Privacy Policy

Updated as of 2 July 2018

This privacy policy sets out how EpiCentre under Elush (T3) Pte Ltd uses and protects any information that you give EpiCentre when you use this website. EpiCentre is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. EpiCentre may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

1. Personal Data

1.1 In this Personal Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from the data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time

1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. 

2. Collection of Personal Data 

2.1 If you are residing in the EU, we are required to disclose the legal basis for processing your data under the GDPR. We will use the Customer Data in the following ways

  • process and assist you with any transactions related to your orders (e.g. making an order, providing services related to the order (e.g. AppleCare registration, Warranty, Purchase Receipt duplicates, etc), and fulfilling such orders);
  • notify you about changes to our services (e.g. delivery, billing, etc.)

As it is in our legitimate interests to be responsive to you, to provide customised services and marketing and to ensure the proper functioning of our products, services and organisation, we will use your Customer Data to:

  • respond to your enquiries, requests or feedback;
  • enforce our terms, conditions and policies;
  • communicate with you;
  • improve the Website and to ensure content from the Website is presented in the most effective manner for you and your device;
  • administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • send you surveys by post or email. You can opt-out receiving these surveys at any time by contacting us, via our Website or our social media pages, or by clicking on the “Unsubscribe” link on an email from us;
  • send you service emails, such as reminders when you have not checked out your purchases on our Website. You can opt-out of receiving service emails at any time by contacting us, via our Website or social media pages, or by clicking on the “Unsubscribe” link on an email from us; 
  • allow you to participate in interactive features of the Website, when you choose to do so;
  • customise our products and services to you, including by responding to and catering for your customer preferences;
  • personalise the content you see on our Website;
  • keep the Website safe and secure;
  • aggregate Customer Data into anonymised statistical data (such as consumer trends for the various products), which we will use for statistical analysis so that we can better understand EpiCentre’s customer profile and improve EpiCentre’s service offering;
  • to customise our marketing (e.g. send you targeted marketing on places you would like to visit, based on your responses to optional questions on our Website and your prior purchases). If you are residing in the EU, you can object to this profiling and opt-out of receiving such targeted marketing.
  • send you marketing and promotional materials in relation to products and services offered by EpiCentre, EpiCentre’s subsidiaries and affiliates and service partners. 
  • if you are an employee of an entity with a contractual relationship with EpiCentre
    • to contact you to perform our services, and in particular, to monitor and record calls for quality, training analysis and other related purposes in order to pursue our legitimate interest to improve service delivery,
    • enforce our terms and conditions against your employer; and
    • communicate with you about products, services, promotions, events and other news and information we think will be of interest to you. 
    • If you are residing in the EU, you can object to this profiling and opt-out of receiving such targeted marketing.

You have the right to withdraw your consent at any time by contacting us, via email or our social media pages. 

2.2 Generally, we collect Personal Data in the following ways:

(a) when you submit an application form or other forms relating to any of our Products and Services (defined below);

(b) when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;

(c) when you use some of our services, for example, websites and apps including establishing any online accounts with us;

(d) when you purchase or obtain third party services through us;

(e) when you request that we contact you, be included in an email or other mailing list;

(f) when you respond to our promotions, initiatives or to any request for additional Personal Data;

(g) when you are contacted by, and respond to, our marketing representatives and customer service officers;

(h) when we receive references from business partners and third parties, for example, where you have been referred by them;

(i) when we seek information from third parties about you in connection with the Products and Services you have applied for; and

(j) when you submit your Personal Data to us for any other reasons.

2.3 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.

2.4 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

2.5 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.

3. Purposes for the Collection, Use and Disclosure of Personal Data

3.1 As EpiCentre is not in the business of selling of Personal Data. Personal Data that EpiCentre collects, may be used and disclosed for the following purposes:

(a) responding to your queries and requests; 

(b) managing the administrative and business operations of EpiCentre and complying with internal policies and procedures;

(c) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

(d) matching any Personal Data held which relates to you for any of the purposes listed herein;

(e) resolving complaints and handling requests and enquiries;

(f) preventing, detecting and investigating crime and analyzing and managing commercial risks;

(g) providing media announcements and responses;

(h) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

(i) organising promotional events;

(j) legal purposes (including but not limited to obtaining legal advice and dispute resolution);

(k) conducting investigations relating to disputes, billing or fraud;

(l) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on - EpiCentre (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and

(m) purposes which are reasonably related to the aforesaid.

3.2 EpiCentre may also collect, use and disclose your Personal Data for the following “Additional Purposes”:

(a) analytics and tracking,

(b) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to EpiCentre's Products and Services, and to improve our service delivery and your customer experience at our touchpoints;

(c) providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from EpiCentre;

(d) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by EpiCentre;

(e) leads generation and management for marketing EpiCentre's Products and Services;

(f) administering contests, competitions and marketing campaigns, and personalising your experience at EpiCentre’s touchpoints;

(g) communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and online marketing);

(h) organising promotional events and corporate social responsibility projects; and

(i) purposes which are reasonably related to the aforesaid. 

3.3 In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for EpiCentre Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by EpiCentre.

(a) EpiCentre may also collect, use and disclose your Personal Data for the following “Preferred Partners Additional Purposes”:

(b) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes with our preferred partners;

(c) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions, loyalty and reward programmes) by our preferred partners;

(d) leads generation and management for marketing the products and services offered by our preferred partners;

(e) administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;

(f) communicating to you advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, (including but not limited to upselling, cross selling and online marketing); and

(g) purposes which are reasonably related to the aforesaid. 

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners' Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by EpiCentre’s preferred partners.

If you have provided your Singapore telephone numbers EpiCentre may contact you using such Singapore telephone numbers (including via voice calls, sms, fax or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts, flash sales and special offers).

In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

When you shop on EpiCentre’s website, we may send you promotional/marketing material via mail along with your order package.

Should you wish to withdraw your consent for us to send you sales, marketing or promotional information via a specific mode, please inform us as follows:

- to withdraw consent from receiving SMS promotions: please unsubscribe by following the steps provided in the promotional SMS;

- to withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;

- to withdraw consent from receiving promotional material with your order package: please email customer service, with the words “PERSONAL DATA” in the subject line, at the address provided below.

Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with EpiCentre.

4. Disclosure of Personal Data

4.1 EpiCentre will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

(a) EpiCentre’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;

(b) companies providing services relating to insurance and consultancy to EpiCentre;

(c) agents, contractors or third party service providers who provide operational services to EpiCentre, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to EpiCentre;

(d) vendors or third party service providers in connection with marketing promotions and services offered by EpiCentre or its preferred partners;

(e) commercial shops and retailers in relation to providing rewards and benefits;

(f) other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;

(g) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;

(h) collection and repossession agencies in relation to the enforcement of repayment obligations for debts;

(i) credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;

(j) external banks, credit card companies and their respective service providers;

(k) our professional advisers such as auditors and lawyers;

(l) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and

(m) any other party to whom you authorise us to disclose your Personal Data to.

5. How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

6. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

7. EU Data Subject Rights

If you are a resident in the EU, you may have certain rights in relation to the Customer Data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.

These rights include:

• The right of access.  

• The right of data portability. 

• The right of rectification. 

• The right of erasure. 

• The right to restrict processing. 

• The right to object. 

Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please submit us an email to epicentresg@elushretail.com

Complaints

In the event that you wish to make a complaint about how we process your Customer Data, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.

Access

You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.

If you require more than one copy of the Customer Data we hold about you, we may charge an administration fee.

We may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person) or where another exemption applies.

Portability

You have the right to receive a subset of the Customer Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Customer Data to another party.

The relevant subset of Customer Data is data that you provide us with your consent (please see here for the types of Customer Data we process on the basis of your consent or for the purposes of performing our contract with you.

If you wish for us to transfer the Customer Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Customer Data or its processing once received by the third party. We also may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person). 

Correction

You have the right to correct any Customer Data held about you that is inaccurate. Please note that whilst we assess whether the Customer Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

To exercise any of your rights, please submit us an email to epicentresg@elushretail.com

Erasure

You may request that we erase the Customer Data we hold about you in the following circumstances:

• you believe that it is no longer necessary for us to hold the Customer Data we hold about you;

•  we are processing the Customer Data we hold about you on the basis of your consent and you wish to withdraw your consent and there is no other ground under which we can process the Customer Data;

• we are processing the Customer Data we hold about you on the basis of our legitimate interest and you object to such processing (please see here for the types of Customer Data we process on that basis. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Customer Data;
• you no longer wish us to use the Customer Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or 
• you believe the Customer Data we hold about you is being unlawfully processed by us.

Also note that you may exercise your right to restrict our processing of the Customer Data whilst we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Customer Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.  Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.

Where you have requested that we erase Customer Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Customer Data or providing links to the Customer Data to erase the Customer Data too.

To exercise any of your rights, please submit us an email to epicentresg@elushretail.com
 

Restriction of Processing to Storage Only

You have a right to require us to stop processing the Customer Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Customer Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

You may request we stop processing and just store the Customer Data we hold about you where:

• you believe the Customer Data is not accurate, for the period it takes for us to verify whether the Customer Data is accurate;

• we wish to erase the Customer Data as the processing we are doing is unlawful but you want us to just store it instead;

• we wish to erase the Customer Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or

• you have objected to us processing Customer Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Customer Data whilst we determine whether there is an overriding interest in us retaining such Customer Data.
 

Objection
 

At any time you have the right to object to our processing of Customer Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Customer Data for that purpose. 
You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below.

You may object where we are processing the Customer Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing. 

Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Customer Data whilst we make the assessment on an overriding interest by indicating this to us via email at epicentresg@elushretail.com

8. How long does EpiCentre keep your data for?

Your data is kept for as long as it is necessary to fulfill the purpose for which it was collected, the legal or business purposes of EpiCentre, or as required by relevant laws. Other than data related to your contract of purchase which we keep for three years in case of a dispute.

9. Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

(a) whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes

(b) if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at epicentresg@elushretail.com

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 2012. A small admin fee may be payable. If you would like a copy of the information held on you please write to epicentresg@elushretail.com.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

10. List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE name

COOKIE Description

CART

The association with your shopping cart.

CATEGORY_INFO

Stores the category info on the page, that allows to display pages more quickly.

COMPARE

The items that you have in the Compare Products list.

CURRENCY

Your preferred currency

CUSTOMER

An encrypted version of your customer id with the store.

CUSTOMER_AUTH

An indicator if you are currently logged into the store.

CUSTOMER_INFO

An encrypted version of the customer group you belong to.

CUSTOMER_SEGMENT_IDS

Stores the Customer Segment ID

EXTERNAL_NO_CACHE

A flag, which indicates whether caching is disabled or not.

FRONTEND

You session ID on the server.

GUEST-VIEW

Allows guests to edit their orders.

LAST_CATEGORY

The last category you visited.

LAST_PRODUCT

The most recent product you have viewed.

NEWMESSAGE

Indicates whether a new message has been received.

NO_CACHE

Indicates whether it is allowed to use cache.

PERSISTENT_SHOPPING_CART

A link to information about your cart and viewing history if you have asked the site.

POLL

The ID of any polls you have recently voted in.

POLLN

Information on what polls you have voted on.

RECENTLYCOMPARED

The items that you have recently compared.

STF

Information on products you have emailed to friends.

STORE

The store view or language you have selected.

USER_ALLOWED_SAVE_COOKIE

Indicates whether a customer allowed to use cookies.

VIEWED_PRODUCT_IDS

The products that you have recently viewed.

WISHLIST

An encrypted list of products added to your Wishlist.

WISHLIST_CNT

The number of items in your Wishlist.