Privacy Policy

1. INTRODUCTION

This Privacy Notice is provided by Sequebb Pte Ltd (a company limited by shares which is incorporated in Singapore and registered with company number 201017758H, whose registered office is at 5 Shenton Way, #10-01 UIC Building, Singapore, 068808 and which trades as ‘SEQUEBB’ and ‘www.sequebb.com/v2023’ (plus such other potential trading names as may be used from time to time, referred to in this Privacy Notice as we, us or our).

We respect your privacy and are committed to protecting your personal data.

This Privacy Notice is intended to inform you as to how we look after your personal data – however you interact with us (including via use of our website(s) and regardless of where you visit any of them from) and to tell you about your privacy rights and how the law protects you.

This Privacy Notice has sought to have been prepared in plain English (and is provided with ‘Headings’ with the aim that you can easily review the specific areas set out below).

2. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how we collect and process your personal data, including any data you may provide through the use of our website(s) (e.g. when you might purchase a product or service, or sign up to any of our newsletter(s), or take part in a competition etc.).

Our website(s) are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Notice (together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you) so that you are fully aware of how and why we are using your data.

This Privacy Notice supplements the other notices and is not intended to override them.

Controller

We are the controller and responsible for your personal data.

We have appointed a data protection officer (‘DPO’). Our DPO is based in Singapore and may be contacted via email. When contacting, please provide as much information as possible that is specific to your enquiry (including geographical or location information where relevant).

Complaints

You have the right to make a complaint at any time to the PDPC in Singapore. We would, however, appreciate the chance to deal with your concerns before you approach the PDPC, so please contact us in the first instance.

So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:

  • Always keep your data safe and private
  • Never sell your data
  • Allow you to manage and review your marketing choices at any time
  • Only collect, manage, transfer and use your data for the purposes set out in this policy
Third-Party Links

Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our website(s), we encourage you to read the Privacy Notice of every website that you visit.

3. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you – which we have grouped together as follows:

  • Identity Data including first name, last name, marital status, title, date of birth and gender
  • Contact Data including billing address, delivery address, email address and telephone number
  • Transaction Data including details about payments to and from you (or a linked business) and other details of products and services that you (or a linked business) have purchased from us
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website(s)
  • Profile Data including your username and password, your interests, preferences, feedback and survey responses
  • Usage Data including information about how you use our website(s), products and services
  • Marketing and Communications Data including your preferences in receiving marketing from us and third parties and your communication preferences

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you – or a linked business – with goods or services).

In such circumstances, we may have to cancel a product or service you – or a linked business – has with us, but we will notify you if this is the case at the time.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, via our website(s) or otherwise.

This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on any of our website(s);
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback

 

Automated technologies or interactions

As you interact with any of our website(s), we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see such cookie policy(ies) as we may maintain (from time to time) for further details. 

Third parties or publicly available sources

We may receive personal data about you from various third parties (and public sources) – such as those as are set out below:

  • Technical Data from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators; and from publicly available sources.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a legal basis for processing your personal data (other than in relation to sending third party direct marketing communications to you via email or electronic text message – where your consent – in appropriate circumstances – may be treated as implicit).

You have the right to withdraw consent to marketing at any time by methods that will be provided in the relevant communication and/or by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so.

We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

To register you – or a linked business – as a new customer(a) Identity
(b) Contact		Performance of a contract with you – or a linked business
To process and deliver your – or a linked business’ order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		(a) Performance of a contract with you – or a linked business
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you – or a linked business – which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		(a) Performance of a contract with you – or a linked business
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications		(a) Performance of a contract with you – or a linked business
(b) Necessary for our legitimate interests (to study how customers use our products / services, to develop them and grow our business)
To administer and protect our business and our website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical		(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical		Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website(s), products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage		Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website(s) updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you – or a linked business(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile		Necessary for our legitimate interests (to develop our products / services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  We may establish a privacy centre where you can view and make certain decisions about your personal data use or the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you – or a linked business. This is how we decide which products, services and offers may be relevant for you – or a linked business (we call this marketing).

You may receive marketing communications from us if you – or a linked business – have requested information from us or purchased goods or services from us (or if you provided us with your details when you entered a competition or registered for a promotion) and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any other company (outside of our group of companies) for marketing purposes.

Opting out

You can ask us (or third parties) to stop sending you marketing messages at any time:

  • by accessing any privacy centre accessible from our website(s) and checking or unchecking relevant boxes to adjust your marketing preferences; or
  • by following the opt-out links on any marketing message sent to you; or
  • by contacting us (at any time).

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all (or some) browser cookies, or to alert you when websites set or access cookies.

If you disable or refuse cookies, please note that some parts of our website(s) may become inaccessible or not function properly.

How we use cookies

Some cookies are needed to run the website. For example, when you log in, cookies help to recognise you and keep you logged in as you browse the website. We call these strictly necessary cookies.

We also use the following types of cookies:

  • Necessary cookies – We need to use these cookies to make our website work, for example, so you can get promotions awarded to your account.
  • Analytics and advertising cookies – These allow us to recognise and count the number of visitors to our website, and see how visitors browse our website, so we can improve it where necessary. These also allow us to see what pages and links you have visited so we can provide more relevant content. We may share this information with other organisations, such as Google, Facebook and LinkedIn, for the same purpose.

These cookies are all session cookies, which means that they will stop tracking your activity on the website when you close your website browser.

Please note, other organisations, such as advertising networks, may also use cookies to track you across different websites. We have no control over these cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

  • Internal Third Parties 
  • External Third Parties 
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets
  • Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. STORAGE SECURITY & INTERNATIONAL TRANSFERS

The data that we collect from you may be transferred to, processed, and stored at, a destination outside Singapore. Your data also may be processed outside Singapore in order for us to fulfil our contract with you to provide the Sequebb Services.

We will need to process your personal data in order for us to action a request made by you. We will take all steps to ensure that your data is treated securely and in accordance with the PDPA.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our app and/or our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app or our website; any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach (where we are legally required to do so).

9. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least six (6) years after they cease being customers (for tax purposes).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes – in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a 'data subject access request').

This enables you to receive a copy of the personal data we hold about you. If you require this, then please contact us.

Please note that Singapore law allows us to refuse your request for access for various reasons, including where the burden or expense of providing such access would be unreasonable to us or disproportionate to your interests.

Request correction of the personal data that we hold about you.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please contact us.

Please note that Singapore law allows us to refuse your request for correction for various reasons, including where your personal data is contained in a document that is related to a prosecution if all proceedings related to the prosecution have not been completed.

Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data.

You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling grounds to process your information which override your rights.

Request restriction of processing of your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it; or
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including Sequebb Services). In this case, we may have to cancel your use of Sequebb Services but we will notify you if this is the case at the time.

Request the transfer of your personal data to you or to a third party.

We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party.

Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please contact us.

Withdraw consent at any time where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Sequebb Services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you fail to provide personal data.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Sequebb Services). In this case, we may have to cancel your use of the Sequebb Services but we will notify you if this is the case at the time.

Changes to privacy policy.

Any changes we may make to our privacy policy in the future will be posted on this page. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services.

11. CONTACT

If there are any questions regarding this privacy policy, you may contact us using the information below.

info@sequebb.com

5 Shenton Way, #10-01 UIC Building, Singapore, 068808

©2023 SEQUEBB Pte Ltd. All rights reserved.

Enquire Now

To learn how we look after your data please see our privacy notice.

Terms & Conditions

These Terms & Conditions apply to any and all use of the website. Any act of accessing or using the Site, including submitting any user content shall constitute your agreement to be bound by and comply with these Terms.

  1. Definitions

    In these terms and conditions, the following definitions have the following meanings: ‘Content’ means all text, images, footage, related data or other material included or presented on the Site. ‘IPR’: all patents, trade marks, service marks, copyright, design rights, database rights, know-how, processes, trade practices and other intellectual property rights whatsoever, whether registered or unregistered anywhere in the world; ‘Site’: the Sequebb Pte Ltd web site at www.sequebb.com/v2023 and any of the sub-domains thereof; ‘User Content’: all text, images, footage, related data or other material that has been input, uploaded or otherwise communicated by you to the Site or to us including by way of selecting items to be linked to the Site. ‘we’, ‘us’, ‘our’, ‘Sequebb’: Sequebb Pte Ltd, (registered company number 201017758H) whose registered office is 5 Shenton Way, #10-01, UIC Building, Singapore 068808. ‘you’, ‘your’, ‘yourself’: any user of the Site.

  2. Your Information
    1. In order to use certain parts of the Site it is necessary for you to provide certain information with us such as your name and email address.
    2. You must ensure that all information submitted by you is complete and accurate.
    3. We will use all information you provide in accordance with our Privacy Policy which is available on the Site.
  3. General Use of the Site
    1. You warrant and undertake that you shall not, and shall not permit others to:
      1. modify, translate, create derivative copies of or copy any aspect of the Site;
      2. reverse engineer, decompile, disassemble or otherwise tamper with any material on the Site;
      3. distribute, sub-license, assign, share, timeshare, sell, rent, lease, grant a security interest in or otherwise transfer any of your rights to use the Site; or
      4. use the Site in any manner not expressly authorised or envisioned or in a way which may bring us into disrepute.
  4. Intellectual Property Rights
    1. All IPR in the Site, Content and all material, content, information or benefits relating to the same, is owned or licensed by us and nothing in these terms and conditions shall confer any ownership of any IPR in the same on you.
    2. You agree to use all Content made available to you for the purpose of viewing such Content on the Site personally only and not to copy, adapt, make available to third parties or distribute any such Content.
  5. User Content and Use of the Site
    1. You grant to us a world-wide, royalty-free, irrevocable, non exclusive licence (including the right to sub-license) to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform and display any User Content (in whole or part) and/or to incorporate such content in other works in any form, media or technology now known or developed.
    2. You agree not to upload, post or otherwise make available on the Site any material protected by confidence, copyright, trademark or other proprietary right without the express permission of the owner of the confidential information, copyright, trademark or other proprietary right or use the Site for any other illegal purpose and the burden of determining that any material is not protected by such rights or that such permission has been obtained rests with you.
    3. You agree that you shall be solely liable for any damage resulting from any breach of confidence or infringement of copyrights, proprietary rights, or any other harm resulting from submission of User Content and agree to indemnify us and keep us indemnified against any damage, harm or loss resulting from such a submission.
    4. You agree to not submit any User Content that is racist, sexist, ageist, obscene or otherwise offensive or to submit User Content in such a way as is intended or likely to disrupt any user’s use or viewing of any part of the Site.
  6. User Content and Use of the Site
    1. You acknowledge that the following provision reflects a fair allocation of risk. These terms and conditions set out our entire liability to you and all other liability of us to you and all warranties relating to the Site or the Content is hereby excluded, subject that nothing shall exclude or restrict our liability for fraudulent misrepresentation and/or for death or personal injury (including but not limited to sickness and death) to the extent that such injury results from our negligence or wilful default, or that of our servants, agents or subcontractors.
    2. In no event shall we be liable to you whether in contract, tort, by statute or otherwise in respect of any loss of profits and/or for any special, indirect, incidental or consequential loss or damage arising out of or in connection with the Site or the Content, including without limitation: loss of revenue, loss of anticipated savings, loss of business and/or goods, loss of goodwill, loss of use, loss and/or corruption of data and/or other information or benefits. For the avoidance of doubt, neither the types of loss and/or damage specified above nor any similar types of loss and/or damage shall constitute direct loss for the purposes of this Agreement.
    3. You agree that we shall not be liable for any loss or damage caused by your reliance on the accuracy or truth of any Content.
  7. Restrictions of the Internet
    1. You acknowledge that:
      1. we have no control over the Internet which is a global decentralised network of computer systems. Accordingly, access to the Site shall not be error free or uninterrupted and may be variable; and
      2. information, benefits and other material accessible over the Internet, including via the Site may contain computer viruses, worms, Trojan horses, cancelbots, or other harmful and destructive components. We are not liable and will not be liable for any direct, indirect, incidental or other loss or damages which result or may result from your access to or use of the Internet. We strongly recommend that you maintain sufficient and updated anti-virus benefits on any hardware used to access the Site and/or access material on the Site.
  8. Governing Law

    These terms and conditions shall be interpreted, governed by and construed in accordance with Singapore law and the parties shall submit to the exclusive jurisdiction of the Singapore courts.

Privacy Policy

Sequebb Pte Ltd fully understands the inherent responsibility of ‘entities handling personal information’ to protect personal information of all people including customers and suppliers who provide personal information to Sequebb Pte Ltd (hereinafter such information is referred to as ‘personal information’ and each of such persons is referred to as ‘the person’). Therefore, Sequebb Pte Ltd has established specific policies on handling personal information as stated below, and thus will make every effort to protect personal information.

  1. Acquisition of Personal InformationWhenever Sequebb Pte Ltd asks a person to provide his/her personal information, we specify in advance the purpose for which the personal information will be used (hereinafter referred to as ‘purpose of use’).

    In the following cases, however, we may omit specifying the purpose of use:

    • When personal information is provided in a business meeting or in the exchange of business cards
    • When personal information is provided on business cards at events, fairs, or seminars etc

    In these cases, Sequebb Pte Ltd may use personal information for introducing products and services as well as providing various information by e-mail, and marketing activities including face-to-face marketing, except when the person rejects those activities.

  2. Management of Personal Information

    In order to prevent leakage, alteration, loss, or use for anything other than the purpose of use, Sequebb Pte Ltd manages personal information strictly in a safe environment under strict security according to related laws, guidelines, and internal regulations.

    As for the proper handling of personal information, Sequebb Pte Ltd executes necessary education and enlightenment to employees

  3. Use of Personal Information

    Sequebb Pte Ltd does not use personal information for anything other than the purpose of use, except under one or more of the following conditions:

    • When the person has given his/her consent
    • When personal information is used in a manner whereby the person cannot be identified (e.g. statistical data)
    • When use for other than purpose of use is authorised by related laws or guidelines
  4. Disclosure of Personal Information to Third Parties

    Sequebb Pte Ltd does not disclose personal information to any third parties except under one or more of the following conditions:

    • When the person has given his/her consent
    • When personal information is disclosed in a manner whereby the person cannot be identified (e.g. statistical data)
    • When personal information is disclosed to Sequebb Pte Ltd dealers or affiliates etc. that have been obligated to preserve confidentiality to Sequebb Pte Ltd (hereinafter referred to as “the business partner”) within the scope necessary to perform the purpose of use
    • When Sequebb Pte Ltd deems it appropriate for the person’s inquiries or request of some materials to be answered or supported by the business partner and personal information is disclosed to such the business partner
    • When it is necessary for the settlement of payment for products purchased or services provided to disclose personal information to financial institutions etc. (This is for verifying the accuracy of bank account information or the validity of credit cards)
    • When a part of the business operations of Sequebb Pte Ltd is succeeded to other company; (Sequebb Pte Ltd will make every possible effort so that the successor shall not leak personal information as well as not use personal information for other than the purposes of use)
    • When disclosure to third parties is authorised by related laws or guidelines
    • When a judicial or administrative organisation has ordered the disclosure or provision of personal information according to laws or ordinances
    • When personal information is disclosed or shared between Sequebb Pte Ltd and its subsidiaries or between the subsidiaries within the scope necessary to perform the purposes of use
  5. Enquiries of Personal Information

    A person who wishes to access, alter, or correct his/her own personal information should contact the section or staff in Sequebb Pte Ltd to whom the person has provided their personal information (contact information site that is displayed on the Web site through which personal information has been provided). Sequebb Pte Ltd will then respond to the person’s request in a timely manner according to prescribed procedures.

    In those cases, in order to prevent unlawful acquisition or alteration of personal information by third parties, Sequebb Pte Ltd will confirm whether the request is really done by the person himself/herself.

  6. Handling of Your Advice and Requests

    As for advice, requests and proposals sent to Sequebb Pte Ltd from the users, Sequebb Pte Ltd can freely use them unless the purpose of use is specifically restricted.

    However, Sequebb Pte Ltd will acquire the person’s consent when personal information is disclosed to the public or to third parties in a manner whereby the person who has provided it can be identified

  7. Handling of Personal Information on the Website
    1. Use of Cookies, Web Beacons and IP Address

      Sequebb Pte Ltd may use Cookies, Web beacons, or IP addresses recorded on the Web site that is operated by Sequebb Pte Ltd for the following purposes:

      • To identify the causes of problems arising at Web servers and to resolve these problems
      • To improve the contents of Web sites and e-mail
      • To customise the contents of Web sites and e-mail for the user’s individual interest or purpose
      • To use browsing history by the person and the results of questionnaires for marketing by Sequebb Pte Ltd in the service for membership system where personal information of the person has been registered in advance
      • To obtain aggregated site visitation statistics whereby the individual person cannot be identified
      • The person can reject use of Cookies and Web beacons by Sequebb Pte Ltd by configuring the Internet browsing software (hereinafter referred to as “browser”) to reject the acquisition of Cookies.
      • In this case, however, some restrictions may occur by which some functions such as customisation cannot be used.
    2. SSL (Secure Sockets Layer)

      Sequebb Pte Ltd will use encryption by SSL (Secure Sockets Layer) or other security technologies to prevent tapping into the communication process by third parties when the person provides his/her personal information through Web sites operated by Sequebb Pte Ltd.

      However, these technologies may not be used in some rare cases because of the person’s computer environment. In these cases, Sequebb Pte Ltd will display on the Web site that security cannot be ensured in the communication process.

    3. Respective Usage Contract

      When extra provisions different from those of this Privacy Policy are settled on through a usage contract of Web sites operated by Sequebb Pte Ltd, Sequebb Pte Ltd will preferentially apply said usage contract.

    4. Linked Sites From Sequebb Pte Ltd Sites

      Sequebb Pte Ltd Web sites may include links to Web sites outside Sequebb Pte Ltd. Although Sequebb Pte Ltd pays full attention to the selection of the linked sites, we cannot assume responsibility for protection of personal information or contents on those Web sites outside Sequebb Pte Ltd.

  8. Compliance with Laws and Regulations

    Sequebb Pte Ltd strictly observes all local laws and internal regulations that are applicable related to personal information. Sequebb Pte Ltd will occasionally revise this Privacy Policy in accordance with revisions of related laws, policies and guidelines, or our internal rules. Therefore, we recommend that you periodically confirm the updated contents of this Privacy Policy.

Note 1: “Subsidiary” means the company, for which Sequebb Pte Ltd holds the majority of voting rights directly or indirectly

Note 2: “Personal information” means information concerning individuals such as name, age, birth date, gender, address, phone number, mailing address, place of employment, number of credit card and information for which the individual specified can be identified by one item or a combination of two or more of items as described above

Note 3: “Cookie” is identification information that is transmitted to the person’s browser by servers and is preserved on the browser side for effective operations of Web sites

Note 4: “Web beacon” is technology to acquire aggregated site visitation statistics of access to the specified Web pages using cookies

Note 5: “IP address” is a number that can specify the computer accessing the servers. (User of computer cannot be specified)

Note 6: Some Web sites operated by Sequebb Pte Ltd may not support SSL by restrictions of systems or other reasons

In these cases, Sequebb Pte Ltd may display on such Websites, where the security cannot be preserved in the communication process.

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