This Privacy Policy sets out how we, I-PRIMO Singapore, and our subsidiaries and associated companies (hereafter collectively referred to as “the Companies”) collect, use, disclose, transfer and store your Personal Information (as defined below). We are committed to protecting your privacy. The Companies may share your Personal Information with each other and use it in a manner and for purposes which are consistent with this Privacy Policy and consistent with the Personal Data Protection Act 2012 of Singapore. We may combine your Personal Information with other information for the purposes of providing products and services to you, or to improve our products, services, content and advertising.

By visiting the Companies website or by providing us with your personal data whether through website, enquiry, in-store transactions or by any other means whatsoever, you accept and consent to the terms of this Privacy Policy.

1. CONSENT & DATA COLLECTION

   We may collect, use, disclose, transfer and store any information you enter on our website or give us through various means, including telephone calls, emails, enquiries or transactions at our sales office, SMS, fax, post, and any platforms used by the Companies from time to time (collectively the “Platforms”). The information which we collect includes information that can identify you (“Personal Data”), including, but not limited to, your name, contact numbers, postal and email addresses, contact preferences, demographic information and payment details if a transaction is carried out.

   We may request Personal Information relating to you through surveys or contests which we conduct from time to time. Participation in these surveys or contests is completely voluntary and you have a choice as to whether or not to provide the Personal Information we have requested through the survey or contest. Personal Information collected through surveys will be used for the purposes of monitoring or improving the use and satisfaction of our services. Personal Information collected through contests will be used to notify winners and award prizes.

   The provision of Personal Data by you to us such as your name, email address, contact details, credit card and such other information may be indicated by I-PRIMO Singapore as compulsory or obligatory in order for I-PRIMO Singapore to perform relevant purposes, as stated in the following section. I-PRIMO may not be able to perform such purposes if you fail to supply your personal information.

2. USAGE OF PERSONAL INFORMATION

   We will use your Personal Information for the following purposes:

   • to provide you with the products and services you request;
   • to provide you with product & web reservation confirmation and updates;
   • to manage your account, including processing bills and providing notifications or updates with regards to your product;
   • to communicate with you in general;
   • to respond to your questions and comments;
   • to allow us to contact you for customer service, if necessary;
   • to measure interest in and improve our products, services, and website;
   • to notify you about special offers and related products and services that may be of interest to you;
   • to customise your experience on our website;
   • to reward you as part of any reward and recognition programme you choose to join;
   • to resolve disputes, collect fees, or troubleshoot problems;
   • to prevent potentially prohibited or illegal activities;
   • to enforce our Terms and Conditions when you make a travel booking with us; and
   • as otherwise notified to you at the point of collection.

   We send marketing messages to you through email, SMS, fax or post that contain information about your jewellery-related interests and special offers which are available with us. Please note that you can withdraw your consent for us to send marketing messages to you. Please refer to the opt-in and opt-out policy section of this Privacy Policy which sets out how you may set your preferences in relation to such marketing messages.

3. DISCLOSURE OF INFORMATION

   We may share your Personal Information with the following third parties, some of whom may be located overseas, and a result, may require us to transfer your Personal Information overseas:

   • Third Party Suppliers or agents may contact you as necessary to obtain additional information about you in order to facilitate the product/service reservation which you have made through us.
   • Third Party Vendors who provide services or functions on our behalf, including credit card processing, business analytics, customer service, marketing, distribution of surveys or contest programmes and fraud prevention. We may also authorise third party vendors to collect Personal Information on our behalf, including as necessary to operate features of our Platforms, or to facilitate the delivery of online advertising tailored to your interests. Third party vendors have access to and may collect Personal Information only as needed to perform their functions and are not permitted to share or use the Personal Information for any other purpose.
   • Business Partners with whom we may jointly offer products or services. If you choose to receive information about these products or services, we may share information about you, including your Personal Information, with those third party partners so that they can contact you directly by email or post about their products and services.

   We will only disclose your Personal Information with your consent (whether implied or express), and will take reasonable steps to ensure that the third parties to whom we have disclosed your Personal Information are also legally bound to protect the privacy of your Personal Information.

   We may also disclose your Personal Information:

   • Where disclosure is necessary to comply with applicable laws, governmental or other regulation or the requirements, orders, directions, instructions or notices of any regulatory authority or legal processes.
   • When we believe it is appropriate to investigate, prevent or take action regarding illegal or suspected illegal activities; to protect and defend the rights and property of the Companies.
   • To effect a corporate transaction, in connection with the sale, merger, acquisition, spin-off or other corporate reorganisation of the Companies.

   We do not rent or sell your personal information to third parties for their marketing purposes without your explicit consent.

4. ACCESSING, CORRECTING, AND AMENDING YOUR PERSONAL DATA

   Where applicable, reasonable steps are taken by us to verify the accuracy of your personal information received at the point of collection. However, please note that you are primarily responsible and liable for the accuracy and completion of all personal information submitted by you.

   You may access, review, correct, and amend your personal data by updating your profile with us. If you have provided your personal data through our website, stores, enquiry or, you may request the correction or amendment of your personal data by contacting our customer service department. I-PRIMO Singapore may comply with your request to access, amend or delete your personal data, to the extent required by law.

5. RETENTION OF INFORMATION

   Your personal data will be retained for as long as it is necessary to fulfill the purposes for which it is collected or for business or legal purposes, or in accordance with applicable laws.

   Deletion of your account with us does not automatically delete all personal data about you. If you choose to request that we delete all personal data together with the deletion of your account and unsubscribe from our mailing list, please contact us at ionorchard@iprimo.sg. Our ability to comply with your deletion request is subject to any applicable legal or other requirement to maintain records of your personal data.

   Please allow 14 working days for your request to be processed.

6. OPT-IN AND OPT-OUT POLICY

   We offer you the ability to opt-in to or opt-out from (as the case may be) receiving marketing messages in relation to our products and services or the products and services of third parties by logging into your account on our member portal and changing your preferences, or emailing us at ionorchard@iprimo.sg.

   While we respect your decision to opt out of receiving marketing information, you understand and accept that this may in some cases impact the availability of services and the quality of services that we may provide to you and may mean that the services provided to you (if possible at all) by us may not be customised for your use, may be less user-friendly and less efficient.

7. TERMS SPECIFIC TO OUR WEBSITE

   Cookies and Other Web Technologies

   We automatically collect some information about you and your computer when you visit our website, such as your IP address, web browser software (such as Firefox, Microsoft Edge or Safari), referring websites, and information about your online activities on our website, such as information viewed and purchases made. One of our goals in collecting this automatic information is to help customise your user experience.

   As a member or visitor to our website, you will be assigned a permanent cookie file on your computer’s hard drive. You can always choose not to receive a cookie file by enabling your web browser to refuse cookies or prompt you before accepting a cookie.

   In addition to the above cookies, we use local shared objects, also referred to as flash cookies, on our website. These are used to enhance your user experience, for example, by storing your user preferences and settings, such as your volume/mute settings, and in connection with animated content on our website. Local shared objects are similar to browser cookies, but can store data more complex than simple text. By themselves, they cannot do anything to or with the data on your computer. Like other cookies, they can only access personal identifiable information that you have provided on our website, and cannot be accessed by other websites.

   Our website may also use web beacons (also known as clear gifs or pixel tags), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a web page. We use web beacons to monitor the traffic patterns of users from one page within our website to another, to deliver or communicate with cookies, to understand whether you have come to our website from an online advertisement displayed on a third-party website, and to improve website performance. We may also allow our third-party vendors to use web beacons to help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our website. This helps us to measure the effectiveness of our content and other offerings.

   Terms Specific to Mobile Phone Devices

   When you use a mobile device to access our website, we will collect, use, disclose, transfer and store Personal Information relating to you in the same way and for the same purposes as when you use a computer to access our website. We also collect, use, disclose, transfer and store the following additional information from your use of a mobile device to access our website in order to optimise our website to minimise data usage:

   The distinction between mobile application and website is not clear in points a and b and may need to be clarified

   • We collect information on the areas of our website which you access through your mobile device, which allows us to refine the arrangement of our website content for compatibility with mobile devices. This information is collected anonymously and we cannot identify you from this.
8. HOW WE PROTECT YOUR PERSONAL INFORMATION

   We want you to feel confident about using our Platforms and we are committed to protecting the Personal Information we collect. We have implemented reasonable administrative, technical, and physical security procedures to help protect the Personal Information you provide to us. For example, only authorised employees are permitted to access your Personal Information and they may do so only for permitted business functions.

   Accessing and Updating Personal Information

   You can access and update the Personal Information which we hold about you. In order to request access to or update your Personal Information, please email us at ionorchard@iprimo.sg.

   We will use reasonable endeavours to ensure that the Personal Information which we hold about you is accurate, complete and up-to-date whenever we collect or use it. This means that from time to time, we will ask you to tell us if there are any changes to your Personal Information. If you find that any Personal Information which we hold about you is incorrect, please notify us immediately.

9. POLICY ON TELEPHONE NUMBERS REGISTERED WITH THE DNC REGISTRY

   Unsolicited telemarketing messages will not be sent to your telephone numbers if they are registered under the Do-Not-Call Registry (“DNC Registry”), unless we have your clear and unambiguous consent to do so. However, we may continue to contact you at the telephone numbers provided to us in the limited circumstances allowed under the DNC Registry even though you have registered these telephone numbers with the DNC Registry. If you do not wish to continue receiving such messages, please email us at ionorchard@iprimo.sg.

10. CHANGES TO PRIVACY POLICY

    We reserve the right to amend this Privacy Policy at any time. We will notify you of any changes to this Privacy Policy by sending a notice to the email address you have provided to us or by placing a prominent notice on our website.

    Contacting Us

    If you have questions relating to your Personal Information or our Privacy Policy, you can email us at ionorchard@iprimo.sg.