FRANCK MULLER PRIVATE LIMITED (FMPL) takes your privacy seriously. The company is committed to the protection of your personal data and your privacy. This Personal Data Protection Notice explains how your data is collected and handled in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). Please note that FMPL may amend this notice from time to time due to changes in applicable laws and regulations and any such amendment will be notified via our website or by email.

The FMPL Cookie Policy is a supplement to this Privacy Policy and describes what cookies are, what FMPL can do with them and the way in which any person can accept or refuse to receive a cookie operated by FMPL on his/her terminal. You can access the Cookie Policy here. This Privacy Policy applies to all entities of the FMPL.

By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to FMPL, its related corporations and affiliates, (collectively referred to herein as “FMPL”, “us”, “we” or “our”), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to FMPL’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

YOUR PERSONAL DATA

In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):

(i) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

(ii) your employment history, education background; and income levels; and

(iii) your payment related information, such as your bank account or credit card information.

INFORMATION COLLECTION AND USE

FMPL collects personal information/data when you submit forms relating to any of our products or services, when you register onto our mailing list, when you interact with our customer service officers, when you wish to contact us, when you contact us directly, for example, upon enquiry of our products and / or services, through third parties such as our business partners, through your job application, and when you submit your personal data to us for any other reason.

When registering to be on our mailing list, customers are required to select the method of communications of promotional materials from FMPL (via direct mailers/ emails/ SMSes), FMPL adheres strictly to the method of communications selected by you.

FMPL collects, maintains, uses and process your personal information/ data for the following general purposes: respond to your queries and requests and responding to complaints; register you on our mailing list, for compliance with any applicable rules, laws and regulations, codes of practice or guidelines, through marketing activities or events, fulfill your requests for products and services, improving our services, verifying your identity, contact you to inform you of promotions from FMPL. We may use your personal information/ data provided to send you information on new products and services, special or promotional offers, or any marketing events, unless you have indicated that you do not wish to receive such materials. You may opt out of receiving any communications from us at any time by clicking on the ‘unsubscribe link’ on the relevant email communications or by contacting us.

INFORMATION SHARING AND DISCLOSURE

(i) FMPL will share, disclose and transfer your personal information/ data to other third party service providers for marketing purposes, letter shopping, text messaging and any other modes of communication. The provision of your personal information/ data for the purposes mentioned in this paragraph (i) herein is voluntary and optional.

(ii) FMPL will share, disclose and transfer your personal information/ data for purposes of fraud/ money-laundering prevention and detection, to comply to subpoenas, court orders, or legal process from authorities investigating any alleged offence, misdeeds and/or abuse or for the purposes of taking legal action against any users for breach of the Singapore Personal Data Protection Act 2012, or to establish or exercise our legal rights or defend against legal claims, and/or for the purposes of disclosing to all relevant authorities/ parties as required under the law to comply with all applicable laws, regulations, rules and directives. The provision of your personal information/ data for the purposes mentioned in this paragraph (ii) herein is compulsory and mandatory.

RIGHT OF ACCESS AND CORRECTION

You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will provide you with suitable means of accessing it (e.g. by emailing or mailing it to you). If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request amendment or correction of it.

CUSTOMER SERVICE SUPPORT

You may submit a request to FMPL at the address or email below for any of the following purposes:-

(a) to cease or stop processing and disclosing your personal information / data for marketing purposes;

(b) to change the method or manner in which FMPL processes and disclose your person information / data for marketing purposes; or

(c) to access and/or make correction or amendments to your personal information / data.

Under certain circumstances, you have rights under the GDPR in relation to your Personal Data. In particular, you have the following rights which you can exercise free of charge, by contacting us via email at [email protected] or write in to us at 391B Orchard Road, #18-01 Ngee Ann City Tower B, Singapore 238874. Our Data Protection Officer, Andrew Yuen, can be reached at this contact detail. The following rights are:

(a) Access - The right to be provided with a copy of your Personal Data (the right of access)

(b) Rectification - The right to require us to correct any mistakes in your Personal Data

(c) To be forgotten - The right to require us to delete your Personal Data —in certain situations

(d) Restriction of processing - The right to require us to restrict processing of your Personal Data—in certain circumstances, e.g. if you contest the accuracy of the date

(e) Data portability - The right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

(f) To object - The right to object: —at any time to your Personal Data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.

(g) Not to be subject to automated individual decision-making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

CONFIDENTIALITY & SECURITY

FMPL takes all reasonable precautions to ensure that your personal information / data is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your personal data are premises security, restricted file access to personal information, deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access, internal password and security policies.

PRIVACY POLICY CHANGES

FMPL may update this policy from time to time in view of market needs. We will notify you about significant changes in the way we treat personal information by placing a prominent notice on our website.