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GLOBAL WELLNESS GROUP PTE LTD PRIVACY POLICY

This Privacy Policy (the “Policy”) applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from goods and/or services offered by Global Wellness Group Pte Ltd (“GWG”).

In addition to this Policy statement, there may also be specific and additional privacy provisions, which apply to our collection and use of your personal information e.g. information provided when entering a competition, subscribing to a newsletter, or participating in a survey. If there is any inconsistency between this Privacy Policy Statement and those specific and additional provisions, the specific and additional provisions will prevail.

  1. General
    1.1 This Policy statement provides information on the obligations and policies of GWG in respect of an individual customer’s Personal Data. GWG undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations. Please take a moment to read this Privacy Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
    1.2 GWG’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, GWG. GWG shall use reasonable endeavours to ensure all collection and/or storage and/or disclosure and/or usage of Personal Data by GWG and by anyone acting on its behalf shall be done in an appropriate manner and in accordance to the Act and this Policy.
    1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to GWG as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “GWG”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to GWG’s authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.
    1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
    1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified —from that data; or from that data and other information to which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of GWG or that which shall be collected by the GWG in the future.
  2. Contacting the Data Protection Officer
    2.1 Where you: (i) legitimately request access to Personal Data relating to you which is in the possession and control of GWG; (ii) have any questions or feedback relating to your Personal Data or This Policy; or (iii) or wish to correct Personal Data relating to you which is in the possession and control of GWG, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated hereinafter. We shall attain to your request a reasonable time and manner.
    2.2 In accordance with the Act, GWG has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that GWG receives your complaints and enquiries, please send the same via email to the DPO at the following email address: DPO@gwg.com.sg
    2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member who has nominated you to receive complimentary services), you should contact that third party to make such queries, complaints, and access and correction requests to GWG on your behalf.
    2.4 Should you not wish GWG to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from GWG, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time. However, please note that in such an event we may not be in a position to continue to provide our products or services to you, administer any contractual relationship in place, and this may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
  3. Statement of Practices
    Types of Personal Data Collected:
    3.1 As part of its day to day activities, GWG may collect from you, through various means, including:

    a) When you register for GWG’s trial services through our websites, our affiliates’ websites, mobile applications, marketing events, advertising and promotions or roadshows;
    b) When you reserve and/or confirm appointments at our Centre;
    c) When you participate in any of our surveys, contests and Loyalty Program;
    d) When you are attended by our consultants who carry out facial / body treatment consultations with you;
    e) When you are served by our consultant / therapist in the course of treatment, including pre and post treatment;
    f) When you purchase your treatment packages and join our membership;
    g) When you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, promotions and other initiatives;
    h) When you are contacted by, and respond to, our marketing representatives and agents;
    i) And when you submit your Personal Data to us for any other reasons.
    3.2 The type of your Personal Data that we collect may include your

    • Name (first and surname);
    • Address
    • Postal Code
    • NRIC/FIN Number
    • Phone Number
    • Email Address
    • Passport Number
    • Date of Birth/Age
    • Race
    • Gender
    • Marital Status / No of Children
    • Occupation
    • Purchase History
    • Product / Service Preferences
    • Health / Medical Information
    • Medical / Skin Conditions
    • Weight
    • Height
    • Video (CCTV)
    • Salary
    • Biometrics (Thumbprint)
    3.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, friends or others), including where you have named them as beneficiaries of our services, or where you refer a third party to us for the purposes of us offering our products and/or services to that third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.Cookies
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    Purpose of Collection of Personal Data
    3.4 The above Personal Data mentioned in Clause 3.2 is collected for the purposes of:

    • Ensuring clients are eligible for discounts, privileges or benefits or other related purposes;
    • To process your purchase of treatment packages and registration of your membership;
    • To enable a suitable treatment for you, taking into consideration of your preference, and existing conditions (such as allergies, if any);
    • To conduct market research and analysis;
    • For direct marketing through voice calls, text messages, email, direct mail and facsimile messages;
    • For payment of purchased products and services;
    • For customer services (including appointment booking) and relationship management;
    • For identification and office access control;
    • To respond to complaints, queries and feedback;
    • To notify you of any changes to our policies or services which may affect you;
    • For maintenance and update of your membership details; and
    • Informing you of new developments, services, promotions of GWG and other third parties which we are associated with.
    Disclosure of Personal Data
    3.5 In order to carry out the functions described above, we may, from time to time, disclose your Personal Data between other companies affiliated with GWG.
    3.6 Without derogating from any of the above, we may also disclose your Personal Data to the following third parties:

    • Pay-roll Processing Services;
    • Regulators and law enforcement officials;
    • Call Centres;
    • Third party service providers and consultants;
    • Survey / Content Gift Suppliers;
    • Credit, debit and charge card companies, banks and other entities processing payment;
    • Potential buyers or investors of GWG or any of GWG’s companies; and
    • Any agent or subcontractor acting on GWG’s behalf for the provision of GWG’s services.
    3.7 GWG may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:

    • To the extent that we is required to do so by the law;
    • In connection with any legal proceedings or prospective legal proceedings;
    • To establish, exercise or defend our legal rights;
    • To the purchaser (or prospective purchaser) of any business or asset which we are (or we are contemplating) selling;
    • To any person and/or entity for the purpose of processing such information on the our behalf;
    • To third parties who provide services to us or on its behalf; and
    • With your consent
    Optional Provision of Personal Data
    3.8 Except where otherwise indicated, collection fields in our various collection avenues are optional and by providing us with that information, it shall be deemed to have been voluntarily provided. In that regard, if you should feel that any of the compulsory fields are excessive or irrelevant to the services provided, feel free to engage any of our personnel. We will consider your feedback and do our best to accede to your request.
    3.9 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve our products and services to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:

    • Your age;
    • Gender;
    • Race;
    • Occupation; and
    • Your medical history
    3.10 Under certain circumstances, telephone calls made to us to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
  4. Personal Data You Provide on Behalf of Another Person
    If you are entering Personal Data on behalf of another person, you warrant to us that you are authorised by that person to enter their Personal Data onto our system, and that the provided information is accurate and correct. In addition you hereby confirm that the person for whom you act is agreeable with the terms of this Policy. You agree to inform us if the referred person withdraws their consent to the collection, use, or disclosure of their personal data. If any non-compliance by you with respect to this provision results in any loss or damage being incurred by us, you may be required to compensate us in respect of such loss.
  5. Accuracy of Personal Data
    Where possible, we will validate data provided using generally accepted practices and guidelines. To assist in ensuring the accuracy of your Personal Data in our possession, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
  6. Protection of Personal Data
    GWG uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside GWG, other than to you or as described in this Policy. However, we cannot ensure or warrant the security of any information you transmit to us and you do so entirely at your own risk. In particular, GWG does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of our physical, technical, or managerial safeguards.
  7. Access and Correction of Personal Data
    7.1 In accordance with Clause 2.1 of this Policy, you have the right to:

    a) check whether we hold any Personal Data relating to you and, if so, obtain copies of such data; and
    b) require us to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used
    7.2 We reserve the right to charge a reasonable administrative fee in order to meet your requests under Clause 8.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
    7.3 If you wish to verify the details you have submitted to us or if you wish to check on the manner in which we use and process your personal data, our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and NRIC or Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which we take in response to a request from someone using your details.
  8. Storage and Retention of Personal Data
    GWG will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of GWG and where the Personal Data is deleted from our electronic, manual, and other filing systems in accordance with our internal procedures and/or other agreements.
  9. Contacting you
    To the extent that any of the communication means which you have provided us with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy, by any means of indication, you hereby grant GWG your clear and unambiguous consent to contact you using all of your communication means you have provided to us including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraphs 3.4 and 3.5. This will ensure your continued enjoyment our promotional rates and services.
  10. Change Policy
    GWG reserve the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by GWG. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
  11. Governing Law
    This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
  12. Miscellaneous
    12.1 This Policy only applies to the collection and use of Personal Data by GWG. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. GWG does not share your Personal Data with third party websites. GWG is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
    12.2 GWG will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to GWG’ website.
    12.3 GWG’ websites do not target and are not intended to attract children under the age of 21 years old. GWG does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.

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