DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis
which LS Aesthetic Clinic (“we”, “us”, or “our”) may collect, use, disclose or
otherwise process personal data of our customers in accordance with the
Personal Data Protection Act (“PDPA”).
This Notice applies to personal data in our possession or
under our control, including personal data in the possession of organisations
which we have engaged to collect, use, disclose or process personal data for
1. As used in this Notice: “customer” means an individual
who (a) has contacted us through any means to find out more about any goods or
services we provide, or (b) may, or has, entered into a contract with us for
the supply of any goods or services by us; and “personal data” means data,
whether true or not, about a customer who can be identified: (a) from that
data; or (b) from that data and other information to which we have or are
likely to have access.
2. Depending on the nature of your interaction with us, some
examples of personal data which we may collect from you at our clinic or online
include your name and identification information such as your NRIC number,
contact information such as your address, email address or telephone number,
nationality, gender, date of birth, marital status, photographs and other
audio-visual information, employment information and financial information such
as credit card numbers, debit card numbers or bank account information.
Online, we may also collect other forms of personal data
such as cookies, IP addresses or analytics:
Cookies are text files put on your computer to
collect standard internet log information and visitor behaviour
information. This information is then used to track visitor use of the
website and to create statistical reports on website activity, but we do not
use these to personally identify you. For more information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above
websites tell you how to remove cookies from your browser. Please note in
a few cases some of our website features may not function because of this.
We use Google Analytics to store information about how
visitors use our website so that we may make improvements and give visitors a
better user experience.
Google Analytics is a third-party information storage system
that records information about the pages you visit, the length of time you were
on specific pages and the website in general, how you arrived at the site and
what you clicked on when you were there. These cookies do not store any
personal information about you, such as your name, address etc and we do not
Internet Based Advertising
We use Facebook and Google advertising services. As such,
there are tracking codes installed on our website so that we can manage the
effectiveness of these campaigns. We do not store any personal data within
this type of tracking.
3. Other terms used in this Notice shall have the meanings
given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a)
it is provided to us voluntarily by you directly or via a third party who has
been duly authorised by you to disclose your personal data to us (your
“authorised representative”) after (i) you (or your authorised representative)
have been notified of the purposes for which the data is collected, and (ii)
you (or your authorised representative) have provided written consent to the
collection and usage of your personal data for those purposes, or (b)
collection and use of personal data without consent is permitted or required by
the PDPA or other laws. We shall seek your consent before collecting any
additional personal data and before using your personal data for a purpose
which has not been notified to you (except where permitted or authorised by
5. We may collect and use your personal data for any or all
of the following purposes: (a) performing obligations in the course of or in
connection with our provision of the goods and/or services requested by you;
(b) verifying your identity; (c) responding to, handling, and processing
queries, requests, applications, complaints, and feedback from you; (d)
managing your relationship with us; (e) processing payment or credit
transactions; (f) sending your marketing information about our goods or
services including notifying you of our marketing events and initiatives; (g)
complying with any applicable laws, regulations, codes of practice, guidelines,
or rules, or to assist in law enforcement and investigations conducted by any
governmental and/or regulatory authority; (h) any other purposes for which you
have provided the information; (i) transmitting to any unaffiliated third
parties including our third party service providers and agents, and relevant
governmental and/or regulatory authorities, whether in Singapore or abroad, for
the aforementioned purposes; and (j) any other incidental business purposes
related to or in connection with the above.
6. We may disclose your personal data: (a) where such
disclosure is required for performing obligations in the course of or in
connection with our provision of the goods or services requested by you; or (b)
to third party service providers, agents and other organisations we have
engaged to perform any of the functions listed in clause 5 above for us.
7. The purposes listed in the above clauses may continue to
apply even in situations where your relationship with us (for example, pursuant
to a contract) has been terminated or altered in any way, for a reasonable
period thereafter (including, where applicable, a period to enable us to
enforce our rights under any contract with you).
WITHDRAWING YOUR CONSENT
8. The consent that you provide for the collection, use and
disclosure of your personal data will remain valid until such time it is being
withdrawn by you in writing. You may withdraw consent and request us to stop
using and/or disclosing your personal data for any or all of the purposes
listed above by submitting your request in writing or via email to our Data
Protection Officer at the contact details provided below.
9. Upon receipt of your written request to withdraw your
consent, we may require reasonable time (depending on the complexity of the
request and its impact on our relationship with you) for your request to be
processed and for us to notify you of the consequences of us acceding to the
same, including any legal consequences which may affect your rights and
liabilities to us. In general, we shall seek to process your request within ten
(10) business days of receiving it.
10. Whilst we respect your decision to withdraw your
consent, please note that depending on the nature and scope of your request, we
may not be in a position to continue providing our goods or services to you and
we shall, in such circumstances, notify you before completing the processing of
your request. Should you decide to cancel your withdrawal of consent, please
inform us in writing in the manner described in clause 8 above.
11. Please note that withdrawing consent does not affect our
right to continue to collect, use and disclose personal data where such
collection, use and disclose without consent is permitted or required under
ACCESS TO AND CORRECTION OF PERSONAL DATA
12. If you wish to make (a) an access request for access to
a copy of the personal data which we hold about you or information about the
ways in which we use or disclose your personal data, or (b) a correction
request to correct or update any of your personal data which we hold about you,
you may submit your request in writing or via email to our Data Protection
Officer at the contact details provided below.
13. Please note that a reasonable fee may be charged for an
access request. If so, we will inform you of the fee before processing your
14. We will respond to your request as soon as reasonably
possible. Should we not be able to respond to your request within thirty (30)
days after receiving your request, we will inform you in writing within thirty
(30) days of the time by which 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 shall generally inform you of the reasons why we are
unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
15. To safeguard your personal data from unauthorised
access, collection, use, disclosure, copying, modification, disposal or similar
risks, we have introduced appropriate administrative, physical and technical
measures such as up-to-date antivirus protection, encryption and the use of
privacy filters to secure all storage and transmission of personal data by us,
and disclosing personal data both internally and to our authorised third party
service providers and agents only on a need-to-know basis.
16. You should be aware, however, that no method of
transmission over the Internet or method of electronic storage is completely
secure. While security cannot be guaranteed, we strive to protect the security
of your information and are constantly reviewing and enhancing our information
ACCURACY OF PERSONAL DATA
17. We generally rely on personal data provided by you (or
your authorised representative). In order to ensure that your personal data is
current, complete and accurate, please update us if there are changes to your
personal data by informing our Data Protection Officer in writing or via email
at the contact details provided below.
RETENTION OF PERSONAL DATA
18. We may retain your personal data for as long as it is
necessary to fulfil the purpose for which it was collected, or as required or
permitted by applicable laws.
19. We will cease to retain your personal data, or remove
the means by which the data can be associated with you, as soon as it is
reasonable to assume that such retention no longer serves the purpose for which
the personal data was collected, and is no longer necessary for legal or
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
20. We generally do not transfer your personal data to
countries outside of Singapore. However, if we do so, we will obtain your consent
for the transfer to be made and we will take steps to ensure that your personal
data continues to receive a standard of protection that is at least comparable
to that provided under the PDPA.
DATA PROTECTION OFFICER
21. You may contact our Data Protection Officer if you have
any enquiries or feedback on our personal data protection policies and
procedures, or if you wish to make any request, in the following manner:
LS Aesthetic Clinic Pte Ltd
Phone: 6738 4700
EFFECT OF NOTICE AND CHANGES TO NOTICE
22. This Notice applies in conjunction with any other
notices, contractual clauses and consent clauses that apply in relation to the
collection, use and disclosure of your personal data by us.
23. We may revise this Notice from time to time without any
prior notice. You may determine if any such revision has taken place by
referring to the date on which this Notice was last updated. Your continued use
of our services constitutes your acknowledgement and acceptance of such
Effective date : 23/5/2018 Last updated : 23/5/2018