Privacy Policy

Enn&CO Holdings Pte. Ltd. (the “Company”, “we” or “us”) promotes the protection of personal data by establishing a mechanism for the protection of personal data and ensuring that all employees are aware of the importance of the protection of personal data and take measures therefor. This Privacy Policy (this “Privacy Policy”) sets out the manner in which the Company may collect, use, disclose or otherwise process data, whether true or not, about users who can be identified either (a) from that data, or (b) from that data and other information to which the Company has or is likely to have access in accordance with the Personal Data Protection Act 2012 of Singapore, as may be amended from time to time (the “PDPA”). This Privacy Policy applies to all users. 

Collection of Information

1. The Company provides services for the sale of makeup products. In order for the Company to render the services, it is necessary for us to collect and use certain personal data. The specific types of personal data that users submit may vary depending on the relevant services provided and whether a user maintains a membership account with the Company.

2. The Company collects personal data directly from users, from the authorized representatives of users, when users interact with the Company’s website (the “Website”), from third parties or publicly available sources.

Management of Personal Data

In order to keep the personal data of users accurate and up-to-date and to prevent unauthorised access, loss, damage, falsification, or leakage of the personal data, the Company shall take commercially reasonable precautions such as the establishment of a security system, maintenance and management system and thorough employee education, the implementation of security measures, and the strict management of the personal data. For details of security management measures taken by the Company, please contact the Data Protection Officer using the contact information below. 

Purpose for Use of Personal Data

The Company may collect and use the personal data received from users for any or all of the following purposes:

(1) Delivery of products or communication from the Company regarding products/services

(2) Retention of member registration information

(3) Answering questions from users

(4) Sending emails or sending materials

(5) Provision of information to the Company’s group companies or other third parties

(6) Instruction, advertisement, and promotion, etc. of the products/services of the Company or the Company’s group companies or other third parties

(7) Analysis and estimation of users’ hobbies, preferences, buying tendencies, attributes, etc. and marketing using such information

(8) Preparation of statistical information and the use of such information for improvement of the Company’s services and development of new services, etc.

Disclosure or Provision of Personal Data to Third Parties

1. The Company will manage personal data received from users in an appropriate manner and, in principle, will not disclose or provide such information to any third party, except where the user’s individual consent has been obtained and where disclosure or provision is made under the PDPA or other applicable laws, regulations, and guidelines. Provided, however, that the foregoing shall not apply in the cases set forth in the following two Paragraphs.

2. In the following limited cases, the Company may disclose personal data of users to third parties:

(1) When providing users’ personal data to partner companies that provide advertisement distribution services, etc. in order to deliver advertisements to users; and

(2) If a user uses the services of a partner company of the Company, when providing the partner company with the user’s personal data necessary to collaborate with such partner company.

3. In order to achieve the purpose for use set forth in this Privacy Policy, the Company may transfer user’s personal data to a third party in a foreign country outside of Singapore. If the Company does so, we will take steps to ensure that the personal data of users continues to receive a standard of protection that is at least comparable to that provided under the PDPA. Information regarding the transfer of personal data of users to a third party in such foreign country is as follows:

(1) Name of the foreign country where the third party to whom information is provided is located:

Japan and any other foreign countries 

(2) Information on the system for the protection of personal data in the relevant foreign country:

Please refer to the following website of the Personal Information Protection Commission:

https://www.ppc.go.jp/en/legal

(3) Information on the measures taken by such third party for the protection of personal data:

The recipient offers a standard of protection that is at least comparable to that provided under the PDPA for handling personal data. 

Delegation of Handling of Personal Data

The Company may outsource the handling of all or part of a user’s personal data to a third party as necessary to achieve the purpose for use set forth in this Privacy Policy. In this case, the Company will conduct necessary and appropriate supervision over the outsourcing contractor to ensure the security of the personal data.

Access to Personal Data

A user may request, in accordance with the procedures prescribed by the Company, that the Company notify the purpose for use of retained personal data that can identify the user, disclose retained personal data or records provided to third parties, correct, add, or delete the retained personal data, and discontinue the use of, delete, or discontinue the provision to third parties of retained personal data. If a user makes such a request, the Company will respond to it after confirming that the request is made by the user in question. For details on how to make a request, please contact the Data Protection Officer using the contact information below.

Retention of Information

1. The Company only retains the personal data of users for as long as is necessary to process the personal data as described above. However, please be advised that the Company may retain some personal data after a user ceases to use the Company’s services, for instance if the data is necessary to meet the Company’s legal obligations.

2. In some circumstances, the Company may anonymize personal data (so that it can no longer be associated with a particular user) for research or statistical purposes in which case we may use this information indefinitely without further notice to the user.

Compliance with Laws, Regulations, and Standards and Review

The Company will comply with all applicable Singapore laws, regulations, and other standards regarding personal data it holds, review the contents of this Privacy Policy from time to time, and strive to improve them. As this Privacy Policy may be modified or amended from time to time, users are requested to check the latest Privacy Policy published on the Company’s website.

Inquiries

If you have any questions regarding this Privacy Policy, please contact:

Data Protection Officer

Saki Nakai

Enn&CO Holdings Pte. Ltd.

160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore (068914)

E-mail: please send through Contact Us

Updated on October 11, 2024