privacy

PRIVACY NOTICE

1. INTRODUCTION

Imperial Treasure Restaurant Group Pte Ltd, Imperial Treasure Cantonese Cuisine Pte Ltd, Imperial Treasure Nan Bei Restaurant Pte Ltd, Imperial Treasure Noodle House Pte Ltd, Imperial Treasure Fine Dining Restaurant Pte Ltd, Multirich F&B Management Pte Ltd, Imperial Treasure Windows of Hong Kong Pte Ltd and Imperial Treasure Steamboat Pte Ltd (collectively referred as "Imperial Treasure", "us", "we") is committed to protect the privacy of visitors to this website (the "Website"). This Privacy Notice sets out how Imperial Treasure collects, uses or discloses personal data that you have provided to us through the Website. By visiting the Website you are accepting and consenting to the collection, use and disclosure of personal data described in this Privacy Notice. If you do not agree with this Privacy Notice, please do not use the Website. This Privacy Notice does not apply to other websites to which we link ("Third Party Website" or "Third Party Websites"). 

This Privacy Notice also describes your data protection rights, including a right to object to some of the processing which Imperial Treasure carries out. More information about your rights, and how to exercise them, is set out in the following section: “8. What rights do I have”.

Maintaining the privacy of our customers’ information is important to us. We do not disclose rent or sell our customers’ personal data to third parties (except as described in "5. Disclosures of personal data to third parties").

 

2. COLLECTION AND USE OF PERSONAL DATA

We collect the following personal data when you register as a user of the Website and make purchases through the Website:

  • email address
  • your NRIC or FIN number;
  • your name, address and phone number (including delivery addresses if different);
  • billing address, including your name, address and phone number; and
  • any other personal data provided to us when you submit any comment, question or feedback to us, request services from us, or disclose your personal data to us in any way

We use your personal data for the following purposes:

  • To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us. This includes:
    • to fulfil your order and deliver it to you;
    • to facilitate and track your purchases from us (including in our restaurants or via our websites); and
    • to provide you with service support;
       
  • As required by Imperial Treasure to conduct our business and pursue our legitimate interest, in particular:
    • to facilitate your registration as a user of the Website;
    • to use information you provide to provide products and services you have requested;
    • (if you use a card payment for any purchase on the Website) we use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud; and
    • respond to comments, queries and feedback.
       
  • Where you give us consent:
    • we provide you with marketing and promotional material and other information about our products (including promotions and special offers), as well as other products and services provided by our affiliates and partners;[A1] [A2]  and
    • on other occasions where we ask you for consent, we will use the data for the purposes which we explain at that time.
       
  • For purposes which are required by law: in response to requests by government or law enforcement authorities conducting an investigation.

Additionally[A3] [A4] , through the Website, we may gather certain aggregated and anonymous information about the use of the Website, such as how frequently certain areas of the Website are visited, including through the use of cookies, web beacons, Google Analytics and other technologies.

We may use cookies, web beacons, Google Analytics and other technologies for the following purposes:

  • to identify the causes of problems arising at web servers and to resolve these problems;
  • to improve the contents of the Website;
  • to customize the content of the Website and our emails to suit your individual interests or purposes and selectively display best-matched pages to you, including tracking your past purchases in order to provide you with new services or special promotions;
  • to utilize your browsing history on the Website for demographic research; and
  • to obtain static data of web visitors and aggregated website visitation statistics which are anonymous in nature.

You may reject our use of cookies by configuring your browser to disable the use of cookies. However, you may no longer be able to receive services or personalized features of the Website which rely on the use of cookies.

3. RELYING ON OUR LEGITIMATE INTERESTS

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

4. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

5. DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES

In order to provide services to you, we may disclose, transfer out of Singapore, your personal data as described in this Privacy Notice:

Your personal data may be transferred out of Singapore from time to time. Such transfers will be carried out in accordance with the Singapore Personal Data Protection Act 2012. Third parties, with the exception of Singapore public agencies, are subject to data protection obligations and may only use your personal data to perform the necessary functions.

Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules.  A copy of the relevant mechanism can be provided for your review on request to our Data Protection Office (please refer to the section below: "9. Contact Us").

 

6. HOW WE PROTECT YOUR INFORMATION

We are committed to protecting the information we receive from you. We adopt reasonable physical, technical and administrative practices to help protect the confidentiality, security and integrity of data, including personal data, stored on our system. We believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved. Although we take reasonable steps to protect the information we receive from you, no computer system is completely secure and we cannot be held liable for any loss you may suffer for unauthorized access or loss of any data provided to the Website.

 

7. LINKS TO THIRD PARTY SITES

The Website may contain links to third party websites and microsites, including third party payment gateways, whose privacy practices may differ from those of ours. If you submit personal data, including payment information, to any of those websites, that personal data is not subject to this Privacy Notice and will be subject to the third party's privacy practices instead.

We therefore encourage you to review the privacy statement of any website you visit. By clicking on or activating such links and leaving the Website, we can no longer exercise control over any data or information which you give to any other entity after leaving the Website, and any access to such other websites is entirely at your own risk.

 

 

8. WHAT RIGHTS DO I HAVE

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the applicable laws and regulations. We will inform you of relevant exemptions we rely upon when responding to any request you make.

If you are based in the EU and have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.  

The provision of your name, family name, NRIC, contact number, Gender, Date of Birth, Country Code and email address is mandatory such that we can contact you and to fulfil any of your orders: if relevant data is not provided, then we will not be able to fulfil your orders. All other provision of your information is optional.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – by contacting our Data Protection Manager (See "11. Contact us" below).  To correct your personal data, you can do so by signing into your user account and updating your personal data. We will only disclose personal data in accordance with an access request to the individual who registered his/her personal data with the Website, and only after confirming that the person requesting access is indeed the registered party.

You may also contact our Data Protection Manger to withdraw your consent to our use of your personal data.

Please allow ten (10) working days for your request to be processed.

 

9. RETENTION OF INFORMATION[A9] [A10]  [A11] 

Where we process registration data, we do this for as long as you are an active user of the Website and for 6 years after this.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Where we process personal data in connection with performing a contract, we keep the data for 6 years from your last interaction with us.

If you withdraw your consent to our collection, use or disclosure of your personal data, we may not be able to provide you with services that require such personal data. Please also note that your personal data may still be retained on our database to the extent permitted by law.

 

10. PRIVACY POLICY CHANGES

If we decide to change our Privacy Notice for the Website, we will post the revised Privacy Notice here and, if appropriate, notify you by email. Please check back frequently to see any updates or changes to our Privacy Notice.


11. CONTACT US

If you have any questions about this Privacy Notice, please contact our Data Protection Manager at [DPO@imperialtreasure.com].