Updated on: 1 August 2020

Xpressflower.com Pte Ltd (“XF” or as appropriate in the context, “we”, “us” or “our”) respects the protection of the Personal Data of individuals and value the relationship we have with you. We take responsibility for protecting your Personal Data and compliance with Applicable Laws very seriously. We are committed to properly managing, protecting and processing your Personal Data in accordance with this Policy, which shall apply to all Personal Data we collect from you through our Platforms. 

 
This Personal Data Policy (“Policy”) describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through our Website. We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices. “Personal Data” in this Policy means data that can identify an individual.

1. What Personal Data do we collect? 

The types of Personal Data that we collect about individuals include: 

1. Name
2. Mobile number
3. Email address
4. Residential/Commercial address
5. Residential/Commercial telephone number

(*) We do NOT STORE our customer credit card data. All credit card data captured during checkout are tokenized and send to the payment gateway for processing. 

You may have provided the Personal Data to us personally or authorised other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals. These individuals could be your superiors, employees, subordinates, colleagues and your family members.

Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in the section “Purposes for which we collect and use Personal Data”, or other purposes for which your consent has been sought and obtained.

2. How will your data be used?

We may use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:

• Register and maintain your Online User account;
• Verify your or your recipient Identity
• Process your online order for our products or services;
• Deliver or perform the products or services you purchased, including our couriers calling or messaging you to obtain your delivery instructions;
• Process your refunds;
• Respond to your requests or queries
• To share news on our products, marketing materials and notify you of changes in our service or product offerings, promotions via email, postal mail, SMS or phone
• Personalise your online shopping experience
• To improve our services to you. Market research is performed so that we are able to improve our marketing initiatives, product development and customer service.
• To maintain general record and book keeping.

In addition, we may use and disclose your Personal Data for the following "Additional Purposes" to:

• send you marketing communications in relation to our sales, products, services, promotions or the Platforms;
• send you marketing communications in relation to the sales, products, services or promotions of business partners, including promotional mail together with your order;
• deliver ads which are related to our products and services which may be of interest to you on the Platforms or other websites, apps or online platforms;
• enable businesses to deliver ads which are related to their products and services which may be of interest to you;
• invitation for customer events;
• process your participation in our promotions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
• process your participation in our business partners’ loyalty or point redemption programs;
• conduct market and customer research, analysis or tracking;
• promote our products and services on our Platforms;
• manage the administrative and business operations of Xpressflower.com and complying with internal policies and procedures;
• improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
• any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page;

3. Who will your personal data be shared with?

In the course of or in connection with providing our products and services to our customers and partners, we may disclose, share and transfer Personal Data to the following parties:

• employees;
• professional advisers and consultants;
• payment processors, who process your payment on the Website and the Apps;
• logistics providers, such as courier services which will deliver your order to you;
• business partners or vendors in connection with the processing of any promotion, event or service organised by us;
• agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and

We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.

In addition, we would disclose Personal Data in the following circumstances:

• we are required to do so by law;
• in response to a request from law enforcement authorities or other government officials;
• to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
• where the disclosure is necessary for investigations or legal proceedings.

4. How do we secure and protect your Personal Data?

We employ a range of technological and physical security arrangements and maintain safeguards to protect against the accidental or unauthorised access, collection, use, disclosure, copying, modification, disposal, deletion and other similar risks to Personal Data. Once we receive your personal information, it is encrypted, protected with firewalls and stored in highly secure data centers. This information is encrypted and transmitted over the Internet with SSL (secure-socket-layer) encryption technology. Other security measures on this website include limited access data-centers and firewall technology to ensure your information is safe and protected.  

Your Password

Your password is the key to your account. Please use unique numbers, letters and special characters, and do not share your Lazada password to anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal data and other data submitted to Xpressflower. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log out of your account and close the browser when you are finished using a shared computer.

5. Retention of your Personal Data

We only retain Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes.  

When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised (remove the means by which the data can be associated with you).

6. How to Contact Us

If you have any questions or comments about this Policy and our policies and practices on our collection, use, disclosure or retention of Personal Data

Please contact the Data Protection Officer:

Attention: Data Protection Officer
Email address:  [email protected]
Mailing address: 160 Paya Lebar Rd, #03-03/04, Orion@PayaLebar S(409022)

7. Updating or correcting your Personal Data

We take reasonable measures to ensure that the Personal Data we collect about individuals are accurate and complete.  For this reason, if there is any change or update in Personal Data, we would like to know about these changes or updates.  If there is a change or an update in your Personal Data or if there is a need to correct any Personal Data of yours that we have, please write to us and provide us with the following details:

1. Your name and an email address or mailing address at which we can contact you.
2. The nature of our relationship with you.
3. The Personal Data for which there has been a change, update or correction.

You may send your requests to the Data Protection Officer at the contact details listed in Section 6 above. We will acknowledge the receipt of your request within 3 working days after the date of receipt of your request if it is sent by e-mail, or within 7 days after the date of receipt of your request if it is sent by post. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.

There may be circumstances where we will not update or correct Personal Data, for example, the Personal Data is opinion data that is kept solely for an evaluative purpose.

8. Your Requests and Feedback on your Personal Data with us

Request for Information Notice

You may request for information from XF on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request.  To learn more about how you can request for information from XF, please mark your email or letter to us (please refer to Section 6) with the subject line “Request for Information Notice”.

Withdrawal of Consent Notice

You may also choose to withdraw your consent to XF’ use, collection, sharing or processing of your Personal Data at any time.  To learn more about how you can withdraw your consent, please mark your email or letter to us (please refer to Section 6) with the subject line “Withdrawal of Consent Notice”.  Please understand that your withdrawal of your consent to our use of your Personal Data may affect our provision of products and services to you or our business dealings with you, depending on the nature of your relationship with us. 

Feedback and Complaint Notice    

If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, we are open to receiving your feedback or complaint.  To learn more about how you may submit your comments/complaints about our use and/or sharing of your Personal Data, please mark your email or letter to us (pl refer to Section 6) “Feedback and Complaint Notice”.   

We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes or updates to the notice. We will indicate the effective date of the notice. If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data (please refer to Section 8 above). 

9. Third Party Cookies

XF uses the services of third party vendors, who may implement cookies on the Website. Advertisements on the Website may be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including Personal Data, collected by such third party cookies are subject to the privacy and data protection policies of the third party vendors and are not under our control.

You may reject third party cookies through the settings on your browser. Note that this may result in the loss of Website functionality, restrict your use of the Website, or delay or affect the way in which the Website operates.

10. Google Analytics and related services

XF uses certain Google Analytics functions. Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking.

XF may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.

XF also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show XF ads on sites across the Internet. XF and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors’ past visits to XF, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to XF.

When you log on to the XF website, XF with the help of Google Analytics may use your browsing behavior to connect it with any other data that has previously been provided by you, in accordance with this policy.

11. Secure Payment Process

Safe transactions and the protection of your privacy are and have always been our top priorities. Each and every transaction made on xpressflower.com is safe as they are put through Secure Sockets Layer (SSL) encryption.

10. Governing Law

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

11. Updates on Data Protection Policy

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, XF may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion.

Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Website. Any amended Policy will be posted on our website and can be viewed at www.xpressflower.com/data-protection-policy-pdp By continuing to use our Platforms and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.

You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.

Updated on: 1 August 2020