FUJIFILM ONLINE DATA PRIVACY POLICY
DATA PRIVACY STATEMENT

his Privacy Policy applies to the products, services, website(s) provided, mobile application(s) provided and/or the business conducted, FUJIFILM Asia Pte Ltd, (collectively and individually referred to as “THE COMPANY”, “we”, “our”, “us”) and explains how we handle Personal Data and comply with the requirements of Singapore’s Personal Data Protection Act (“PDPA”). We are committed to protection of data privacy, transparency and choice of individual persons who visit this website (“You”). If You reside in the Republic of Singapore, the controller of Your Personal Data as defined herein is FUJIFILM Asia Pacific Pte. Ltd, with its principal place of business at 10 New Industrial Road, Fujifilm Building, Singapore 536201.This Privacy Policy will assist you in understanding how we collect, use, disclose and/or process the Personal Data you have provided to us or that we possess about you, as well as to assist you in making an informed decision before providing us with any of your Personal Data. The term “Personal Data” refers to information that is connected to you as an identifiable individual, defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access (“Personal Data”). This may include your name, address, telephone number, email address, date of birth, gender, credit card details, Beauty Profile information, photographs, personal images, information about your purchases or preferences, and any other information collected by us where you are identified or identifiable.
If you, at any time, have any queries about this Privacy Policy or any other queries in relation to how we may manage, protect and/or process your Personal Data, please email our Data Protection Officer at astalift.sg@fujifilm.com.
This Privacy Policy is subject to Singapore laws.

BY USING THIS WEBSITE, YOU CONSENT TO OUR COLLECTION AND USE OF THE PERSONAL DATA AS SET FORTH IN THIS PRIVACY POLICY.

1. PURPOSE & SCOPE APPLICATION

1.1 Definition & purpose

(a) Except as otherwise specified herein, the following terms have the respective meanings set forth below for all purposes of this online data privacy policy (“This Privacy Policy”):

i. “Act”: Singapore Personal Data Protection Act 2012 as amended from time to time and the relevant version in force at the time of application of This Privacy Policy including subsidiary legislations and Personal Data Protection Commission’s Advisory Guidelines;

ii. “Personal Data”: Data (regardless of its authenticity) about an individual, a natural person who can be identified from such data, or from such data in combination with other information to which the Company may have access, including the meaning otherwise as defined in the Act;

iii. “Process”: Carrying out of any operation or set of operations in relation to Personal Data including, recording; holding; organisation; adaptation or alteration; retrieval; combination; transmission; erasure; or destruction, and including the meaning otherwise as defined in the Act; and

iv. “Website(s)”: Website(s) are managed and operated by the Company and which start with the URL https://www.astalift.com.sg

(b) This Privacy Policy describes the way in which the Company manages and Processes the Personal Data and Your rights and responsibilities in relation to Your Personal Data collected on Our Website(s) (“Your Personal Data”).

1.2 Scope of Application

This Privacy Policy only applies to Your Personal Data and does not apply to the Personal Data collected on individual websites other than the Website(s) including social media features and widgets (either hosted by third party or hosted directly on Our Website(s). The management of such Personal Data shall be governed by relevant terms of applicable policies of respective organisations providing such websites.

2. MANAGEMENT & PROCESSING OF YOUR PERSONAL DATA

2.1 Purpose of Use of Your Personal Data

The Company will/may collect, use, disclose and/or process your Personal Data for one or more of the following purposes:

(a) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Site. Without limiting the generality of the foregoing, if you:

(i) gain access to or sign in to the Site, using your login credentials of a Social Networking Site, or (ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Site, it may result in information or your Personal Data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your Personal Data;

(b) monitoring, processing and/or tracking your use of the Site in order to provide you with a seamless experience, facilitating or administering your use of the Site, and/or to assist us in improving your experience in using the Site;

(c) assessing and processing your request for the purchase of and/or subscription to our products and/or services;

(d) registering you as a customer of THE COMPANY and/or to deal with, process and/or administer the account that you may open with us, including to facilitate your transactions or activities on the Site, or your transactions or activities with us;

(e) administering, facilitating, processing and/or dealing with your relationship with us, any transactions or activities carried out by you on the Site or at our retail stores. This includes processing your application, orders and payment transactions; implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a purchase to be delivered to a third party recipient, you consent to us disclosing Personal Data that identifies you, to the said third party recipient (such as but not limited to your name). Further, you acknowledge and agree that delivery of your purchase could involve disclosure of certain Personal Data about you to bring about delivery of the same such as your name and contact details, which may be disclosed on the cover of the parcel, on an envelope or a delivery related document, as the case may be, which could be seen by third parties who view such parcel, envelope or said document;

(f) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your customer service enquiries and complaints; or responding to or dealing with your interactions with us;

(g) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Site, your membership (if applicable) and/or account with us, your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

(h) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively “Feedback” ) that you provide through Social Networking Sites, to the Site or to us (including at the retail stores), with other users of the Site or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business of The Company, and/or to acquiring customers, and/or for the purpose of providing the public with your Feedback which may be useful for the public’s purchasing decision or for the public’s information or otherwise. This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our affiliates’) annual reports (if any) etc., and/or incorporated as part of The Company’s marketing collaterals/materials or corporate video to be disclosed to the public, and you hereby consent to the same. Do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately email our Customer Department at _________________________ and head the subject of your email with the word “Confidential”;

(i) where you have provided your consent to us, whether such consent was obtained through the Site, the retail store(s) or otherwise, sharing your Beauty Profile Personal Data with or disclosing your Beauty Profile Personal Data to other users of the Site or with/to the public, through the Site or any other media (whether print, online or otherwise) or communication platform as we so choose, at our discretion, such as but not limited to as part of The Company’s marketing collaterals/materials or corporate video. “Beauty Profile Personal Data” includes your name, skin type/ concerns, and other information which you provide;

(j) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations (whether Singapore or foreign Country/Region) applicable to us or our affiliates/associated companies, the requirements or guidelines of governmental authorities (whether Singapore or foreign Country/Region) which we determine are applicable to us or our affiliates/associated companies, and/or our risk management procedures that may be required by law (whether Singapore or foreign Country/Region) or that may have been put in place by us or our affiliates/associated companies;

(l) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with and/or investigating complaints;

(m) complying with or as required by any applicable law, court order, order of a regulatory body, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;

(n) complying with or as required by any request or direction of any governmental authority (whether Singapore or foreign Country/Region) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to Singapore Customs and Ministry of Health) (whether Singapore or foreign Country/Region). For the avoidance of doubt, this means that we may/will disclose your Personal Data to such parties upon their request or direction;

(o) conducting research (including customer research), surveys, market surveys, analysis and/or development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities, or to improve our understanding of your interests, concerns and preferences, in order to enhance any continued interaction between yourself and us connected or in relation to the Site, or improve any of our products or services. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey, by way of email or postal mail;

(p) storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside Singapore;

(q) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of THE COMPANY or that of its affiliates/related corporations;

(r) for marketing purpose and in this regard, we would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including those of third party organisations whom THE COMPANY may collaborate with) that THE COMPANY (including its affiliates/related corporations) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future:

(i) by way of postal mail, electronic transmission to your email address(es), other forms or harnessing other technologies (such as geo-location technology) or other technologies on your computers, and/or through other modes of communication that is not one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes” ), in compliance with the PDPA. You may opt out of this or withdraw from this at any time by sending an email to our Data Protection Officer. For the avoidance of doubt, unlike (ii) below, the application of or your acceptance of or your consent to, this Privacy Policy, constitutes your consent to this subparagraph (i); and/or

(ii) if you have separately expressly consented to one or more of the 3 DNC Modes to your Singapore telephone number, in compliance with the requirements of the PDPA.

For the avoidance of doubt, this subparagraph is without prejudice to subparagraph (o) above for which you have hereby consented to us contacting you for a survey, which you may subsequently opt out of by sending our Data Protection Officer notice;

(s) to implement and maintain our information technology systems, including to store and process Personal Data in computer databases and servers located within and outside Singapore;

(t) anonymization of your Personal Data. In this regard, you acknowledge that Personal Data that has been anonymized is no longer Personal Data and the requirements of the PDPA would no longer apply to such anonymized data;

(u) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of THE COMPANY or of its affiliates/related corporations; and

 (the purposes set out in this paragraph 2.1 above shall be collectively referred to as the “Purposes”).

2.2 Provision Of Third Party Personal Data By You

Should you provide us with Personal Data of individual(s) other than yourself, you represent and warrant us and you hereby confirm that :

(a) prior to disclosing such Personal Data to us, you would have and had obtained consent from the individuals whose Personal Data are being disclosed to us, to:

(i) permit you to disclose the individuals’ Personal Data to us for the Purposes; and

(ii) permit us to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes, as set out in paragraph 2.1 above;

(b) any Personal Data of individuals that you disclose to us is accurate; and

(c) you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to us to collect, use, disclose and process such Personal Data for the Purposes.

2.3 Collection of Your Personal Data

(a) In principle, You may view the Website(s) without disclosing Your Personal Data. However, some of Our services (such as news distribution, user registrations and sending email or inquiry to the Company) may require You to provide us with Your Personal Data;

(b) Our Website(s) may collect information such as which content You have viewed within the Website(s), which other website You have referred to through the Website(s), or any other aggregated data for actions taken on our Website(s) that do not specifically indentify You. In the process of collecting such information, which purpose is to improve the usability of our Website(s), information shall not be collected in a manner in which You may be indentified nor shall You be identified during the process of information analysis.

(c) You have no obligation to provide any of the Personal Data requested by us. However, depending on circumstances, it may be the case that if you do not provide the requested Personal Data, we may not be able to provide you with certain products and services, or transact with you, that depend on the collection, use or disclosure of your Personal Data.

2.4 Non-Disclosure of Your Personal Data

(a) The Company will not disclose or supply, share or otherwise distribute Your Personal Data to third parties except when:

i. Your consent is given in advance or deemed to be given pursuant to the Act;

ii. it is necessary to commission operations to the Company’s affiliates worldwide;

iii. the Company determines, from Your inquiry in relation to Our products/services, that it is appropriate for the Company’s affiliates worldwide providing the Company’s products/services to respond to the customer’s inquiry;

iv. You order products or use other services which require a fee. Your name, address, credit card number, and other information is disclosed to financial institutions or other parties for payment settlement;

v. Our business is assigned or transferred either by operation in law or otherwise including mergers, consolidations and dissolution or transfer of operations;

vi. Your Personal Data disclosure is required by relevant laws and regulations, or such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding conducted by relevant authorities; or

vii. there is an immediate need for disclosure to protect human life or human rights.

(b) We will disclose Your Personal Data for the above listed cases only to the third parties who have agreed with us:

i. to use Your Personal Data only for the purpose agreed upon in advance;

ii. not to sell Your Personal Data to any other third parties; and

iii. not to disclose Your Personal Data to any other third parties except as may be required by law.z

2.5 Retention of Your Personal Data

The Company will retain Your Personal Data pursuant to the Act. We will cease retention of Your Personal Data or remove the means by which any information can be associated with Your Personal Data, as soon as retention no longer serves the purpose for which it was collected for, and is no longer necessary for legal or business purpose.

2.6 Cross-Border Data Transfer

We are a global group of companies and have databases in different countries, some of which are operated by one of our affiliates or by third parties on behalf of them. We may transfer Your Personal Data to one of the Company’s database outside Your country of domicile. We will ensure that all cross-border data transfer shall be in compliance with This Privacy Policy and applicable laws and regulations. If Your Personal Data are transferred to countries which may not necessarily require an adequate level of protection for Your Personal Data compared with the level provided by the Act, we will make reasonable efforts to ensure effective levels of data protection.

2.7 Security Measures

Your Personal Data provided shall be managed in an appropriate manner under the responsibility of each division of the Company that receives such Personal Data. We use data networks protected by industry standard firewall and password protection and take reasonable measures to protect Your Personal Data from loss, misuse, unauthorised access, disclosure, alteration or destruction.

3. YOUR RIGHT OF ACCESS, CORRECTION, DELETION & WITHDRAWAL OF CONSENT

3.1 Accessing, Updating or Correcting Your Personal Data

(a) You may request to access, update, correct or delete Your Personal Data (or any part thereof) or withdraw Your Consent or object to management and Processing of Your Personal Data. In the case of electronic direct marketing, We will provide You with a method to opt out of receiving further marketing materials or with a method to opt in if required by relevant laws and regulations.

(b) If you want to exercise Your rights set forth above or have any questions or concerns in relation to Your Personal Data, please contact the Data Protection Officer of the Company at ffap.dpo@fujifilm.com. with the following information:

i. Copies of proper identification of You;

ii. Name of the Website(s) where You provided Personal Data; and

iii. Specific information regarding Your Personal Data that You would like to access, or request for updating, correcting or deleting.

3.2 Exceptions and Prohibitions

Your request made under Section 3.1 hereof will be subject to the statutory exceptions and prohibitions stipulated by the Act and/or any other applicable laws and regulations.

4. USE OF COOKIES & INTERNET TAGS

4.1 Cookies

(a) Cookies are a mechanism to store information, including the recording of a user’s browsing activities, in order to facilitate more convenient use of websites. The Company uses “session-cookies” for privacy protection purposes. For more detailed information about cookies, please visit http://www.allaboutcookies.org.

(b) The Website(s) may use cookies for the following purposes while ensuring that the identity of the user is not disclosed.

i. To provide the “Save Password” function for members-only websites where customers and/or visitors input their ID and password to view content;

ii. To analyse customer and visitors’ access to the Website(s) in order to improve operability or to identify the cause of problems on the Website(s);

iii. To display the most appropriate advertisements on third party sites based on customer interests or previous usage of the Website(s);

iv. To enhance services; or

v. To prompt customers and/or visitors to re-enter their password for security purposes after a certain period of time has elapsed.

(c) The Company may save and refer to cookies via a third party being outsourced by the Company for the delivery of advertisements.

(d) By changing the settings on the Internet browser, You may disable their cookies or set it so that a warning will appear on the computer screen before cookies are issued. However, some services provided through the Website(s) may not be usable if cookies are disabled.

4.2 Internet Tags & Third Party Web Partners

The Company may use internet tags such as Web Beacons (also known as a clear Graphic Interchange Format (GIF) or a pixel tag and may deploy these tags through a third party advertising partner or a Web analytical service partner (collectively “Third Party Web Partners”) located outside Singapore and they may store the respective information outside Singapore. Our Third Party Web Partners may be able to collect Your Personal Data because of these internet tags and cookies and may provide us with reports summarising Your Website activities. We use internet tags to measure Your responses to the Website(s).

5. Problems, queries or complaints

5.1 If you have any queries relating to our Privacy Policy, or if you wish to request for access to or correction of your Personal Data or to withdraw your consent, please contact or send your request to our Data Protection Officer by email to astalift.sg@fujifilm.com.

5.2 You may also contact us at the details above if you have a complaint about how we have handled your Personal Data. We will investigate your complaint and will use reasonable endeavours to respond to you in writing as soon as possible.

6. General

6.1 Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you provided to us with regard to processing of your Personal Data.

6.2 For the avoidance of doubt, in the event that Singapore Personal Data protection law permits an organisation such as us to collect, use or disclose your Personal Data without your consent, such permission granted by the law shall continue to apply.

7. USE OF DNT & SOCIAL MEDIA FEATURES AND WIDGETS

7.1 Do-Not-Track

You may prevent tracking of Your online activity by setting a Do-Not-Track signal (“DNT”) in Your browser that alerts websites You visit that You do not want them to collect certain information about You. However, Our Website(s) may not recognise or take action in response to DNT signals from Web browsers. For more detailed information about DNT, please visit https://allaboutdnt.com.

 Our Website(s) include social media features, such as Facebook’s “Like” button, and widgets, such as the “Share This” button or interactive mini-programmes that run on the Website(s). These features are recognisable by their third party brand and may collect Your IP address, pages You are visiting on our Website(s) and set a cookie to enable the feature. Social media features and widgets are either hosted by a third party or hosted directly on our Website(s). You interaction with these features shall be governed by respective privacy policies of individual organisations providing such features.8. GOOGLE ANALYTICS

The Company uses Google Analytics service offered by Google Inc. for the purpose of evaluating the use of Website(s), optimising traffic to and between Website(s) or integrating Web pages where appropriate. The information generated by the cookies about Your use of Website(s), including Your IP address, will be anonymised and transmitted to Google servers. For more information on IP anonymisation, please refer to https://support.google.com/analytics/answer/2763052.

7.2 Social Media Features and Widgets

Our Website(s) include social media features, such as Facebook’s “Like” button, and widgets, such as the “Share This” button or interactive mini-programmes that run on the Website(s). These features are recognisable by their third party brand and may collect Your IP address, pages You are visiting on our Website(s) and set a cookie to enable the feature. Social media features and widgets are either hosted by a third party or hosted directly on our Website(s). You interaction with these features shall be governed by respective privacy policies of individual organisations providing such features.

8. GOOGLE ANALYTICS

The Company uses Google Analytics service offered by Google Inc. for the purpose of evaluating the use of Website(s), optimising traffic to and between Website(s) or integrating Web pages where appropriate. The information generated by the cookies about Your use of Website(s), including Your IP address, will be anonymised and transmitted to Google servers. For more information on IP anonymisation, please refer to https://support.google.com/analytics/answer/2763052.

9. THIRD PARTY LINKS ON OUR WEBSITE(S)

The Privacy Policy shall not apply to other websites owned by third parties to which we may provide links (as in the link to Google Analytics in the above Section 6). The Company cannot guarantee the privacy standards of third parties links on Our Website(s) or be responsible for the contents of such third party website linked on Our Website(s).

10. PERSONAL DATA FROM A MINOR

The Company will not knowingly collect, use or disclose any Personal Data from a minor under the age of 18. Any Personal Data provided by a minor must be submitted with a written consent from a person with parental responsibility such as a parent or guardians through direct off-line contact.

11. CHANGES TO THIS PRIVACY POLICY

You acknowledge that the Company may periodically change, modify, add or remove or otherwise update This Privacy Policy at Our discretion, without prior notification. In such event, We will post a prominent notice on the Website(s) prior to the effective dates of any relevant changes. If such changes are inconsistent with provisions in This Privacy Policy, and where required by applicable laws and regulations, We will either notify You or provide You with an opportunity to opt-out Your Personal Data.