Privacy policy
Last updated: September 6, 2024
This Frozen Beauty (FB) Personal Data Policy ("PD Policy") sets out how Legacy Solution LLP (LS) (UEN: T16LL0008H and its associated individuals/organizations (collectively,”LS”, "FB", "us", "our") collect, use, disclose and retain your personal data. Frozen Beauty is a trademarked brand registered by Legacy Solution LLP.
By accessing www.frozenbeauty.com.sg you agree to be bound by these Terms of Use and the Frozen Beauty Privacy Policy.
We are committed to safeguarding your privacy rights and ensuring that your personal data is protected.
This Privacy Policy explains the types of personal data we collect and how we process and protect that data in connection with the services we offer. This includes information collected offline in our stores or through our customer services, and online through our websites, applications (including mobile apps) and Third-Party platforms (together referred to as “Sites”).
This Privacy Policy also applies to our targeted or personalised content, including online offers and advertisements for products and services, which you may see on Third-Party websites, platforms, and applications (together referred to as “Third-Party Sites”). These Third-Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third-Party Sites.
1. WHO IS RESPONSIBLE FOR WHAT HAPPENS WITH YOUR DATA?
Legacy Solution LLP (LS) is responsible for processing your personal data on our Sites. Data collected from Frozen beauty website is solely used for Frozen Beauty (FB) businesses activities.
2. WHAT IS PERSONAL DATA?
Personal Data generally refers to information that can directly or indirectly identify you ("Personal Data"). This typically includes information such as your name, address, email address, and telephone number, but can also include other information such as IP address, shopping habits, information about health and beauty, information about your lifestyle or preferences such as your hobbies and interests. Information about health is called “special categories of Personal Data” that require special protection because of their sensitivity.
3. WHAT HAPPENS WHEN YOU PROVIDE US WITH YOUR PERSONAL DATA OR WHEN WE OTHERWISE RECEIVE YOUR PERSONAL DATA?
We collect your Personal Data directly in a number of ways, for example, when you provide us with your information to register as a customer on our Sites or as a member of our loyalty program, register for prize draws, games or competitions, subscribe to our newsletters, receive information or mailings, use our applications, buy a product or service from us, complete a survey, complete a beauty or health diagnostic test, make a comment or enquiry or contact our customer services.
When you provide us with your Personal Data, we will process it in accordance with this Privacy Policy. If you do not wish us to process your Personal Data in this way, please do not provide us with your personal information.
We may also receive your Personal Data from other sources, including information passively received from available sources such as operators of any Third-Party platforms and Third-Party Sites as referred above and information from Our Partners (as defined in Section 6.1 below). If you do not want us to receive your Personal Data from other sources, please communicate your preferences directly with the relevant sources.
We process your Personal Data to provide you with our services as further explained below. In certain instances, we will only process your Personal Data if you have given us permission, with your consent or indication of no objection to do so, for example where we process your Personal Data for direct marketing purposes, use Cookies (as defined in Section 5.3 below) or location data or where we process your sensitive personal information, or when we process your Personal Data for any new purposes (if any) that are outside of the scope of the purposes set out in this Privacy Policy. In other instances, we may rely on other legal grounds for processing your personal data, such as performance of the contract with you or legitimate interests, like fraud prevention.
If you become a member of our loyalty program, you may still receive service notices or non-direct marketing communications about the program despite you have opted out of receiving direct marketing communications from us without detriment to your loyalty benefits.
Where we process your Personal Data on the basis of your consent or indication of no objection, we will ask for your consent or indication explicitly and only for a particular purpose.
Please refer to Section 5 of this Privacy Policy for details of the various types of Personal Data we may collect, the relevant purposes and the legal basis for such processing.
4. WHAT HAPPENS IF OUR CUSTOMER IS A CHILD?
Our Sites are intended for adults, but there could be instances where some customers under the age of 18 view or purchase products on our Sites. If we know that a customer is under the age of 18, we will not use such customer’s Personal Data for direct marketing purposes unless parental or guardian consent is provided to us.
To provide parental consent to marketing, please ask your parent or guardian to call or write to Frozen Beauty contact details as listed in Section 12 (applicable to loyalty card or online account members only).
Note however that access to certain parts of our Sites and/or eligibility to receive prizes, samples or other rewards may be limited to users over a certain age. We may use your Personal Data to carry out age verification checks and enforce any such age restrictions.
5.1 We process the following categories of Personal Data for the following purposes:
Browsing on our Sites
Purchasing products / Agreeing to a Service
Loyalty Program
Customer Service
Online Shopping
Competitions, events and games
Marketing and promoting the business activities
Suggesting products & services which may interest you
providing, managing, Operating, processing and administering our products and services to you;
Fraud prevention and other administrative services, such as registration
In-app features (such as in-app storage of e-coupons, comments, recommendations, and postings, etc)
5.2 Cookies and Similar Technologies
We use cookies, pixel tags, web beacons and similar technologies (together referred to as “Cookies”) to improve our products and your experience on our Sites by collecting information on how you use our Sites. Some of the Cookies we use are required to enable core site functionality, for example to provide secure log-in or to remember how far you are through an order, but we also use Cookies that allow us to analyse site usage (so we can measure and improve performance), and advertisement Cookies which are used by advertising companies to serve ads that are relevant to your interests.
We may also tailor our Sites and our products to your interests and needs, by collecting information about your device and linking this to your Personal Data so as to ensure that our Sites present the best experience on our Sites for you. The types of data we may collect from you when you visit the Sites include:
• your IP address;
• details of the web pages you have viewed;
• information about the type of browser you use;
• the websites you visited before arriving at our Site.
• the hyperlinks you have clicked; and
• information about the mobile device used and the characteristics of such mobile device;
Our websites are initially set up to accept Cookies. You can opt-out of or delete historical cookies by changing the settings on your web browsers; however, if you do so, you may find that certain features on our website and/or our app do not work properly
If you wish to change your cookie preferences, please click the ‘Cookie Settings' button below. However, the content or functionality of our site may be limited or unavailable if cookies are disabled.
Cookies Settings
5.3 About using our Sites
When you choose to use access or download our Sites or allow connectivity via Wi-Fi connections to your device, we receive information about your location and mobile device, including a unique identifier for your personalised device, your GPS data or wireless networks data (WLAN). Location data is neither stored nor transmitted to third parties. If you agree with the localisation function and/or enable the notifications function on your device mobile, we can provide you with location-based services including advertising, search results and personalised content. When you are near one of our Stores, then we can use push email communications or notifications (such as recommended promotion and recommended products) to you based on your geo-location data services and/or immediately previous on-line activities if you have provided your consent to receive such communications and advertising.
Most mobile devices allow you to turn off location services and push notifications on your device. Should you wish to do so, please access your own device and vary the settings for notification on your device to reflect your own preference to be notified (or not) following the relevant instructions under your device.
6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymised or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your Personal Data) with third parties who may or may not be located overseas, as detailed in this section. By using our Sites, you agree to allow us to share your Personal Data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your Personal Data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.
6.1 Partners
Your Personal Data may be shared by us with our trusted business partners which offer Retail Goods or Services (“Our Partners”), such as Third-Party merchants providing the relevant Retail Goods or Services with whom we may from time to time cooperate with to offer you with those goods or services, to facilitate the processing of earning and redemption of loyalty points and related transactions, as well as for data analytics purposes in order to improve their operations for and supply of the relevant Retail Goods or Services to you.
Provided we have obtained your prior consent or indication of no objection, your Personal Data may be shared by us with Our Partners when we engage in customer matching with our members and Our Partners’ customers to undertake data analytics of common customers who may have shown an interest in receiving any offers tailored to the products offered by Our Partners and/or us.
Please be aware that Our Partners may themselves directly collect personal data from you if you give it to them when you purchase any goods or services at their stores, or if you register with them as a customer. The handling of your data collected by Our Partners will be governed by the relevant Partner's separate privacy policy (and not this Privacy Policy), and we are not involved or responsible for the collection and handling of such data.
6.2 Collection Centre
Your Personal Data may be transferred from us to appointed collection centre for shipment purposes only. We will not provide your Personal Data to any collection centre in order for them to send you direct marketing communications or materials regarding their own products and services under their own capacity, unless we obtain your prior explicit consent.
6.3 Our service providers
Your Personal Data may be shared with our service providers (including agents and contractors ) which process Personal Data on our behalf to help us administer and operate our business and our Sites to conduct data analytics, to help aggregate and anonymise the personal data, or to carry out any of the purposes set out in Section 5 above. These may include IT vendors, back-office and front-end or ancillary service providers, logistic and delivery service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on our behalf for any of the purposes set out in Section 5 above.
6.4 Professional advisors and assignees
When necessary, we may share your Personal Data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your Personal Data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.
6.5 Government and regulatory authorities
We will disclose your Personal Data to courts, law enforcement, regulatory or other governmental agencies if we are required to do so by law, or by a warrant, subpoena or court order.
6.6 Other recipients
We may transfer your Personal Data in the following scenarios:
- to data analytical firms, such as Google Analytics Inc. (to the extent that such Personal Data is not aggregated or anonymised) where your Personal Data was collected by cookies or similar tracking technologies across our Sites and other parties’ sites for these data analytical firms’ own benefit;
- to social media platforms such as Facebook ,Google ,Instagram ,TikTok or REDnote, when we engage in audience building or customer matching activities of our loyalty members with social media platforms including Facebook members or Google or Instagram or Tiktok or REDnote customer segmentation to undertake data mapping of common customers that you hereby expressly consent for us to do so;
- in an emergency, such as to safeguard the life, health or property of an individual; and/or
- with our consent to proceed to share your Personal Data with third parties where required by law.
7. TO WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA?
Many of our trusted third parties and Group companies are based in countries that provide an adequate level of data protection, such as the European Economic Area ("EEA"), Singapore and Hong Kong to ensure your Personal Data are safeguarded with sufficient protection in compliance with applicable Data Protection Laws.
When we need to transfer your Personal Data to a trusted Third-Party or Group company based in a country where data protection laws are considered not to offer the same level of protection, we ensure adequate data protection safeguards by relying on other legitimate means, such as Standard Contractual Clauses.
More details on the transfer mechanisms can be obtained from our Data Protection Officer (see contact details in Section 12).
8. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?
By providing your personal data to us, you accept that LS and FB may retain your information for as long as necessary, to fulfill the purpose(s) for which it is collected in compliance with applicable laws and regulations and LS and FB's prevailing internal policies. FB applies reasonable security measures to prevent unauthorised or accidental access, processing, erasure, loss or use including limiting physical access to data within LS and FB's systems and encryption of sensitive data when transferring such data. Reasonable steps will be taken to delete, destroy or anonymise your personal data when it is no longer necessary for any of the purposes above.
9. HOW DO WE PROTECT YOUR PERSONAL DATA?
We applies reasonable security measures to prevent unauthorized or accidental access, processing, erasure, loss or use including limiting physical access to data within FB's systems and encryption of sensitive data when transferring such data. Reasonable steps will be taken to delete, destroy or anonymise your personal data when it is no longer necessary for any of the purposes above.
Our Sites may contain hyperlinks to other websites provided by third parties. We do not control these Third-Party websites or apps or any of the content contained on those websites or apps. Once you have left our website or apps, we cannot be responsible nor accept any liability for the protection and privacy of any information which you provide to other sites or apps. You should exercise caution and look at the privacy policies of the other sites that you visit.
10. WHAT ARE YOUR RIGHTS?
If certain requirements are fulfilled and to the extent permitted by the Personal Data Protection Act 2012, you have the right to:
- Obtain from us confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data;
- Rectification of inaccurate Personal Data;
- Right to Request your Personal Data to be transmitted directly to another controller;
- Withdraw your consent for marketing communications (by logging into your account under “Marketing Preferences” or using the unsubscribe link in any of our marketing communications);
- Withdraw your consent for use of Cookies (via adjusting the setting under your web browser)
To exercise your rights, please contact the Data Protection Officer (see Section 12 for contact details) or get in touch with our Customer Service Team.
11. CAN WE CHANGE OUR PRIVACY POLICY?
We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy here. We encourage you to visit this area frequently to stay informed.
12. HOW DO I MAKE ENQUIRIES ABOUT MY PERSONAL DATA?
If you have any question or request in relation to how we process your personal data, you can contact our Data Protection Officer via email at frozenbeauty.contact@gmail.com or via post at 10 Anson Road , #10-11, International Plaza ,Singapore, 079903.
13. Complaints
If you have complaints about how we process your personal information, please contact us using the contact details provided below.
14. International Users
Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.
If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.
15. Contact
Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please whatapp or email us at frozenbeauty.contact@gmail.com or contact us at 10 Anson Road, 10-11, Singapore, 079903, SG.