Nippon Paint Singapore Privacy Policy

At Nippon Paint (Singapore) Co Pte Ltd [“NPS”] we are committed to respecting and protecting your personal data. This Privacy Policy sets out the basis upon which NPS collects, uses, discloses, stores and processes personal data in Singapore in compliance with the Personal Data Protection Act 2012 (“PDPA”).

Definitions

As used in this Privacy Policy:

“Personal Data” means 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.

“Business Contact Information (BCI)” is defined as an individual’s name, position name or title, business telephone number, business address, business email address and any other similar information about the individual, not provided by the individual solely for his personal purposes. Under the Singapore PDPA, business contact information is not considered as Personal Data so long as it is used strictly for business-to-business (B2B) transactions.

Application of this Privacy Policy

This Privacy Policy applies to all users of Nippon Paint Singapore’s websites, online services including Mobile Apps and communicating with us through email, by telephone, or in writing,

Our websites may contain links to other websites which are not maintained by NPS. This Privacy Policy only applies to the websites of NPS. When visiting these third-party websites, you should read their privacy policies which will apply to your use of those websites.

Collection, Use and Disclosure of Personal Data

1. We collect Personal Data when you:

• • Register for a specific product or service (e.g. registering your interest to purchase painting service package)
  • Order products through our Nippon Paint On-line store
  • Visit our website and leave behind your contact information through “Contact Us” form
  • Interact with our staff via telephone calls, letters, fax, face-to-face meetings, social media platforms, emails and any other forms of communication
  • Sign up for alerts or newsletters
  • Participate in a competition, lucky draw or survey
  • Visit our premises where you register in the visitor logbook and potential use of CCTV in our offices and the reception area.
  • Download and used our Mobile Apps

2. We collect your name, address, telephone number, e-mail address, as well as service-related information such as credit card information for purchasing items from the on-line store.
3. NPS do not collect NRIC, FIN or passport numbers, unless such collection, use or disclosure is required under the law (or an exception under the PDPA applies); or such collection, use or disclosure is necessary to accurately establish or verify your identity to a high degree of fidelity.
4. You are not obliged to provide your personal data to NPS. However, it would not be possible for us to fulfil our contractual duties towards you or facilitate your request or provide the goods and services to you.
5. We may also collect, use, and disclose personal data without consent pursuant to an exception where:

• • Required or permitted by laws or regulations or under the exception of PDPA
  • The collection is necessary to respond to an emergency that threatens the life, health or safety of the individual or another individual

Withdrawing Your Consent

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 by submitting your request in writing or via email to our Data Protection Officer (DPO) at the contact details provided below.

If you request to withdraw your consent, we will inform you of the potential consequences and the time required to complete the withdrawal. Such requests will be processed within a reasonable timeframe, taking ten (10) business days or more depending on the complexity of the request. In some cases, not providing the personal data, or withdrawing consent to the use, processing, or disclosure of the personal data, may adversely affect NPS’ ability to continue our providing our goods or services to you.

Cookies and Related Technologies

Our websites and mobile applications (“apps”) use cookies. A cookie is a small text file placed on your computer or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our apps.

You have the choice to set up your web browser to block cookies which may limit certain features and functions in your use of our websites or applications.

Accuracy of Personal Data

We will take reasonable steps to ensure that the Personal Data we collect about you is current, complete and accurate. Please update us if there are changes to your personal data by informing your Sales account manager or our Data Protection Officer in writing or via email at the contact details provided below.

Protection of Personal Data

To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented appropriate information security, technical, physical and administrative measures to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data and will only share your data with authorised persons on a ‘need to know’ basis.

Retention of Personal Data

We have a documented retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited personal data will be deleted right away. If received by telephone, these will not be recorded.

Access and Correction to Your Personal Data

You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by checking identification document, and the legitimacy of your request. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. Please note that a reasonable fee may be charged for an access request, depending on their nature and complexity. If so, we will inform you of the fee before processing your request.

If you find that the personal data we hold about you is incorrect you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, after verifying your identity, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

Sharing of Personal Data

We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to Nippon SEA Group Headquarters in Singapore, or to third party providers, agents and other organizations we have engaged to fulfil our contractual obligations in delivering goods and services to you.

When third-party data intermediaries are engaged to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures and have taken reasonable steps to comply with these measures.

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

We wish to emphasise that NPS does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.

Transfer of Personal Data Outside of Singapore

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.

Complaints relating to Personal Data

Complaints relating to Personal Data should be referred to the DPO, who will acknowledged and provide a response within 10 working days. Please include your name and contact information when submitting a complaint. We treat all complaints seriously and confidentially.

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, in the following manner:

Name of DPO            : Edmund Ng

Contact No.               : +65 6265 5355

Email Address           : dpo@nipponpaint.com.sg

Address                      : 1 First Lok Yang Road, Jurong, Singapore 629728

Changes to this Privacy Policy

This Privacy Policy is reviewed and updated periodically to ensure that it is consistent with our future developments, industry trends and/or changes in legal or regulatory requirements. We will notify you of any changes by posting the latest Policy on our website.

Please visit our website periodically to note any changes. Changes to this Policy take effect when they are posted on our website.