TRUU.SG PRIVACY POLICY
Updated and Effective as of: 27 Nov 2023
Youth Biotech Pte Ltd (“we”, “us”, or “our”), operator of TRUU.SG, respects your concerns about privacy and value the relationship we have with you.
When you visit our websites (“Platform”) empowered by our SaaS service provider, SHOPLINE (“SHOPLINE”), we may collect and use personal information about you (including your employees and/or persons who act on your behalf). We may also collect and use personal information from you if you visit or purchase on the Platform. We are fully aware of the importance of personal information to you and we are committed to ensure integrity and security of the Platform. This Privacy Policy describes the types of personal information we collect about you, how we use the information, with whom we share it, and the choices available to you regarding our use of the information.
This Privacy Policy will help you understand the following:
What We Collect
Information You Provide
How We Use Personal Information
How We Use “Cookies” And Other Similar Tracking Technologies
How We Process, Share, Transfer And Disclose Personal Information
Your Rights and Choices
How We Protect Personal Information
How We update this Privacy Policy
How To Contact Us
What We Collect
We may obtain personal information about you from various sources. We may collect this information when you provide it on or via the Platform, or when you access and/or use our social media/ social networking pages (or their relevant platforms or corresponding mobile applications, e.g. Facebook, Instagram). Our products are available for sale online only. When you visit the Platform, our social media/ social networking pages (or their relevant platforms or corresponding mobile applications), we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs and web beacons.
Information You Provide
You may choose to provide personal information to us in a number of ways, such as when you sign up on the Platform, or when you make a purchase on the Platform, or via our social media. The types of personal information you may provide to us, if applicable, include:
Contact information (such as name, postal address, email address, mobile phone or other phone numbers, mobile service provider);
Age and date of birth;
Gender, preferred language;
Username and password
Payment information (such as your payment card number, expiry date, delivery address, and billing address);
Purchase history;
Product preferences and communication channel preferences;
Content you provide (such as photographs, videos, reviews, articles, survey responses and comments);
Information provided to us when you visit our social media pages (such as your name, profile picture, likes, location, friend list and other information described on the social media network or application sign-up page, or your geo-location details when using one of our mobile applications);
Device identifiers, such as information about your device like your MAC address, IP address, or other online identifiers.
It is voluntary for you to provide your personal information to us, but certain services and promotions may not be available to you if you do not provide your personal information.
How We Use Personal Information
We may use the information you provide for the below purposes:
Send you promotional materials or other communications;
Provide requested information and services to you;
Contact you to follow up or confirm your orders, appointments, returns, or refunds and to send you other non-marketing communications related to products and services we provide to you;
Process your payment and/or transactions;
Create and manage your account, including access to your purchase history;
Respond to your inquiries;
Tailor ads on the Platform, social media platforms and elsewhere to your interests and history with us;
Communicate with you about, and administer your participation in, special events, contests, sweepstakes, campaigns (if any), surveys and other offers;
Operate and communicate with you about our social networking or [mobile applications];
Operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; managing our communications; analyzing our products; performing market researches, data analytics and customer relations management programs, and performing accounting, auditing and other internal functions);
Comply with applicable legal requirements, relevant industry standards and our policies;
To avoid duplication and ensure accuracy of your Information, periodically conduct data cleansing, linking or merging of our records, either internally or through our service providers.
We also may use the information in other ways for which we provide specific notice at the time of collection.
If you provide us with your personal information, we intend to use it for direct marketing purpose to offer or advertise the availability of our goods and/or services. However, we may not use your personal information for such purpose unless we have received your consent to our intended use.
All types of personal information listed in the section "Information You Provide" above may be used by us in direct marketing if you provide such information to us and you expressly consent to such use in writing.
Direct marketing communications may be sent to you through various channels, including by telephone, post, email, SMS, through mobile apps, online apps, social media platforms and other online means. [NOTE: INCLUDE ALL THAT APPLIES TO YOUR BUSINESS] Upon your consent, the personal data you provided in the form, or the personal data you provided at the time when you consented to the said subscription, would simultaneously be used by us for that marketing purpose. Our handling of any data transfer issues concerned under this paragraph would remain consistent with what is provided in this Privacy Policy.
If you do not wish us to use your personal information in direct marketing, you may opt out of our direct marketing at any time by following the procedures set out in the section “Your Rights and Choices” below. We must, without charge to you, cease to use your personal information in direct marketing if you so require.
We will use the personal information supplied by you for direct marketing only in accordance with [insert the relevant data privacy laws in the relevant Country] [NOTE: TO INSERT THE RELEVANT DATA PRIVACY LAW]. Our direct marketing materials may come in several forms, including but not limited to marketing mails, emails and text messages, the details of which are set out in the following sub-sections.
How We Use “Cookies” And Other Similar Tracking Technologies
What are “cookies”
A cookie is a small file stored in your computer, mobile phone or any other smart terminal device by the Platform server when it logs into the Platform or browses Platform content, usually containing identifiers, site names and some numbers and characters. When you visit the Platform again, the Platform can identify the browser of you through cookies. Cookies may store user preferences and other information.
(2) How “cookies” are used
When you use the Platform, we may collect the device model, operating system, device identifier and login IP address information of the Personal Data Subject through cookies or similar technologies, as well as cache the browsing information and clicking information of the Personal Data Subject, so as to view the network environment of the Personal Data Subject. Cookies allow us to identify you when it visits the Platform, continuously optimize the user friendliness of the Platform and make adjustments to the website according to the needs of you. You can also change the settings of the browser so that the browser does not accept cookies on the Platform, but this may affect your use of some features of the website.
On the Platform, with the help of cookies and other similar technologies, we can identify whether you are our user without having to re-login and authenticate on each page.
(3) How to manage “cookies”
You can manage or delete certain categories of tracking technologies according to their own preferences. Many web browsers have a Do Not Track feature that sends a Do Not Track request to the Platform.
In addition to the controls we provide, you may choose to enable or disable cookies in their Internet browsers. Most Internet browsers also allow you to choose whether to disable all cookies or only third-party cookies. By default, most Internet browsers accept cookies, but this can be changed. For more information, see the Help menu in your Internet browser or the documentation of your device.
The following links provide instructions on how to control cookies in all major browsers:
Google Chrome:https://support.google.com/chrome/answer/95647?hl=en
IE:https://support.microsoft.com/en-us/help/260971/description-of-cookies
Safari (desktop): https://support.apple.com/kb/PH5042?locale=en_US
Firefox browser: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
On the Platform, you may delete existing tracking technologies by clearing the cache.
When you browse a webpage without logging in, we will collect cookies necessary to realize the browsing feature in order to provide relevant services to you.
Please note that if you refuse to use or remove the existing tracking technologies, it is necessary to personally change the user settings at each visit, and we may not be able to provide a quality user experience to you, and some feature may not be able to function properly.
How We Process, Share, Transfer And Disclose Personal Information
(1) Process
Certain features of the Platform may be provided by our third-party partners, and we may entrust partners (including technical service providers) with the processing of certain personal information of you. For example, when you use auto-payments feature, we may ask third-party payments companies to process your credit card information so that to charge you relevant services fee as directed by you; when SHOPLINE Payments is used, we may ask third-party services providers which can facilitate in “Know Your Client” and transaction monitoring and risk management, to process your and your customers’ personal information. We will sign confidentiality agreements with the third-party services providers to govern purposes of data processing, process period, and the responsibilities of both parties, and will ask the partners to process data in accordance with our requirements and this Privacy Policy. If you do not agree the partners to collect personal information necessary for the provision of relevant services, you or your customers may not be able to use the relevant services.
(2) Sharing
We do not share personal information with any third parties unless one or more of the following circumstances exist:
At your request, or with the prior explicit authorization or consent of you;
Related to performance of our obligations under laws and regulations;
Directly related to national security or national defense security;
Directly related to public safety, public health and major public interests;
Directly related to criminal investigation, prosecution, trials and enforcement;
For the purpose of safeguarding the life, property and other major legitimate rights and interests of you or any other person, but it is difficult to obtain the consent of that person;
The personal information involved is disclosed to the public by you;
The personal information involved is collected from lawfully and publicly disclosed information.
Sharing with SHOPLINE and affiliated companies of SHOPLINE: In order to provide you with SHOPLINE products and services, to make recommendation that may be of interest to you, to troubleshoot accounts issues, and protect the personal and property safety of our affiliated companies or other users or the public, you acknowledge and agree that we may share your and your customers' personal information with our affiliated companies. We will only share personal information to the extent necessary and are bound by purposes as specified under this Privacy Policy. If we share sensitive personal information or our affiliated companies use and process the personal information for different purposes, we will seek authorization and consent from you again.
Sharing with our third-party partners: We will only share personal information for lawful, legitimate, necessary, specific and explicit purposes, and will only share personal information necessary to provide relevant services to you or your customers. We will not share personal information that can identify you, unless otherwise permitted by laws or regulations. Generally, these third-party partners are also data controllers who will process personal information in their own accounts after obtaining the consent of you. Such partners may have their own separate privacy policies and user agreements.
n addition, We may use third party features or services when we use the Platform (including apps from Apps Store, payments gateways or logistics services providers). Please note that such features or services are provided by third parties. The rules and procedures described in this Privacy Policy do not apply to such third-party features and services. Any information you provide to third-party websites or services will be provided directly to the network operators of these services. Even if you access through the Platform, you must comply with the applicable privacy policies and user agreements (if any) of these third parties. We are not responsible for the content of any third-party websites, and third-party policies on personal information and security measures. You shall read and understand the privacy policies and user agreements of third parties before providing any personal information to them.
(3) Transfer
In principle, we will not transfer control of personal information to any third parties, except in the following circumstances:
At the request of the personal information subject, or with your prior express authorization or consent;
Related to performance of our obligations under laws and regulations;
Directly related to national security or national defense security;
Directly related to public safety, public health and major public interests;
Directly related to criminal investigation, prosecution, trials and enforcement;
For the purpose of safeguarding the life, property and other major legitimate rights and interests of you or any other person, but it is difficult to obtain the authorization and consent of that person;
The personal information involved is disclosed to the public by you;
The personal information involved is collected from lawfully and publicly disclosed information;
Transfer in the event of a change of operational entities following an acquisition, merger, reorganization or bankruptcy.
Note: If transfer is necessary due to the above reasons, we will inform you of the purpose and type of transfer and transferee of the information before the transfer (we will also let you know if sensitive information is involved) and obtain your consent to such transfer, except as otherwise provided by law or regulation. The transferee will continue to perform personal information related obligations hereunder. If we go bankrupt or cease operation and there is no transferee, we will delete or anonymize your personal information.
(4) Public disclosure
In principle, we will not disclose your personal information to the public or undefined groups, except that we may disclose your personal information based on our agreement with you or according to applicable laws and regulations.
Minors
The Platform is not intended for individuals under the age of 22. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address above to request deletion.
Your Rights and Choices
We offer you certain choices in connection with the personal information we collect from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.
Email Opt-Out
You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated in the "How to Contact Us" section below. You also may opt out of receiving marketing emails from us by sending an opt-out request to truusg8888@gmail.com
Text Message Opt-Out
You can request that we refrain from sending you text messages by contacting us as indicated below.
Social Networking Application Opt-Out
To remove or delete our social media applications from your social networking account, follow the instructions from the social network.
For Facebook: please see instructions provided by the Facebook Help Center .
Geo-Location Information
When you use one of our mobile applications, you may be asked for your geo-location via such mobile application. You may choose not to share your geo-location details by adjusting your mobile device’s location services settings. To decline sharing your geo-location details, follow the instructions on your mobile device on changing the relevant settings; otherwise, please contact your service provider or device manufacturer.
Withdrawing Consent
You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot take advantage of some of our products or services.
Reviewing, Updating and Modifying Personal Information
We may retain and use your Information for as long as necessary to fulfill the purposes set out above. You have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to review, change or delete your personal information by sending an email to truusg8888@gmail.com [with attention to our data protection officer”.
How We Protect Personal Information
We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no security system is perfect, and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.
For how SHOPLINE retains and protect personal information, please refer to Privacy policy (shopline.com).
How We Update This Privacy Policy
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on the Platform to notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated.
How to Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at truusg8888@gmail.com.
Discrepancies
If there is any conflict between the English and the Chinese versions of this Privacy Policy, the English version shall prevail.