PRIVACY POLICY - 21^st August 2019

PDPA

This is True Heritage Brew’s Personal Data Protection Policy (“Personal Data Protection Policy”) and the purpose of this document is to inform you of how True Heritage Brew manages, collects, uses and discloses your Personal Data, which is subject to the Singapore Personal Data Protection Act (2012) (“the Act”). This Privacy Policy outlines True Heritage Brew’s policy and responsibility in relation to the collection, use and disclosure of Customer Data.

By continuing to use True Heritage Brew’s services, you signify that you have read, understood and agree to be bound by this Privacy Policy as amended from time to time in respect of True Heritage Brew’s collection, use and disclosure of your Customer Data.

True Heritage Brew is committed to protecting the privacy of visitors to this website (the “Site”). By using our Site, you consent to our Privacy Policy. If you do not agree with this Privacy Policy, please do not use our site.

Types of Customer Data

The types of Customer Data that True Heritage Brew collects depend on the circumstances of collection and on the nature of the service requested or transaction undertaken. There are two broad categories of Customer Data that True Heritage Brew collects:
(A)Personal Data, which includes but is not limited to -

1. 1. personal information that links back to an individual e.g., name, gender, date of birth;
2. 2. contact information e.g., address, phone number, email address;
3. 3. technical information e.g., IP address; and

(B) Statistical Data e.g., number of visitors, to the Site. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand True Heritage Brew's customer profile and improve True Heritage Brew's service offering. 

The provision of Customer Data (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for True Heritage Brew to carry out its services to you. The failure to supply such Customer Data may result in (i) True Heritage Brew being unable to provide you with the services and/or products requested; (ii) True Heritage Brew being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by True Heritage Brew.

Purposes for Collection, Use and Disclosure
Generally, True Heritage Brew collects Customer Data, either directly from you or from third parties (e.g. our service provider), or from publicly available sources, through our website, mobile services, and other channels including our retail outlets, in order to fulfil the following purposes, which include but are not limited to:

Personalising your experience
Your information may help us to better respond to your individual needs and more effectively provide customer service and support requested.
Providing services to you such as processing a transaction (e.g., making an order online), providing technical or customer service assistance, assisting you in the transaction through True Heritage Brew’s website;

Marketing and communicating with you in relation to products and services offered by True Heritage Brew, True Heritage Brew’s service partners, as well as True Heritage Brew’s appointed agents; Contacting you for product or customer surveys and market research; to administer a contest, promotion or other Site feature.

Unless you have specifically opted out by registering with the Do Not Call Registry and have informed us in advance.

Safety, security and legal compliance
True Heritage Brew may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above. True Heritage Brew shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of Customer Data will observe and adhere to the terms of this Privacy Policy. True Heritage Brew may disclose your Customer Data to law enforcement agencies and government for security purposes and if legally obliged to.

In addition, True Heritage Brew may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. True Heritage Brew also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity such as True Heritage Brew. Further, True Heritage Brew may disclose Customer Data, as is necessary, to investigate suspected unlawful activities.

Transfer of Information to outside parties
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party Sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked Sites.

Consent 
Generally, in the course of True Heritage Brew performing transactional functions such as making an order online, Customer Data will, by nature of the task or transaction, be provided by our customers to True Heritage Brew. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for True Heritage Brew to provide the requested or necessary service and/or product to them. However, where required by law, True Heritage Brew will adopt an ‘opt-in' policy for obtaining customer consent, in which event, express consent will be sought from you when collecting your Customer Data e.g., signing a form or checking a box or given verbally. Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to True Heritage Brew, has authorized the disclosure, is informed of and consents to the terms and conditions of this Privacy Policy. You may submit a request to withdraw your consent at any time by contacting True Heritage Brew.

Access 
True Heritage Brew will, upon your written request to our appointed Data Protection Officer, allow you to view your stored Personal Data. Where permitted by law, True Heritage Brew will reserve the right to charge a reasonable administrative fee for this service. In exceptional circumstances, True Heritage Brew reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws. Exceptional circumstances include where: 

An investigating authority or government institution objects True Heritage Brew complying with a customer’s request.
The information may, in the exercise of True Heritage Brew’s reasonable discretion and/or assessment, affect the life or security of an individual, and Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.

True Heritage Brew will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of True Heritage Brew, or as required by relevant laws. When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.

Accuracy
True Heritage Brew needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform True Heritage Brew of changes to your Personal Data by contacting True Heritage Brew and submitting your updated particulars.

True Heritage Brew may also request Personal Data updates from you from time to time. For e.g. your delivery address may be disclosed to the appropriate delivery fulfilment companies. As such, it is important to ensure that the Personal Data contained in your order confirmation is current, complete and accurate.

Security Safeguards
True Heritage Brew takes the security and protection of your Customer Data very seriously. As such, True Heritage Brew makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure. Including technical safeguards. If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, True Heritage Brew will not be liable for any consequential misuse and/or fraud.

Updates to the Privacy Policy
True Heritage Brew will amend this Privacy Policy from time to time and the updated versions will be posted on True Heritage Brew’s website and date stamped so that you are aware of when the Privacy Policy was last updated. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.

Cookies
Our Site uses cookies to enhance your online experience and to recognise your preferences and to tailor content to you. The cookies do not contain your Customer Data but only Statistical Data which is entirely anonymous. Cookies are small files that a Site or its service provider transfers to your computers hard drive through your web browser (if allowed) that enables the Site or service provider system to recognise your browser and capture and retain certain information. We use cookies to help us remember and process the items in your shopping cart and understand and save your preferences for future visits.

Minors
True Heritage Brew cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided True Heritage Brew with Customer Data without parental or guardian consent, the parent or guardian should contact True Heritage Brew to remove the relevant Customer Data and unsubscribe the minor.

At retail outlets where True Heritage Brew sells alcohol related products and services to the public, we are required by law to verify all customers are of legal drinking age. We may request verification of age to complete any sales transactions. Personal data is for age verification only and will not be retained under the provisions of the Act.

Contact Us
If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact True Heritage Brew in writing at the address below referencing ‘Privacy Policy' and attention to 

Data Protection Officer at info@trueheritagebrew.com