Data Protection Policy

  1. Generally, Party A and/or any of its Affiliates shall collect your personal data in any of the following ways:

i. when you purchase the Product;
ii. when you request that we contact you;
iii. when you are contacted by, and respond to, our marketing representatives and agents;
iv. when you interact with our customer services officers;
v. when you establish any online accounts with us;
vi. when you respond to our request for additional personal data;
vii. when you ask to be included in an email or other mailing list; and/or
viii. when you submit your personal data to us for any other reason.

  1. You consent to Party A or any of its Affiliates collecting, using, disclosing and/or processing data relating to you for the following purposes:

i. to administer the Warranty;
ii. to keep you informed by post or telephone about other Party A products and services that may be of interest to you;
iii. responding to your queries, requests or complaints;
iv. verifying your identity, such as know-your client checks and credit-worthiness checks;
v. preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
vi. protecting and enforcing our contractual and legal rights and obligations;
vii. compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
viii. verifying and processing your personal particulars and payments in relation to the supply of the Products to you;
ix. communicating with you to inform you of changes and developments to Party A’s policies, terms and conditions and other administrative information, including for the purposes of providing the Products to you;
x. resolving complaints and handling requests and enquiries;
xi. conducting market research for profiling and statistical analysis for the improvement of our Products offered to you;
xii. conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and develop special offers and marketing programmes;
xiii. providing other services, products and benefits to you, including promotions, loyalty and reward programmes, and sending you details of the same which may be of interest to you; and
xiv. matching personal data with other data collected for other purposes and from other sources (including third parties) in connection with the supply or offering of products and services, whether by Party A, its Affiliates, or other third parties; and
xv. processing your personal data in relation to any of the purposes stated above.

  1. In connection with your consent provided in Section 4b, Party A or any of its Affiliates may disclose your personal data to the following third parties, wherever they may be located:

i. any other Affiliates of Party A;
ii. agents, contractors or third-party service providers who provide operational services to Party A, including for the purpose of providing the Products;
iii. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
iv. our professional advisors such as our auditors and lawyers;
v. relevant government regulators or law enforcement agency to comply with any applicable rules and regulations imposed by such authorities; and
vi. any other party to whom you authorise us to disclose your personal data.

  1. For the purposes of this Section 4, “processing” in relation to personal data shall refer to the carrying out of any operation or set of operations in relation to the personal data, which includes (i) recording, (ii) holding, (iii) organization, adaptation or alteration, (iv) retrieval, (v) combination, (vi) transmission; or (vii) erasure or destruction in accordance with the Personal Data Protection Act 2012.
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