Privacy Policy

DATA PROTECTION NOTICE FOR CUSTOMERS

This Data Protection Notice (“Notice”) sets out the basis which MEOWAESTHETICSPRIVATE LIMITED (UEN:202434776ZH) (“we”, “us”, or “our”) may collect, use, discloseor otherwise process personal data of our customers in accordance with the Personal DataProtection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engagedto collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Notice:

• customer means an individual who (a) has contacted us through any meanstofindout more about any goods or services we provide, or (b) may, or has, enteredintoacontract with us for the supply of any goods or services by us; and
• personal data means data, whether true or not, about a customer whocanbeidentified: (a) from that data; or (b) from that data and other information to whichwehave or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal datawhich we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photographandvideos during sessions.

3. Other terms used in this Notice shall have the meanings given to themin thePDPA(where the context so permits)

4. We generally do not collect your personal data unless (a) it is providedtousvoluntarily by you directly or via a third party who has been duly authorised by youtodisclose your personal data to us (your“authorised representative” ) after (i) you(or your authorised representative) have been notified of the purposes for whichthedatais collected, and (ii) you (or your authorised representative) have providedwrittenconsent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or requiredbythePDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not beennotified to you (except where permitted or authorised by law).

5. We may collect and use your personal data for any or all of the following purposes:

• performing obligations in the course of or in connection with our provisionof the goods and/or services requested by you;
• responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
• processing payment or credit transactions;
• complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conductedbyanygovernmental and/or regulatory authority;
• any other purposes for which you have provided the information;
• transmitting to any unaffiliated third parties including our third party serviceproviders and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
• any other incidental business purposes related to or in connectionwiththeabove.

6. We may disclose your personal data:

• where such disclosure is required for performing obligations in the courseof or in connection with our provision of the goods and services requestedbyyou; or
• to third party service providers, agents and other organisations wehaveengaged to perform any of the functions with reference to theabovementioned purposes.

7. The purposes listed in the above clauses may continue to apply even in situationswhere your relationship with us (for example, pursuant to a contract) hasbeenterminated or altered in any way, for a reasonable period thereafter (including, whereapplicable, a period to enable us to enforce our rights under a contract with you).

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

8.In compliance with the PDPA, we may collect, use or disclose your personal datawithout your consent for the legitimate interests of MEOWCADEMYPRIVATELIMITED or another person. In relying on the legitimate interests exceptionof thePDPA, MEOWCADEMY PRIVATE LIMITED will assess the likely adverse effectsonthe individual and determine that the legitimate interests outweigh any adverseeffect.

9. In line with the legitimate interests exception, we will collect, use or discloseyour personal data for the following purposes:

• Fraud detection and prevention;
• Detection and prevention of misuse of services;
• Network analysis to prevent fraud and financial crime, and performcredit analysis; and
• Collection and use of personal data on company-issued devices to prevent dataloss.

The purposes listed in the above clause may continue to apply even in situations whereyour relationship with us (for example, pursuant to a contract) has been terminated or alteredinany way, for a reasonable period thereafter.

WITHDRAWING YOUR CONSENT

10. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. Youmaywithdraw consent and request us to stop collecting, using and/or disclosingyour personal data for any or all of the purposes listed above by submitting your request inwriting or via email to our Data Protection Officer at the contact details providedbelow.

11. Upon receipt of your written request to withdraw your consent, we may requirereasonable time (depending on the complexity of the request and its impact onour relationship with you) for your request to be processed and for us to notify youof theconsequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to processyour request within fourteen (14) business days of receiving it.

12. Whilst we respect your decision to withdraw your consent, please notethat depending on the nature and scope of your request, we may not be in a positiontocontinue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decidetocancel your withdrawal of consent, please inform us in writing in themanner described in clause 8 above.

13. Please note that withdrawing consent does not affect our right to continue tocollect, use and disclose personal data where such collection, use and disclosewithout consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

14. If you wish to make (a) an access request for access to a copy of the personal datawhich we hold about you or information about the ways in which we use or discloseyour personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writingor viaemail to our Data Protection Officer at the contact details provided below.

15. Please note that a reasonable fee may be charged for an access request. If so, wewill inform you of the fee before processing your request.

16. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not beabletorespond to your request within thirty (30) days after receiving your request, wewill inform you in writing within thirty (30) days of the time by which we will beabletorespond to your request. If we are unable to provide you with any personal dataor tomake a correction requested by you, we shall generally informyou of thereasonswhy we are unable to do so (except where we are not required to do so under thePDPA).

PROTECTION OF PERSONAL DATA

17. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introducedappropriate administrative, physical and technical measures such as minimisedcollection of personal data, authentication and access controls (such asgoodpassword practices, need-to-basis for data disclosure, etc.), encryption of data, dataanonymisation, up-to-date antivirus protection, regular patching of operatingsystemand other software, securely erase storage media in devices before disposal, websecurity measures against risks, usage of one time password(otp)/2factor authentication (2fa)/multi-factor authentication (mfa) to secure access, andsecurityreview and testing performed regularly.

18. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot beguaranteed, we strive to protect the security of your information and are constantlyreviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

19. We generally rely on personal data provided by you (or your authorisedrepresentative). In order to ensure that your personal data is current, completeandaccurate, please update us if there are changes to your personal data by informingour Data Protection Officer in writing or via email at the contact details providedbelow.

RETENTION OF PERSONAL DATA

20. We may retain your personal data for as long as it is necessary to fulfil thepurposefor which it was collected, or as required or permitted by applicable laws.

21. We will cease to retain your personal data, or remove the means by whichthedatacan be associated with you, as soon as it is reasonable to assume that suchretention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

22. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be madeandwewill take steps to ensure that your personal data continues to receive a standardof protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

23. You may contact our Data Protection Officer if you have any enquiries or feedbackon our personal data protection policies and procedures, or if you wish to makeanyrequest, in the following manner:

EFFECT OF NOTICE AND CHANGES TO NOTICE

24. This Notice applies in conjunction with any other notices, contractual clausesandconsent clauses that apply in relation to the collection, use and disclosureof your personal data by us.

25. We may revise this Notice from time to time without any prior notice. Youmaydetermine if any such revision has taken place by referring to the date on whichthisNotice was last updated. Your continued use of our services constitutesyour acknowledgement and acceptance of such changes.