PRIVACY POLICY 

Updated 1st November 2020 

NC (SINGAPORE) PTE. LTD. (“we” or “us” or “our”) respects the privacy of our customers (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application or the associated website, collectively termed as the “Platform”s, in compliance with the Singapore Personal Data Protection Act 2012 (the “Act”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE PLATFORM. 

By accessing and using the Coolfix website or the Coolfix mobile application (collectively, the “Platform”) you agree to the consent to the collection, use and disclosure of your Personal Data in accordance with this Policy. 

1 

PERSONAL DATA 

1.1 

“Customer” (or “you”, “your”) means an individual who has 

(a) 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 goods and services by us. 

1.1 

“Personal Data” means data, whether true or not, about a customer who can be identified from: 

(a) That data; or 

(b) That data and other information which we have or are likely to have access to. 

1.3 

Examples of personal data which may be collected from you, include but are not limited to the following: 

(a) your name; 

(b) contact information such as your residential address, email address, or telephone number; 

(c) personal particulars such as your nationality, date of birth, marital status, 

(d) photographs and other audio-visual information; 

(e) employment information; and 

(f) financial information such as credit card numbers, debit card numbers or bank account information. 

2 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA 

2.1 

Your Personal Data may be collected by us generally only where: 

(a) you have provided it to us voluntarily, either directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) and; 

(i) you, or where applicable, 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 your consent is permitted or required by the Act or other laws. 

2.2 

We will seek your consent before collecting any Personal Data and before using your Personal Data for purposes which have not been notified to you, except where permitted or authorised by law. 

3 

PURPOSES OF COLLECTION AND USE OF PERSONAL DATA 

3.1 

We may collect and use your Personal Data for any or all of the following purposes: 

(a) performing obligations in the course of 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 you marketing information about our goods and/or services including notifying you of our marketing events, initiatives and promotions, lucky draws, memberships, reward schemes and other promotions; 

(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules to assist in law enforcement, and investigations conducted by any governmental and/or regulatory authority; 

(h) transmitting to any unaffiliated third parties, including our third-party service providers and agents, and 

(i) any other incidental business purposes related to or in connection with the above. 

4 

DISCLOSURE OF PERSONAL DATA 

4.1 

We may disclose your Personal Data in the following situations: 

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and/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 4.1(a) above for us. 

4.2 

The purposes listed in the above clauses 3 and 4 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). 

5 

WITHDRAWING YOUR CONSENT 

5.1 

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. 

5.2 

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. 

5.3 

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. 

5.4 

In general, we shall seek to process your request within ten (10) business days of receiving it. 

5.5 

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 able 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 5.2 above. 

5.6 

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 applicable laws. 

6 

ACCESS TO AND CORRECTION OF PERSONAL DATA 

6.1 

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. 

6.2 

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. 

6.3 

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 Act). 

7 

PROTECTION OF PERSONAL DATA 

7.1 

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. 

7.2 

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 security measures. 

8 

ACCURACY OF PERSONAL DATA 

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 at dpo.nch@natcool.com 

9 

RETENTION OF PERSONAL DATA 

9.1 

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. 

9.2 

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 business purposes. 

10 

TRANSFER OF PERSONAL DATA OUTSIDE SINGAPORE 

10.1 

Your Personal Data may be transferred to, stored, used and processed in a country other than Singapore, to our partners in other countries. You understand and consent to the transfer of your Personal Data to our partners in other countries. 

10.2 

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 Act. 

11 

DATA PROTECTION OFFICER 

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 at dpo.nch@natcool.com 

12 

EFFECT OF POLICY AND CHANGES TO POLICY 

12.1 

This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. 

12.2 

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 Policy was last updated. 

12.3 

Your continued use of our services constitutes your acknowledgement and acceptance of such changes. 

13 

COOKIE POLICY 

13.1 

When you access our Platform, we may send a small data file to your browser, which will store and track information about you (“Cookies”). Such information could include how frequently 

you access our Platform, and what pages that you access, and could include Personal Data. Cookies cannot read and store data off your hard disk. 

13.2 

You have the choice of accepting or declining Cookies. You may deactivate Cookies by modifying the settings of your internet browser. However, this may interfere with your taking full advantage of the website. 

13.3 

Where you do not deactivate Cookies by modifying the settings of your internet browser, you agree to accept Cookies and the collection of Personal Data through Cookies. 

13.4 

THIRD-PARTY WEBSITES 

The Platform may contain links to third-party websites and applications of interest, including advertisements and external services that are not affiliated with us. Once you have used these links to leave the Platform, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Platform. 

CONTACT US 

If you have questions or comments about this Privacy Policy, please contact us via email at: 

dpo.nch@natcool.com