We want you to understand why and how Sleek Tech Pte. Ltd. and Sleek Hong Kong Limited (“SLEEK”, “we”, “us” and/or “our”) collects, uses, discloses and or/processes your Personal Data (as defined below) under Singapore’s Personal Data Protection Act 2012 (the “PDPA”), Hong Kong’s Personal Data Privacy Ordinance (Cap. 486) (the “PDPO”) and the European General Data Protection Regulation (the “GDPR”).
This Policy supplements but does not supersede or replace any previous consent which you may have provided to SLEEK, nor does it affect any legal rights that SLEEK may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data.
SLEEK may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at www.sleek.com (the “SLEEK Website”). Notification of any material revisions will also be published on the SLEEK Website. You shall be deemed to have accepted the Policy as amended by continuing your relationship with SLEEK after any amendments have been published on the SLEEK Website, .
This Policy forms part of the terms and conditions, if any, governing your specific relationship with SLEEK (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
1) Definitions: For the purposes of this Policy:
“Individual” (or “you”) means a natural person, whether living or deceased and “Individuals” (and “your”) shall be construed accordingly;
“Personal Data” means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to SLEEK;
“Personnel” means any Individual engaged under a contract of service with SLEEK including permanent or temporary employees as well as trainees and interns engaged by SLEEK from time to time; and
“Potential Personnel” means any Individual who has submitted an application to be engaged by SLEEK as Personnel.
Purposes for collection, use and disclosure of Personal Data
SLEEK will only collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:
a) Facilitating SLEEK’s provision of products and services which are used by you;
b) Communicating with you to assist you with your enquiries;
c) Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you;
d) Conducting market research and customer satisfaction surveys;
e) Any other purposes that we notify you of at the time of obtaining consent (collectively known as the “Purposes”).
The Purposes for which we may/will collect, use, or disclose your Personal Data depend upon the circumstances at hand. We will notify you of the purpose at the time of obtaining your consent to collect the data.
2) How SLEEK collects Personal Data
Generally, SLEEK may collect Personal Data from you in one or more of the following ways or circumstances:
a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services.
b) Information collected automatically: Some information is collected automatically, such as an IP address and device type, when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.
c) Information from third parties: The majority of information that we collect is collected directly from you. Some data may be collected from other sources, such as information that is available in the public domain. We use this information to supplement the Personal Data that we have collected from you.
3) Processing Personal Data
Where we collect Personal data, we will only process it:
a) To perform a contract with you, or
b) Where we have a legitimate interest to protect the Personal Data which is not overridden by your rights, or
c) In accordance with a legal obligation, or
d) Where we have your consent.
Unless otherwise authorised under the PDPA, PDPO, GDPR or any other applicable law, SLEEK will not collect, use or disclose your Personal Data without your knowledge and consent. SLEEK will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data.
SLEEK may obtain your consent by any of the following means:
a) via express provisions in a contract, application form and/or registration form to be signed with or submitted to SLEEK;
b) via notifications on SLEEK’s websites;
In so far as any Purpose(s) are intrinsic to the relationship or provision of services, SLEEK reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to SLEEK’s collection, use or disclosure of your Personal Data for such purposes.
- voluntarily provide Personal Data to SLEEK for any specified purpose;
- use or access SLEEK’s website(s) or computer network;
- enter SLEEK’s premises or use any of the facilities thereon; and/or
- attend or participate in events or programmes organised by SLEEK
If you provide SLEEK with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, you represent to SLEEK that you have obtained the consent of the relevant third party for SLEEK to collect, use or disclose such Personal Data for the relevant purpose.
5) Disclosure of Personal Data
There may be occasions where we may need to share your Personal Data with third parties. SLEEK will disclose your Personal Data only in the following circumstances:
a) to SLEEK’s third party service providers or agents;
b) to SLEEK’s auditors and professional advisors;
c) to regulators, law enforcement bodies, government agencies, courts or any other third party to whom disclosure is permitted or required by any applicable law or regulation;
d) to other parties where we have your consent.
6) Request to Withdraw Consent
You have the right to withdraw your consent to the collection, use and/or disclosure of your Personal Data in the possession of SLEEK by submitting your request to SLEEK’s Data Protection Officer at firstname.lastname@example.org at any time.
We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, use and/or disclose your Personal Data in the manner stated in your request.
Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing business relationship.
7) Security of Personal Data.
SLEEK shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
If SLEEK transfers Personal Data outside of Singapore (or Hong Kong, in the case of our Hong Kong operations), SLEEK will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and PDPO and such transfer shall be subject to this Policy.
SLEEK will ensure that third parties who receive Personal Data from SLEEK protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by SLEEK, by incorporating appropriate contractual terms in its written agreements with third parties.
SLEEK is not responsible in any way for the security and/or management of Personal Data shared by you with third party websites accessible via links on SLEEK’s website.
8) Accuracy of Personal Data
Information voluntarily provided by you to SLEEK shall be deemed complete and accurate.
SLEEK will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you to SLEEK is complete and accurate.
SLEEK will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying SLEEK, from time to time, of any applicable changes to your Personal Data. You can amend your Persona Data on the Sleek Platform or you may notify our customer success team of any changes to your Personal Data by email at email@example.com, or you may contact the Personal Data Officer by email at firstname.lastname@example.org at any time.
SLEEK shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to SLEEK is complete and accurate.
9) Access to and correction of Personal Data
You may request (i) access to any Personal Data that is currently in our possession or control; and/or (ii) correction of any data that is currently in our possession or control by contacting us by email at email@example.com.
When you request access to your Personal Data within our possession or control, we will seek to provide you with the relevant information within 14 days.
Upon your written request, we will correct any inaccurate Personal Data that is within our possession or control within 14 days.
With your consent, once we have corrected your Personal Data, we will send the corrected Personal Data to all organisations to which your Personal Data was disclosed by Sleek within a year before the correction was made, unless that organisation does not require the corrected Personal Data for any legal or business purpose.
SLEEK is not required, under the PDPA and PDPO, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA or PDPO.
10) Retention of Data
The length of time that we keep your Personal Data depends on what it is and whether we have an ongoing business need to retain it.
We will only retain your data for as long as we have a business relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, or where we are required by law to retain it.
Upon the expiry of time relating to any business needs or legal requirements to retain your Personal Data we will ensure that your Personal Data is deleted or anonymised.
11) Making a complaint
You are welcome to contact us if you have any complaint or grievance about how we are handling any Personal Data in our control or possession.
To make a complaint you can:
a) Contact our Data Protection Officer via email at firstname.lastname@example.org;
b)Contact us by telephone during our office hours (9:00am to 6:00 pm) at +65 6909 2214; or +852 8191 6911;
c) Visit us in person at our Singapore or Hong Kong office during our office hours (9:00am to 6:00pm).