industry standards) to ensure the security of the Personal Data, please be aware that the Company cannot guarantee absolute security of the same.

1. DATA BREACH
   In the event of a data breach that relates to the unauthorised access, collection, use, disclosure, copying or modification of Personal Data that is, or is likely to be of a significant scale or results in, or is likely to result in, significant harm to you (as assessed by the Company), the Company shall notify you of such a breach unless it is prevented by law from doing so or it is permitted by law to not do so.

1. ACCESS AND CORRECTION, AMENDMENTS AND UPDATES
   1. If you wish to access or correct the Personal Data that the Company has relating to you, inquire about the ways in which Personal Data relating to you has been or may have been used or disclosed by the Company within the past year, or wish to withdraw your consent to our use of such Personal Data, you may contact the Company (and the data protection officer) at . The Company will seek to attend to your request as best as we reasonably can. The Company reserves the right to charge such fees as it may incur for the granting of such access or the correction of any Personal Data.
   2. Where there is an ongoing relationship with the Company, your control over your Personal Data extends to your right to make a porting request for your Personal Data to be transmitted to another entity. Please note that the Company may be prevented by law from complying with such a request of transmitting certain types of Personal Data.
   3. This Privacy Policy may be amended and updated by the Company from time to time. Any such amendment or update will be made available to you so long as our business relationship remains. All communications, transactions and dealings with the Company will be subject to the latest version of this Privacy Policy in force at the relevant time.
   4. The Company’s rights under this Privacy Policy shall be without prejudice to other rights of collection, use and disclosure available pursuant to such terms and conditions under the law and nothing herein is to be construed as limiting any of these other rights.

1. DATA RETENTION PERIOD
   The Company may also retain Personal Data for so long as one or more of the purposes for which it was collected remains valid, where required or permitted by regulation or law (national or international), or as it may deem necessary for the purposes of record retention and for its own business purposes.

1. ACKNOWLEDGMENTS AND DISCLAIMERS
   1. You acknowledge that your Personal Data is transmitted to the Company at your own risk. Please contact the Company immediately if you become aware or have reason to believe there has been any unauthorised use of your Personal Data.
   2. To the maximum extent permitted by law, you agree that the Company shall not be liable in any event for any direct, indirect, incidental, consequential or special damages suffered as a result of unauthorised or unintended use, access or disclosure of your Personal Data.

1. GOVERNING LAW
   This Privacy Policy shall be governed in all respects by the laws of Singapore

1. CONTACT US If you have any questions about this Privacy Policy or wish to contact the Company in connection with this Privacy Policy, please contact our data protection officer through the email [privacy@remy-cointreau.com] or at the following postal address:
   REMY COINTREAU INTERNATIONAL PTE LTD
   152 Beach Road
   #33-01 Gateway East
   Singapore 189721
   
   Last update: [February 2021]