Data Protection Policy - Tiger Balm Japan

Data Protection Policy

Your privacy is important to us. The purpose of this document (“Data Protection Policy”) is to inform you of how Haw Par Healthcare Limited handles Personal Data (as defined below). Please take a moment to read this Data Protection Policy carefully so that you know and understand the purposes for which we collect, use and disclose your Personal Data. You may contact us in the manner stated in this Data Protection Policy if you have any questions.

By accessing and using the Haw Par Healthcare Limited website (“Website”), interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Haw Par Healthcare Limited and its related corporations as well as its representatives and/or agents (collectively referred to herein as “HPH”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst them your Personal Data, and disclosing such Personal Data to HPH’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to HPH in respect of your Personal Data nor does it affect any rights we may have at law in connection with the collection, use or disclosure of your Personal Data and any consents you may have provided in connection with this Data Protection Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.

HPH may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. While you should regularly check this Data Protection Policy and determine if any such revision has taken place by referring to the date on which this Data Protection Policy was last updated, we may also notify you of updates to this Data Protection Policy in any form as we may deem appropriate or, where required by applicable law, by posting a notice or reaching you via other forms of communication. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our Website.

1. Your Personal Data

1.1 In this Data Protection 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 you may provide to us include (depending on the nature of your interaction with us):

(a) your name, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have entered on the Website, provided us in any forms you may have submitted to us, or in other forms of interaction with you (including e-mail);

(b) your payment related information, such as your bank account or credit card information;

(c) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website;

(d) marketing and communications data, such as your preferences in receiving marketing messages from us, your communication preferences and history of communications with us, our service providers or third parties; and/or

(e) other information, which may include your participation in our contests, promotions, or surveys, and photographs, videos and/or audio recordings taken by us or our representatives.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

(a) when you interact with our customer service officers;

(b) when you use some of our services, e.g. websites;

(d) when you request that we contact you;

(e) when you are contacted by, and respond to, our marketing representatives and agents;

(f) when you respond to our request for additional Personal Data;

(g) when you ask to be included in an email or other mailing list;

(h) when you respond to our promotions and other initiatives;

(i) via closed-circuit television surveillance when you visit our premises;

(j) when we receive references from business partners and third parties, for example, where you have been referred by them;

(k) when you share comments or feedback with us (such as by giving feedback on our Website or leaving a review on our products or contacting our representatives via email); and/or

(k) when you submit your Personal Data to us for any other reason;

2.2 When you browse our Website, you generally do so anonymously but please see the section below on cookies. We do not automatically collect Personal Data via our Website, including your email address unless you provide such information or login with your account credentials.

2.3 We may also collect and process information from third-party sources, which may include public records, or social media platforms. If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the collection, use and disclosure of their Personal Data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any products and/or services you have requested.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, where permitted under applicable law, HPH collects, uses and discloses your Personal Data for the following purposes:

(a) responding to your queries and requests;

(b) managing the infrastructure, administrative and business operations of any entity within HPH and complying with internal policies and procedures;

(c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the entities related to HPH;

(d) matching any Personal Data held which relates to you for any of the purposes listed herein;

(e) resolving complaints and handling requests and enquiries;

(f) preventing, detecting and investigating crime;

(g) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;

(f) communicating with you and informing you of changes and development to HPH’s policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the products and services offered to you;

(j) protecting or addressing our legal rights or obligations;

(k) managing and preparing reports or documentation for submission to regulatory authorities;

(l) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

(m) matching any Personal Data held which relates to you for any of the purposes listed herein; and/or

(n) any other purpose relating to or reasonably necessary for any of the above

These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

3.2 If you are a tenant or a visitor to our premises, HPH collects, uses and discloses your Personal Data for the following purposes:

(a) monitoring and enhancing the security of the premises;

(b) contacting you in the event of emergencies and in other situations, where necessary;

(d) any other purposes relating to the aforesaid.

3.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in delays in the processing of your application, or our inability to process your application.

3.4 In addition, where permitted under applicable law, HPH may also collect, use and disclose your Personal Data for the following purposes, which we may describe as “Additional Purposes”:

(a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;

(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by HPH or other third parties;

(d) sending you details of products, services, special offers and rewards, either to our customers generally, or which may be of interest to you;

(e) conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes; and

(h) processing of your Personal Date in relation to any of the purposes stated above.

3.5 If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, HPH may, subject to applicable laws, contact you using such telephone number(s) (including via voice calls, sms, fax or other means) with information about our products and services (including discounts and special offers).

3.6 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.7 In relation to particular products or services or in your interactions with us, we may also have provided additional “just-in-time” disclosures or specifically notified you of other purposes for which we process your Personal Data. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your Personal Data for these purposes as well.

3.8 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to HPH collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:

(a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to HPH for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and

(b) where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Data Protection Policy.

3.9 In addition to and without limiting the consents you have provided to our collection, use and/or disclosure of your Personal Data for the purposes set out elsewhere in this Data Protection Policy, where permitted by applicable law, HPH may also in accordance with the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of applicable law:

(a) for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes:

(i) any investigations or proceedings;

(ii) fraud detection and prevention; and

(iii) detection and prevention of misuse of services by users; and

(b) we may collect your Personal Data from any of our partners, we may use your Personal Data, and any of our partners may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective customer of HPH).

4. Disclosure of Personal Data

4.1 Personal Data will be protected and kept confidential but, subject to the provisions of any applicable law, may be provided, for the purposes listed above (where applicable), to the following third parties, whether they are located in Japan or outside of Japan:

(a) HPH, its affiliates and its related entities;

(b) vendors, agents, contractors or third party service providers who provide operational services to HPH, either independently or on our behalf in connection with any of the purposes listed above in this Data Protection Policy such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to HPH;

(c) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the entities related to HPH;

(d) banks, credit card companies and their respective service providers;

(e) our professional advisers such as our auditors and lawyers;

(f) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and/or

(g) any other party to whom you authorise us to disclose your Personal Data to.

5. Use of cookies

5.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.

5.2 HPH uses “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

5.3 The Aggregate Information collected is used to assist HPH in analysing the usage of the website and improving the website.

5.4 You acknowledge and agree that our Website may include analytics code and other tools that may allow us to gather information on any use of any aspect of our Website, and may include our use of cookies, running of verification and compliance analysis and/or use of data capture, syndication analysis, and/or other similar tools to track, extract, compile, aggregate, archive, disclose or otherwise analyse any data and/or information resulting from any person’s access to and/or use of any of our Website, and further that: (a) we shall retain all rights, title and interest in and to all such gathered information and data; (b) you shall not disable or interfere with any such analytics code and tools; and (c) any intellectual property rights of or in the results of such analytics shall vest solely in us. For the avoidance of doubt, we may monitor, track and share with third parties your geo-location information obtained by our Website for safety, security, technical, marketing and commercial purposes, including to provide and improve our products and services.

5.5 Without limiting the generality of the foregoing, we may employ cookies and other technologies as follows:

(a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;

(b) making our Website easier to use. For example, cookies may be used to help speed up your future interactions with our Website;

(c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;

(d) collating information on a user’s search and browsing history;

(e) when you interact with us on our Website, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page, your searches, and other actions);

(f) using such information to understand how people use our Website, and to help us improve their structure and contents;

(g) using cookies that are necessary in order to enable our Website to operate, for example, cookies that enable you to log onto secure parts of our Website; and/or

(h) personalising the Website for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.

5.6 Most browsers let you remove or reject cookies. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies. To remove or reject cookies, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website and this may impact your user experience while on our Website, including but not limited to your ability to enter or use certain part(s) of our Website. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

5.7 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites, platforms and other HPH online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.

5.8 If you have registered for an account with us, you may review and update certain account information by logging into your account, or by contacting us in the manner specified below. You should ensure that all Personal Data submitted to us is accurate, true and correct, as failure on your part to do so may affect our ability to provide you with any products and/or services.

6. Data Security

6.1 HPH will take reasonable measures to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.

6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via our Website, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

6.3 If applicable, you undertake to protect against unauthorized access to your password and to your computer, and to sign off when you are no longer accessing the Website and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.

7. Contacting Us – Withdrawal, Access and Correction of your Personal Data

7.1 If you:

(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;

(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

please contact HPH’s designated Data Protection Officer at the following email address: tigerbalm@hph.hawpar.com

7.2 Please note that while we respect your decision to withdraw your consent to any processing of your Personal Data, if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, HPH may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements with HPH, and your being in breach of your contractual obligations or undertakings, and HPH’s legal rights and remedies in such event are expressly reserved. Withdrawing consent does not affect our right to continue to process Personal Data where such processing without consent is permitted or required under applicable laws.

7.3 Upon receipt of your written request, we may require reasonable time to process your request 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 thirty (30) days of receiving it, and will inform you should we require more time or information from you to process the request (which may depend on the complexity of the request, the rights and exemptions under applicable law, and the impact on our relationship with you).

8. Governing Law

8.1 This Data Protection Policy and your use of this Website shall be governed in all respects by the laws of Singapore.

9. Third-Party Sites

9.1 Our Website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our Website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

10. Language

10.1 This English language version of the Data Protection Policy shall be the official version of the Data Protection Policy for the Tiger Balm Japan website. In the event of any conflict or inconsistency between the provisions of this English language version and any other language version, this English language version shall prevail.