Rebel and Soul Pte Ltd (collectively referred to as ”Rebel & Soul”, “we”, “us” or “our” in this privacy policy) respects your concerns about privacy and is committed to protecting your personal data. This privacy policy describes how we look after your personal data when you visit our website www.rebelandsoul.com (the “Site”), regardless of where you visit from, and tell you about your privacy rights.
You can click on the following links to jump to the specific section listed below:
Purpose of this Privacy Policy
This privacy policy aims to give you information on how Rebel & Soul collects and processes your personal data through your use of the Site, including any data you may provide through the Site.
The Site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Information We Collect
Personal data, or personal information, means data, whether true or not, about a person 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.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, identification information and your contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
Automated Collection of Personal Data
We also collect certain information by automated means when you visit the Site. By collecting this information, we learn how to best tailor the Site to our visitors. We collect this information through various means, such as browser cookies, web beacons, device identifiers, server logs, and other technologies.
The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with the Site (such as the web pages you visit, links you click, videos you watch and features you use), the pages that led or referred you to the Site, dates and times of access to the Site, geolocation information, and other information about your use of the Site.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use beacons in emails to help us track response rates, identify when our emails are accessed or forwarded, and for other purposes listed below.
Why Do We Use These Technologies?
They help us
To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer.
The Site is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.
Third-Party Web Analytics Services
We may obtain personal data and information about your online activities over time and across third-party websites, devices and other online services. On the Site, we use third-party online analytics services, such as those of Google Analytics and Hubspot. The service providers that administer these analytics services use automated technologies to collect data (such as email address, IP addresses, cookies and other device identifiers) to evaluate, for example, use of the Site and to diagnose technical issues. To learn more about Google Analytics, please visit http://www.google.com/analytics/learn/privacy.html. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout?hl+en=GB. To learn more about Hubspot, please visit http://www.legal.hubspot.com/privacy-policy.
Online Tracking and Interest-Based Advertising
On the Site, both we and certain third parties may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes. You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests, location and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of browser cookies, web beacons, device identifiers, server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites and apps, and to build a profile of users’ online browsing and app usage activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed, and the actions taken on the websites or apps. This data collection takes place on third-party websites and apps that participate in the ad networks.
How Do I Disable Or Remove Cookies?
You can restrict the use of cookies on the Site by visiting this “Privacy Policy.” A link to this “Privacy Policy” will be provided at the bottom of all webpages on the Site.
You may also restrict or disable the use of cookies through your web browser. Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies, please visit the appropriate link below.
In addition, you can delete Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. You can also visit http://www.allaboutcookies.org.
How We Use the Information We Collect
We may use the information we obtain on the Site for any or all of the following purposes:
As required by applicable law, we use the personal data and information we obtain to comply with applicable legal requirements, carry out our contractual obligations and, as permitted by law, pursue our legitimate interests (such as managing the Site, performing data analytics, and operating, evaluating and improving our business). We also may use the information we obtain in other ways for which we provide specific notice at the time of collection or otherwise with your consent. We may combine information we obtain about you (such as through the Site or from third parties) for the purposes described above.
Sharing Information
We do not sell or otherwise disclose personal data or information we collect about you, except as described herein or otherwise disclose to you at the time the data is collected.
We may share your information with other Rebel & Soul-related entities. We may also share information provided by our visitors to this Site with service providers we have retained to perform services on our behalf, including without limitation, hosting, analysing, relationship management or operating this Site and analysing data. We require these service providers by contract to appropriately safeguard the privacy and security of personal information they process on our behalf.
We may also disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); or (7) otherwise with your consent.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Data Transfer
We may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. For example, we may transfer the information to our service provider in the United States that host the Site. Those countries may not have the same data protection laws as the country in which you initially provided the information. By submitting your personal data, you consent to this transfer. When we transfer your information to other countries, we will protect that information as described in this privacy policy and in accordance with applicable law.
Other Online Services and Third-Party Features
The Site may provide links to other online services and websites for your convenience and information, and may include third-party features such as apps, tools, widgets and plug-ins (e.g., Facebook, Instagram, LinkedIn, Twitter, YouTube and Vimeo buttons). These services, websites, and third-party features may operate independently from us. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, Rebel & Soul is not responsible for these third parties’ information practices.
Withdrawing your Consent
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time as it has been effectively withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
Protection of Personal Data
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention of Personal Data
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Access to Personal Data and Correction of Personal Data
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable law).
Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any enquiries or feedback on our privacy policy, or if you wish to make a request, please contact the DPO by email at hello@rebelandsoul.com or write to:
Rebel and Soul Pte Ltd
13 Bussorah Street
#02-00, Singapore
199434
Updates to this Privacy Policy
This privacy policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this privacy policy from time to time without any prior notice and will post any revisions on the Site. You may determine if any such revision has taken place by referring to the date on which this privacy policy was last updated. Your continued use of our Site and services constitutes your acknowledgement and acceptance of such changes.
Effective date: [July 30, 2019]
Last updated: [July 30, 2019]
Rebel and Soul Pte Ltd (collectively referred to as ”Rebel & Soul”, “we”, “us” or “our” in this privacy policy) respects your concerns about privacy and is committed to protecting your personal data. This privacy policy describes how we look after your personal data when you visit our website www.rebelandsoul.com (the “Site”), regardless of where you visit from, and tell you about your privacy rights.
You can click on the following links to jump to the specific section listed below:
Purpose of this Privacy Policy
This privacy policy aims to give you information on how Rebel & Soul collects and processes your personal data through your use of the Site, including any data you may provide through the Site.
The Site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Information We Collect
Personal data, or personal information, means data, whether true or not, about a person 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.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, identification information and your contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
Automated Collection of Personal Data
We also collect certain information by automated means when you visit the Site. By collecting this information, we learn how to best tailor the Site to our visitors. We collect this information through various means, such as browser cookies, web beacons, device identifiers, server logs, and other technologies.
The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with the Site (such as the web pages you visit, links you click, videos you watch and features you use), the pages that led or referred you to the Site, dates and times of access to the Site, geolocation information, and other information about your use of the Site.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use beacons in emails to help us track response rates, identify when our emails are accessed or forwarded, and for other purposes listed below.
Why Do We Use These Technologies?
They help us
To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer.
The Site is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.
Third-Party Web Analytics Services
We may obtain personal data and information about your online activities over time and across third-party websites, devices and other online services. On the Site, we use third-party online analytics services, such as those of Google Analytics and Hubspot. The service providers that administer these analytics services use automated technologies to collect data (such as email address, IP addresses, cookies and other device identifiers) to evaluate, for example, use of the Site and to diagnose technical issues. To learn more about Google Analytics, please visit http://www.google.com/analytics/learn/privacy.html. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout?hl+en=GB. To learn more about Hubspot, please visit http://www.legal.hubspot.com/privacy-policy.
Online Tracking and Interest-Based Advertising
On the Site, both we and certain third parties may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes. You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests, location and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of browser cookies, web beacons, device identifiers, server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites and apps, and to build a profile of users’ online browsing and app usage activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed, and the actions taken on the websites or apps. This data collection takes place on third-party websites and apps that participate in the ad networks.
How Do I Disable Or Remove Cookies?
You can restrict the use of cookies on the Site by visiting this “Privacy Policy.” A link to this “Privacy Policy” will be provided at the bottom of all webpages on the Site.
You may also restrict or disable the use of cookies through your web browser. Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies, please visit the appropriate link below.
In addition, you can delete Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. You can also visit http://www.allaboutcookies.org.
How We Use the Information We Collect
We may use the information we obtain on the Site for any or all of the following purposes:
As required by applicable law, we use the personal data and information we obtain to comply with applicable legal requirements, carry out our contractual obligations and, as permitted by law, pursue our legitimate interests (such as managing the Site, performing data analytics, and operating, evaluating and improving our business). We also may use the information we obtain in other ways for which we provide specific notice at the time of collection or otherwise with your consent. We may combine information we obtain about you (such as through the Site or from third parties) for the purposes described above.
Sharing Information
We do not sell or otherwise disclose personal data or information we collect about you, except as described herein or otherwise disclose to you at the time the data is collected.
We may share your information with other Rebel & Soul-related entities. We may also share information provided by our visitors to this Site with service providers we have retained to perform services on our behalf, including without limitation, hosting, analysing, relationship management or operating this Site and analysing data. We require these service providers by contract to appropriately safeguard the privacy and security of personal information they process on our behalf.
We may also disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); or (7) otherwise with your consent.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Data Transfer
We may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. For example, we may transfer the information to our service provider in the United States that host the Site. Those countries may not have the same data protection laws as the country in which you initially provided the information. By submitting your personal data, you consent to this transfer. When we transfer your information to other countries, we will protect that information as described in this privacy policy and in accordance with applicable law.
Other Online Services and Third-Party Features
The Site may provide links to other online services and websites for your convenience and information, and may include third-party features such as apps, tools, widgets and plug-ins (e.g., Facebook, Instagram, LinkedIn, Twitter, YouTube and Vimeo buttons). These services, websites, and third-party features may operate independently from us. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, Rebel & Soul is not responsible for these third parties’ information practices.
Withdrawing your Consent
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time as it has been effectively withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
Protection of Personal Data
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below
Retention of Personal Data
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Access to Personal Data and Correction of Personal Data
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable law).
Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any enquiries or feedback on our privacy policy, or if you wish to make a request, please contact the DPO by email at hello@rebelandsoul.com or write to:
Rebel and Soul Pte Ltd
13 Bussorah Street
#02-00, Singapore
199434
Updates to this Privacy Policy
This privacy policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this privacy policy from time to time without any prior notice and will post any revisions on the Site. You may determine if any such revision has taken place by referring to the date on which this privacy policy was last updated. Your continued use of our Site and services constitutes your acknowledgement and acceptance of such changes.
Effective date: [July 30, 2019]
Last updated: [July 30, 2019]
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