DOWNLOAD APPPRIVACY POLICY
This policy:
・ sets out the principles and practices Hot Palette (Asia Pacific) Pte. Ltd. (“Hot Palette”)
follows when collecting, using, disclosing, retaining and removing personal
data; and
・ describes other important topics relating to an individual’s privacy.
By sales transactions with Hot Palette, by communicating with Hot Palette through email, on telephone, in writing or via any of Hot Palette’s other services including the Hot Palette website or otherwise by providing personal data to us, you agree to the collection, use and disclosure of your personal data described in this policy.
The type of personal data that Hot Palette may collect from individuals will depend upon the particular transaction and the dealing. Normally the personal data of an individual collected by Hot Palette may include that individual’s:
・ Name, title, address;
・ NRIC/FIN/Passport number;
・ Telephone Number;
・ Email address;
・ Records of communications with Hot Palette;
・ Responses to surveys and contests conducted by Hot Palette or on its behalf;
・ Credit card or debit card information;
・ Camera or video footage that identifies individuals (including CCTV footage); and/or
・ Website usage information.
Hot Palette only collects, uses and discloses personal data of an individual with the individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.
An individual’s personal data will, generally, only be collected and used for the primary purposes (“Primary Purposes“) of :
・ conducting, improving, maintaining and developing the individual’s business relationship with Hot Palette;
・ processing, servicing or enforcing transactions with the individual and sending related communications;
・ identification and verification purposes in connection with any of the services or products that may be supplied to the individual;
・ responding to the individual’s queries;
・ administering contests or market surveys conducted by Hot Palette or on its behalf;
・ marketing (such as providing individuals with information about our products and promotional notices and offers);
・ improving Hot Palette’s website;
・ carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by Hot Palette;
・ investigating fraud, misconduct, any unlawful action or omission, whether relating to the individual’s relationship with Hot Palette or any other matter arising from the individual’s relationship with Hot Palette, and whether or not there is any suspicion of the aforementioned;
・ storing, hosting, backing up (whether for disaster recovery or otherwise) of the individual’s personal data, whether within or outside Singapore; and
・complying with applicable law in administering and managing the individual’s relationship with Hot Palette.
Hot Palette takes reasonable steps to ensure an individual is aware of:
・ the likely use of the individual’s personal data;
・ the means of requesting Hot Palette on the provision of the individual’s personal data that is in the possession of Hot Palette;
・ the means of withdrawing any consent in respect of the collection of the individual’s personal data or use or disclosure thereof that is in the possession of Hot Palette;
・ the identity and contact details of the organisation to whom the individual’s personal data is disclosed;
・ any law requiring collection, use or disclosure of the individual’s personal data; and
・ the main consequences of the individual’s failure to provide personal data to Hot Palette.
You directly provide Hot Palette with most of the data we collect. We collect and process data when you:
• sign up for our newsletter through our website;
• submit a franchise application through our website;
• send us an email enquiry to our email addresses;
• order our food through third-party delivery services we work with, such as Deliveroo, GrabFood and Food Panda; and
• use or view our website via your browser’s cookies.
By using the Hot Palette website, you are consenting to us collecting any data we receive either expressly or indirectly.
Hot Palette discloses personal data of an individual:
・ for one or more of the above Primary Purposes for which it was collected;
・ for purposes that a reasonable person would consider appropriate in the circumstances;
・ where the individual has provided prior consent;
・ for direct marketing by Hot Palette where consent has been given provided that Hot Palette gives the individual an opportunity to opt out of such direct marketing; or
・ where permitted under the PDPA or other applicable law or if required by law.
In order to conduct our business operations more smoothly, Hot Palette may also be disclosing the personal data you have provided to Hot Palette to third party service providers, agents and/or affiliates or related corporations of Hot Palette, which may be sited outside of Singapore, for one or more of the above-stated Primary Purposes. This is because such third party service providers, agents and/or affiliates or related corporations would be processing your personal data on behalf of HOT PALETTE for one or more of the above-stated Primary Purposes.
HOT PALETTE does not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or other applicable laws and regulations. Please note that HOT PALETTE may disclose your personal data to third parties without first obtaining your consent in certain situations that are listed in the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://sso.agc.gov.sg. In all other instances of disclosure of personal data to third parties with your express consent, HOT PALETTE will endeavour to provide adequate supervision over the handling and administration of your personal data by such third parties, as well as to provide for adequate forms of protection over such personal data.
HOT PALETTE takes reasonable steps to ensure information is accurate and up-to-date by updating its records whenever changes come to its attention. HOT PALETTE disregards information which, on a reasonable basis, is inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.
If an individual has submitted personal data to HOT PALETTE electronically or otherwise, and would like it corrected, a written request should be sent by email to HOT PALETTE’s Data Protection Officer at [email protected] or to the address below.
HOT PALETTE will comply with an individual’s request to correct their personal data as soon as practicable. HOT PALETTE will also send the corrected personal data to every other organisation to which the personal data was disclosed by HOT PALETTE within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose. Notwithstanding the foregoing, HOT PALETTE may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by HOT PALETTE within a year before the date the correction was made.
If HOT PALETTE disagrees with any request to correct an individual’s personal data on reasonable grounds, HOT PALETTE shall annotate the personal data with the correction that was requested but not made.
An individual may withdraw his or her consent for the collection, use or disclosure of personal data by giving HOT PALETTE reasonable notice by sending a written request by email to the Data Protection Officer at [email protected] or to the address below. HOT PALETTE shall inform the individual of the likely consequences of the withdrawal of the consent. HOT PALETTE will cease to collect, use or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulations.
7. Using our WebsiteAs with most websites, when you visit or use an application on HOT PALETTE’s websites, HOT PALETTE may record anonymous information such as IP address (not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, type of browser and operating system.
HOT PALETTE’s websites also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use HOT PALETTE’s websites, but may be limited in the usage of some of its features.
HOT PALETTE will take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that personal data is securely stored. Appropriate security arrangements will be taken to prevent misuse or loss of your personal data. However, HOT PALETTE cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond HOT PALETTE’s control.
9. Retention and Removal of your Personal DataHOT PALETTE will also take commercially reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer served by the retention; and (ii) retention of the personal data is no longer necessary for any other legal or business purposes. Any data removed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.
10. Dealing with Unsolicited InformationHOT PALETTE takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.
11. Access to Personal DataIf an individual wishes to be provided with information regarding his or her personal data that is in the possession or under the control of HOT PALETTE or the ways in which such personal data has been used or disclosed by HOT PALETTE in the year preceding such request, the individual needs to send a written request by email to the Data Protection Officer at [email protected] or to the address below. HOT PALETTE will handle such requests as soon as reasonably possible in accordance with the PDPA.
Depending on the nature of the work required to process your access request, HOT PALETTE may be required to charge you a reasonable fee for the handling and processing of your requests to access your personal data to recover administrative costs. HOT PALETTE’s Data Protection Officer will determine whether such a fee should be imposed on a case-by-case basis. Where such a fee is to be imposed, HOT PALETTE will provide you with a written estimate of the fee for your consideration. HOT PALETTE will only begin processing your access request upon receiving your agreement to the payment of the fee.
HOT PALETTE allows individuals the option to not identify themselves when dealing with it, where practical.
13. Cross Border DisclosureAny personal data provided to HOT PALETTE may be transferred to, stored by or disclosed to an overseas recipient. For example, HOT PALETTE may use a server hosted overseas to store data, which may include your personal data. Where personal data is transferred to HOT PALETTE’s affiliates outside of Singapore, HOT PALETTE will ensure that suitable binding corporate rules are put in place to ensure that HOT PALETTE’s affiliates provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA. Where personal data is transferred to other third parties outside of Singapore, HOT PALETTE will ensure that suitable contracts between HOT PALETTE and the third parties are put in place to ensure that such third parties provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
14. Sensitive InformationHOT PALETTE does not collect sensitive information without the individual’s consent and unless collection of such information is specifically relevant and necessary for the Primary Purposes described in Article 2 of this policy or otherwise permitted or required by the PDPA or other applicable laws. All sensitive information is collected and used in accordance with this policy. We use partial NRIC/FIN for promotional campaigns to identify individuals.
15. Forwarding of personal data to third partiesHOT PALETTE processes personal data collected, and may forward the data collected to the agency commissioned to run the website as well as to the technical service provider.
Your personal data may also be shared with the social media plug-ins on the HOT PALETTE website, namely Facebook, Instagram, Twitter, Tiktok and YouTube.
By clicking on the social media buttons, you establish direct contact with the social network and expressly consent to sharing information such as your IP address and/or browser behaviour with the respective social media site.
Further information pertaining to the purpose and the scope of data collection and processing by the respective social media site can be found on their respective privacy policies via their websites.
HOT PALETTE complies with all provisions regarding the DNC Registry under the PDPA.
17. Other Important InformationHOT PALETTE reserves the right to modify this policy at any time. A current version of this policy will be published on HOT PALETTE’s website or may be obtained free of charge upon request.
18. Privacy policy of other websitesThe HOT PALETTE website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
19. Changes to our privacy policyHOT PALETTE keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on [16 August 2019].
20. Further InformationIf you have any queries or concerns about HOT PALETTE’s personal data protection policies and practices, please contact:
Data Protection Officer
1 Coleman Street, #10-08/09 The Adelphi, 179803
Email: [email protected]
