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Welcome to Secretlab!

At Secretlab, we respect your privacy. References to Secretlab, we, us and our refer to Secretlab SG Pte. Ltd. and its subsidiaries.

As a user of the internet, you know by now that e-commerce companies such as Secretlab’s collect and use information relating to you. We also disclose your information and transfer your information to others from time to time.

However, we respect your rights to your personal data. This Privacy Notice explains how we use, collect, disclose, transfer or otherwise manage your personal data. We are providing this Notice to you so that you can instruct us on how you want us to manage your personal data within your legal rights.

When you do business with us, we will be collecting data to achieve various objectives that we have described in detail elsewhere in this Privacy Notice. However, the underlying principles behind these objectives are mainly twofold:

• carry out our business of selling products to you through the various commercial channels available to us; and
• provide you with an experience that we believe will improve your impression of, and your relationship with, the Secretlab brand.

We respect and adopt the major privacy principles and frameworks around the world in designing our policies and processes as they apply to our management of your personal data. These principles and frameworks include the OECD Guidelines on the Protection of Privacy and Transborder Flows and EU General Data Protection Regulation 2016/679 (GDPR).

This Privacy Notice applies to all websites and domains owned by us, which we refer to as the Sites. It also applies to our interactions with you in person, as well as through the following Communication Platforms: e-mails, social media accounts, messaging and voice-over-IP platforms and services, chatbots, telephone calls, and any other form of communication media now available or becomes available anywhere in the world that we use to interact with you.

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1. WHAT INFORMATION WE COLLECT AND HOW WE USE IT

We want to get to know you, but we do not want to be creepy. That’s why we only collect personal data that we need so that we can sell the products you love to you, provide you with our awesome after-sales support and fulfil our legitimate business purposes. Obviously, we must follow the laws and regulations that apply to us and our interactions with you.

Depending on your relationship with Secretlab, we collect and process your personal data as described below.

1.1 Potential and actual customers

We collect and use your contact details, login credentials, payment information (e.g., credit card and other information used to authorise payment for your order(s) and the relevant billing information) and information relating to the product(s) you have expressed an interest in purchasing, or that you actually purchase, and the intended shipping addresses and addressees for your orders, for the following main purposes:

• enter into and perform our contracts with you or your organisation;
• provide customer service support (including pre-sales inquiries and after-sales support);
• manage and fulfil orders;
• screen orders for potential risk and fraud;
• communicate with you, and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products;
• develop and improve our products;
• protect Secretlab’s infrastructure and systems and other digital assets; and
• ensure compliance with regulatory requirements.

1.2 Potential customers we target

We collect and use the contact details, identification information, information required to purchase our products online, profile, role and preferences, login credentials, digital activity information and other information as may be relevant (e.g. information from publicly available sources) for the following main purposes:

• sales and marketing;
• advertising;
• creating and delivering targeted adverts and offers;
• conducting marketing campaigns;
• managing contacts and preferences;
• generating leads and opportunities;
• managing lead generation activities;
• organizing and managing events; and
• engaging in social media interactions.

1.3 Persons who visit our sites or interact with us

We collect and use your digital activity information for the following main purposes:

• enable the efficient use of our Sites and Communication Platforms;
• collective statistics to optimise the functionality of our Sites and Communication Platforms;
• improve your user experience; and
• improve marketing and advertising campaigns.

We also collect and use your contact details, login credentials, information included in your inquiries, comments and feedback that you may provide on online forums and surveys (including information from publicly available sources) or through any Communication Platform to:

• engage with our partners;
• conduct customer satisfaction and engagement surveys; and
• address and resolve inquiries and complaints.

1.4 Our potential and actual partners

We collect and use your contact details to:

• manage our relationship with you; and
• deliver products to customers or partner teams or members, in which case we may receive personal data directly from you or our partners.

1.5 Third parties with whom we interact

We collect and use your contact details and other information as we reasonably determine to be relevant (including information from publicly available sources) to:

• conduct anti-corruption due diligence on third parties and the required investigations in compliance with applicable laws; and
• conducting investigations into Secretlab product-related fraud, compliance, theft and/or counterfeit.

1.6 Potential and actual job candidates

We collect and use your contact details, your employment and pay history, your references and information that are publicly available on professional social networks such as LinkedIn, to identify and contact potential job candidates and to consider the applications of candidates who apply for job openings through our Sites or other Communication Platforms.

1.7 Visitors to our showrooms and offices

We collect the contact details, identification information and CCTV footage of individuals who visit Secretlab’s showrooms and offices to ensure the safety and security of Secretlab staff, intellectual property and premises.

1.8 Interactions through third-party sites

We sell our products through our Sites as well as through third-party platforms. From time to time, we conduct marketing campaigns that are hosted on Communication Platforms that belong to our partners. We may also make available to you, through our Sites and other Communication Platforms, social media features that enable you to share information about Secretlab or its products with your social networks, and to interact with us on various social media sites.

If you purchase our products through third-party sites, access social media sites through us, or engage with our marketing campaigns that are hosted on our partners’ sites, you should be aware that we do not control any of those sites or their respective privacy practices.

We do not endorse or make any representations about those sites. Any personal data that you choose to provide to, or that is collected or shared by, those sites is not covered by this Privacy Notice. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.

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2. HOW YOU CAN MANAGE YOUR COMMUNICATIONS AND PREFERENCES

If you choose to join our mailing list, Secretlab may provide you with information that complements our products and/or communications about our new products and offers. Our mailing list is an opt-in list and you do not have to join our mailing list to purchase our products.

In the event you no longer wish to receive communications from us, you can unsubscribe from such communications by following the opt-out or unsubscribe link and/or instructions included in each e-mail subscription communication.

In the event your opt-out or unsubscribe request has not been resolved in a timely manner, please contact the Secretlab DPO with details of your name, contact information, and description of the communications you no longer wish to receive from Secretlab.

Please note that these options do not apply to communications relating to the administration of orders, contracts, support, product safety warnings, or other administrative and transactional notices, where the primary purpose of these communications is not promotional in nature.

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3. HOW TO ACCESS, UPDATE OR DELETE PERSONAL DATA

We strive to maintain the accuracy of our records of your personal data. As required by the laws applicable to the relevant Secretlab entity, we provide individuals with reasonable access to personal data that they provide to Secretlab and the reasonable ability to review and correct it.

To protect your privacy and security, we will take reasonable steps to verify your identity, including requiring you to provide us with proof of your identity, before granting access to your personal data. To view and update the personal data you provided directly to Secretlab, you can update your information with us:

• if you have an online account with us, by updating your profile in your online account;
• contacting our customer support team by visiting the Contact page; or
• contacting the Secretlab DPO.

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4. HOW WE SHARE PERSONAL DATA

We do not sell, rent or lease personal data to others except as described in this Privacy Notice.

We may share and/or disclose your personal data as follows:

• Within the Secretlab group of companies. Secretlab has its headquarters in Singapore and operates worldwide. We may disclose your personal data as necessary within the Secretlab group of companies in connection with how we use your personal data.

• To third parties.

  • Where we engage with partners as part of our business operations, we may disclose your personal data to them in order to facilitate the sales, fulfilment and delivery of our products. We have entered into contracts with our partners, requiring them to keep confidential and secure the information that they receive from Secretlab and use such information only for the purposes of providing the contracted for business operations support, unless otherwise authorised by you or applicable laws and regulations.
  • We retain suppliers and service providers to manage or support our business operations, customer relationships, provide professional services, fulfil and deliver products, assist us with marketing and sales communication initiatives and to use your personal data as described above. Those third parties may receive and process your personal data under proper instructions, as necessary to support and facilitate how we use your personal data. Our contracts with our suppliers and service providers require them to keep confidential and secure any information they process on our behalf and to limit the use of information they receive from us solely to carrying out the contracted for services.
  • Except as described in this Privacy Notice, we will not share your personal data with third parties without your permission, unless to:
    • respond to duly authorised information requests of police and governmental authorities;
    • comply with law, regulation, subpoena or court order;
    • enforce/protect the rights and properties of Secretlab; or
    • protect the rights or personal safety of Secretlab, our employees, and third parties on or using Secretlab property when allowed and in each case in accordance with applicable law.
• In connection with a business reorganisation. Circumstances may arise where, whether for strategic or other business reasons, Secretlab decides to sell, buy, merge or otherwise reorganise its businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or our receipt of personal data from businesses that we wish to acquire. We will seek appropriate contractual protection for personal data in these types of transactions.

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5. HOW WE TRANSFER PERSONAL DATA INTERNATIONALLY

Secretlab may transfer your personal data as necessary within the Secretlab group of companies and to other third parties. The recipients may be located in countries which do not provide the same level of data protection as the country in which you are located. We will take steps to ensure there is adequate protection for the transfer of your personal data in compliance with the applicable data protection laws. Where required by local law, we will request your consent to transfer your personal data.

With respect to transfers to third parties located in countries that do not provide an adequate level of data protection, Secretlab will take appropriate safeguards such as signing EU Standard Contractual Clauses with the recipient, relying on their Privacy Shield certification, other approved codes of conduct or certification mechanisms or binding and enforceable commitments of the recipient. If you would like to receive more information about the appropriate safeguards and/or receive a copy of the relevant mechanism for your review, please contact the Secretlab DPO.

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6. HOW WE KEEP PERSONAL DATA SECURE

We use reasonable and appropriate physical, technical and administrative procedures to safeguard the information we collect and process. All systems used to support our business are governed by our corporate cyber security policies. However, please note that no digital transmission of data can ever be guaranteed 100% secure, so we encourage you to take care when disclosing your personal data online and to use readily available tools, such as Internet firewalls, secure e-mail and similar technologies, to protect yourself online.

We use Stripe to process our credit card payments and no credit card details are stored on our services. Stripe has been audited by a PCI-certified auditor, and is certified to PCI Service Provider Level 1. This is the most stringent level of certification available.

In case of an unauthorised security intrusion that materially affects you, we will notify you as soon as possible and will, within a reasonable time, report on our response actions.

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7. HOW LONG WE KEEP PERSONAL DATA

Typically, we keep personal data for the length of any contractual relationship and, to the extent permitted by applicable laws, after the end of that relationship for as long as necessary to perform purposes set out in this Privacy Notice, to protect Secretlab from legal claims and to administer our business. When we no longer need to use personal data, we will delete it from our systems and records or take steps to anonymise the data unless we need to keep it longer to comply with a legal or regulatory obligation. If you would like to receive more information about our data retention policies, please contact the Secretlab DPO.

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8. ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EU, EEA AND SWITZERLAND

Our privacy practices are aligned with the requirements of the General Data Protection Regulation (GDPR). If you are located in the European Union (EU), the European Economic Area (EEA), the UK or Switzerland, this additional information may be relevant and applicable to you.

8.1 Data controllers

Companies from the Secretlab group of companies may act as data controllers in relation to your personal data for the processing of personal data described in this Privacy Notice. If you would like to receive more information about which Secretlab entity acts as data controller for your personal data, please contact the Secretlab DPO.

8.2 Data Protection Officer

We have appointed a Data Protection Officer, or DPO, who is responsible for matters relating to data privacy and protection. You can contact the DPO by writing to:

Secretlab SG Pte. Ltd.
ATTENTION: LEGAL AND COMPLIANCE - SECRETLAB DPO
351 Braddell Road
#05-02
Singapore 579713
E-mail: compliance@secretlab.sg

8.3 Legal bases to process personal data

We process your personal data on the following legal bases:

• Legitimate interest. We may process your personal data as required to pursue our legitimate business interests (provided this is not overridden by the interests or rights of relevant individuals). In particular, we may process your personal data to manage, develop and improve our products; support our customers and sales operations; protect our staff and assets; communicate information that supplements our products; and ensure compliance with the laws and regulations.
• Legal obligation. We may process your personal data to comply with applicable laws and regulations, establish or exercise our legal rights. This may include situations involving investigations or legal claims or for compliance or regulatory purposes.
• Consent. We may process your personal data where you have provided your consent. In particular, we will rely on your consent where we cannot rely on an alternative legal basis or we are required by law to ask for your consent in the context of some of our sales and marketing activities, automatic data collection tools or surveys. At any time, you have a right to withdraw your consent by changing your communication choices, unsubscribing from Secretlab communications or contacting the Secretlab DPO.

8.4 Your rights in relation to your personal data

You may have the following rights to:

• request access or copies of personal data that Secretlab processes about you;
• rectify any inaccurate or incomplete personal data belonging to you;
• deletion of your personal data, unless an exception applies (such as in instances where we must keep your personal data to comply with our legal obligations);
• restrict the processing of your personal data in certain circumstances (such as when you are contesting the accuracy of your personal data and require restrictions in the processing of your personal data for us to verify its accuracy);
• data portability in certain circumstances (such as when you require us to transmit your data to another organisation where the processing of your data is based on your consent or a contract); or
• object to the processing of your personal data in certain circumstances (such as when you object to the use of your personal data for profiling for direct marketing).

These rights may be limited in some situations such as where Secretlab can demonstrate that we have a legal requirement or legitimate interest to process your personal data.

If you would like to exercise your rights, please contact us by completing the support form available on this site or by writing to the Secretlab DPO.

8.5 Complaint with a supervisory authority

If you consider that the processing of your personal data infringes the GDPR, you have a right to lodge a complaint with a supervisory authority in the country where you live or work, or where you consider that data protection rules have been breached.

8.6 Your rights under Standard Contractual Clauses

You may have additional rights under the data processing and/or data transfer agreements we have entered into with other parties. For instance, as a third-party beneficiary, where you believe your personal data has been transferred to a Secretlab company located outside the EU and processed by that company in breach of such data processing and/or data transfer agreements, you may have a right to:

• Lodge a complaint with the EU Secretlab company which transferred your personal data outside the EU;
• Lodge a complaint with a supervisory authority located in the same country as the EU Secretlab company which transferred your data outside the EU;
• Bring a court action against the EU Secretlab company which transferred your personal data outside the EU.

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9. HOW TO CONTACT US

We value your opinions. If you have any questions about our Privacy Notice, any concerns or complaints regarding our collection and use of your personal data or wish to report a possible breach of your privacy, please contact the Secretlab DPO by writing to us at the physical or e-mail addresses below. We will treat your requests and complaints confidentially. Our representative will contact you within a reasonable time after receiving your complaint to address your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Secretlab SG Pte. Ltd.
ATTENTION: LEGAL AND COMPLIANCE - SECRETLAB DPO
351 Braddell Road
#05-02
Singapore 579713
E-mail: compliance@secretlab.sg

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10. CHANGES TO THIS PRIVACY STATEMENT

If we modify this Privacy Statement, we will publish a revised version with an updated revision date. The privacy link on the footer of every Secretlab web page will then point to that new version.