Personal Data Protection Policy

The purpose of this Privacy Policy is to inform you of how we manage Personal Data which is subject to the Act and to set out the type of Personal Data we gather about you, what we do with it, the safeguards we have in place to protect it, and how you can control our use of it. By interacting with us, using our websites and/or submitting Personal Data at our stores, call centres and/or our websites, you agree and consent to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorized service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

Where your personal data is covered by the General Data Protection Regulation (EU) 2016/679 (“GDPR”), please refer instead to our GDPR privacy policy which can be found here .

I. PERSONAL DATA

In this PDP Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include your name, last four characters of your NRIC, passport or other identification number, telephone numbers, mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

II. COLLECTION OF PERSONAL DATA

Generally, we may collect Personal Data from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources in the following ways:

(a) when you submit forms relating to or purchase or use any of our products or services;
(b) when you interact with our personnel, agents, sales representatives or customer service officers, including via telephone calls, SMS, mail, face-to-face meetings and emails;
(c) when you respond to our queries or you request that we contact you or be included in an email or other mailing list;
(d) when you respond to our surveys, promotions or other incentives;
(e) when we receive references from business partners and third parties, for example, where you have been referred by them;
(f) when you submit your Personal Data to us for any other reasons;
(g) when you use our websites; and
(h) when you choose to pay be credit or debit card for any of your purchases at our LAC stores.

If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

III. PURPOSES FOR COLLECTION, USAGE AND DISCLOSURE

We collect, and may use and disclose your Personal Data for the following purposes (“ Purposes ”): (a) to process your orders;
(b) to allow us to provide you access to products and services and any relevant customer support;
(c) managing our administrative and business operations or that of any of our related corporations and complying with internal policies and procedures;
(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us or any of our related corporations;
(e) matching any Personal Data held which relates to you for any of the purposes listed herein;
(f) resolving complaints and handling requests and enquiries;
(g) preventing, detecting and investigating crime and analysing and managing commercial risks;
(h) providing media announcements and responses;
(i) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(j) organising and informing you about promotional events;
(k) legal purposes (including but not limited to obtaining legal advice and dispute resolution);
(l) conducting investigations relating to disputes, billing or fraud;
(m) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
(n) purposes which are reasonably related to the aforesaid.

Where permitted under the Act, we may also collect, use and disclose your Personal Data for the following “Additional Purposes” :

(a) conducting market research and surveys to enable us to understand and determine customer preferences and demographics to develop special offers and marketing programmes in relation to our products and services, and to improve our service delivery and our customers’ experience at our touchpoints;
(b) providing additional products and services and benefits to you, including our promotions, loyalty and reward programmes;
(c) data analytics and research;
(d) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of our products and services;
(e) leads generation and management for marketing our products and services;
(f) administering contests, competitions and marketing campaigns, and personalising your experience at our touchpoints;
(g) communicating to you advertisements involving details of our products and services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and online marketing);
(h) organising promotional events;
(i) to continually assess and improve the products and services we offer; and
(j) purposes which are reasonably related to the aforesaid.

In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

IV. DISCLOSURE OF PERSONAL DATA
We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Information provided by you is not sold to other parties for any commercial purposes.

Notwithstanding the above, subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed below (where applicable), to the following:

(a) our business units, related corporations and employees to provide products and services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our products and services, to activate, deactivate, install, maintain and operate our systems and/or services;
(b) companies providing services to us relating to insurance and consultancy;
(c) agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services;
(d) 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) involving us or any of our related corporations;
(e) vendors or third party service providers in connection with marketing promotions and services offered by us;
(f) our professional advisers such as auditors and lawyers;
(g) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(h) any other party to whom you authorise us to disclose your Personal Data to.

In addition, where permitted under the Act and subject to the provisions of any applicable law:-

(a) your Personal Data may be disclosed, for the Additional Purposes, to our agents or other third party service providers in connection with promotions and services offered by us;
(b) some of our operations, such as our electronic commerce, may be managed by service providers who are unaffiliated companies. These companies may share Personal Data with their affiliates and with service providers whom they engage to perform services related to our website or the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfilment and shipping, marketing and promotional material distribution, web site evaluation, data analysis and, where applicable, data cleansing. These companies may have access to your Personal Data on a confidential basis only to the extent necessary to perform their functions. In no event will we authorize these companies to use your Personal Data for any reason other than to provide you with those specific services; and
(c) we may disclose your Personal Data to our related corporations for the purpose of allowing our related corporations to collect, use, and disclose your Personal Data for all of the same purposes for which we are allowed to collect, use, and disclose your Personal Data. Our related corporations include our subsidiaries, holding companies, and the subsidiaries of all of our holding companies up to our ultimate holding company.

V. ADDITIONAL INFORMATION ABOUT OUR WEBSITES
Visiting Our Sites: In general, you can visit our websites without telling us who you are or providing us with any information. However, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system and average time spent on our websites. We use this information to monitor and improve our websites. Cookies: Our websites use a technology called "cookies". A cookie is a tiny element of data that our websites can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. All pages on our websites where you are prompted to log in or that are customizable require that you accept cookies. If you have registered with our websites, these cookies (1) may let us know who you are, (2) are necessary to access your account information ( stored on our computers) in order to deliver products and personalized services, and (3) will provide us and our service providers with information that we will use to personalize our websites in accordance with your preferences. Cookies are a lso required to optimize your shopping experience in that they allow you to add multiple items to your shopping basket before checking out. You may set your web browser to notify you when you receive a cookie. However, should you decide not to accept cookies from our websites, you will limit the functionality we can provide when you visit our websites.

Security of Personal Data: We maintain administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Data in our custody and control. We also are committed to employing reasonable technology in order to protect the security of our websites. We will take reasonable measures which we believe are appropriate to protect your Personal Data from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer such information to take comparable steps to protect that security.

Secure Shopping: When you place orders on our websites, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our websites from capturing and viewing your Personal Data. Since any order information you provide to us on our websites will be transmitted using a secure connection, if your web browser cannot support this level of security, you will not be able to order products through our websites. Passwords: To provide you with an increased level of security, online access to your Personal Data is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or e-mail messages).

VI. CONTACT VIA TELEPHONE NUMBER(S)
If you have provided your Singapore telephone number(s), we may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).

VII. WITHDRAWAL, ACCESS AND CORRECTION
You may withdraw your consent to any of the aforementioned purposes at any time by emailing us at dpo.sg@lac.com .

You may also request for access to and/or correction of your Personal Data which we have collected from you by contacting our Data Protection Officer at dpo.sg@lac.com .

VIII. RETENTION
We will retain your Personal Data for such duration of time to carry out the purposes for which your personal data was collected, for the other purposes set out in this policy, for business purposes and as required by relevant laws.

IX. GOVERNING LAW AND JURISDICTION
This PDP Policy shall be governed by and construed in accordance with the laws of Singapore. The parties irrevocably agree to submit to the non-exclusive jurisdiction of the courts of Singapore as regards any claim or matter arising in relation to this Policy. The Contracts (Rights of Third Parties) Act (Cap. 53B) shall not apply to the Policy.

X. UPDATES TO THE POLICY
We may, at any time and without notice, add to, change, update or modify this PDP Policy, simply by notifying you of such change, update or modification. If we decide to change our personal data protection policy, those changes will be notified on our website or via other suitable methods. Any such change, update or modification will be effective as stated in the PDP Policy.