Privacy Policy

Overview and Scope

Your personal data privacy is important to us and LEAP Commerce are highly committed in respecting and managing your Personal Data collected in line with this Policy. This Personal Data Privacy Policy sets out the collection, use and disclosure of your Personal Data.In line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012), “Personal Data” means any data or information, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which LEAP Commerce is likely to have access to. Personal Data excludes business contact information such as an individual’s business telephone number and business electronic mail address.


When and what kind of Personal Data do we collect?

LEAP Commerce may collect, use and disclose the following data about you:

  1. When you provide Personal Data by filling in forms on any of the LEAP Commerce Group of Companies’ websites and web-based programmes, when giving feedback, asking queries, requests and submissions;
  2. If and when you contact LEAP Commerce, we may keep a record of that correspondence;
  3. Details of your visits to our website including, but not limited to, cookies, location data, weblogs and other communication data, that you access;
  4. When you fill up a customer data form or join any of LEAP Commerce’s membership programmes at any LEAP Commerce retail outlet, counter or pop-up store;
  5. If you enter into any contract with LEAP Commerce or purchase any products from LEAP Commerce;
  6. If you participate in any exhibition/event organised by LEAP Commerce or where LEAP Commerce is a participant. When you provide Personal Data by filling in forms for specific services

LEAP Commerce may collect the following kinds of Personal Data through the different channels mentioned above:

  1. Name;
  2. ID/Passport/Work Permit/FIN numbers and copies;
  3. Date of Birth;
  4. Mailing and residential addresses;
  5. Email addresses;
  6. Telephone numbers;
  7. Gender;
  8. Photos and CCTV/videos;
  9. Medical history and/or skin conditions (for specific services)

What purposes does LEAP Commerce Collect, Use and Disclose Personal Data?

LEAP Commerce may use the information we collect from you for any of the following purposes:

  1. To perform or carry out LEAP Commerce’s obligations arising from any contracts entered into between you and us (i.e. purchase and delivery of LEAP Commerce’s products and services);
  2. To enable LEAP Commerce’s subcontractors, third-party agents and service providers, to fulfil obligations as stipulated in your contract with LEAP Commerce;
  3. To handle products and services requests and enquiries (including payments for products and services);
  4. To administer and update your records in our databases; monitoring and maintaining a copy of your record of previous transactions;
  5. To facilitate the delivery, maintenance and enhancement of LEAP Commerce’s products, services, programmes, activities and events;
  6. To plan, monitor and enhance the provision of new products, services, projects, programmes, activities and events;
  7. To improve LEAP Commerce’s customer service through your feedback and provide recommendations;
  8. To process your enquiries and any and all other ancillary administrative purposes;
  9. To send regular e-newsletters;
  10. To process, formulate, tabulate or evaluate contest information, promotion or other marketing activities;
  11. For communications, marketing and publicity purposes;
  12. For government, audit and other regulatory purposes;
  13. For security, surveillance and monitoring purposes;
  14. For internal reporting and/or accounting purposes;
  15. Purposes incidental to each or all of the above.

We may also contact you by any means of communication for which you have given us contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.

By your submission of your Personal Data to us, you consent to the onward disclosure of your Personal Data to these agents or service providers and the processing of your Personal data by these agents or service providers. These agents and service providers include:

  1. Affiliated companies within LEAP Commerce for marketing and administrative purposes (i.e. verification and IT purposes); and
  2. Marketing partners and third-party service providers (such as subcontractors, agents or network operators providing IT, website, customer relationship management and marketing support) who perform functions such as marketing. The entities to whom we disclose your Personal Data may be located in a range of countries.

The countries in which these third parties are located will depend on the circumstances. In the ordinary course of business we commonly disclose Personal Data to parties located in Singapore. LEAP Commerce may also disclose or transfer out of the country personal data as permitted or required by law. In the event any cross-border transfer or disclosure is required, we will take steps to ensure that the recipient organisation will take reasonable measures in the protection of your personal data.


Consent for the collection and use of my Personal Data

We do not collect, use, or disclose your Personal Data without your consent, except where permitted and authorised by law. You consent to the collection, use, disclosure, transfer, and processing of your Personal Data for the abovementioned purposes and agree to be bound by the obligations it imposes on you, when you accept this Privacy Policy. You accept this Privacy Policy when you continue to browse on LEAP Commerce’s website.

We may update this Privacy Policy by posting updated versions on the Website. Your continued membership, access to, and/or use of the Website will be taken to be your consent to and acceptance of all changes made in each updated version.

In this regard, please note that it is on your part to ensure that all personal data submitted to us is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

Please note that if you do not consent to any of the above business purposes, LEAP Commerce may also be unable to meet the purposes for which the information was collected.

LEAP Commerce shall not be liable for any damage, claim and/or harm suffered by you as a result of your failure to update us of any change of your Personal Data.


Children’s Privacy

If you are under 16 years of age, you may browse the LEAP Commerce Site. However, you may not provide personal information to us. This site is not designed for persons under the age of 16 and we do not knowingly collect personal information from anyone under the age of 16.


Does LEAP Commerce disclose Personal Data to third parties?

LEAP Commerce may disclose your Personal Data to any member within our group, which means our subsidiaries, affiliates, our ultimate holding company and its affiliates or subsidiaries, as defined in the Companies Act (Cap. 50).

LEAP Commerce may retain other companies and individuals to perform functions on our behalf consistent with this Privacy Policy. On occasion, LEAP Commerce may use third party agents and service providers to assist us in the use of your Personal Data as outlined under “What purposes does LEAP Commerce Collect, Use and Disclose Personal Data?” You consent to such use of your Personal Data by continuing to browse on LEAP Commerce’s website.

LEAP Commerce may use and disclose your Personal Data to perform your instructions and, as relevant, (a) comply with legislative and regulatory requirements; (b) protect or defend our property, services and legal rights; c) Prevent fraud against LEAP Commerce and others; (d) take emergency measures for the purpose of securing the safety of customers, LEAP Commerce, or the general public.

LEAP Commerce will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.


Location and Transfer of Personal Data

LEAP Commerce may collect and process your Personal Data in countries other than your country of residence or the country from which you provided LEAP Commerce with your Personal Data. These other countries may not have the same data protection laws as the country in which you reside or provided Personal Data. In addition, LEAP Commerce may transfer the Personal Data to our affiliates, subsidiaries, and service providers in other countries for the aforementioned purposes. When transferring, LEAP Commerce does so in accordance with applicable law.


For how long does LEAP Commerce retain my Personal Data?

LEAP Commerce will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.


How does LEAP Commerce protect your Personal Data?

The Personal Data that we hold about you will be stored on our servers. LEAP Commerce implements appropriate technical and organisational security measures to protect your submitted information from unauthorised access, use, and disclosure. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.

Although every reasonable effort has been made to ensure that all personal data will be so protected, no data transmission over the internet can be guaranteed as fully secure. We cannot guarantee that the security measures that we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be efficient or effective. LEAP Commerce cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.

Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.


Links to third party websites from LEAP Commerce’s website

Our websites may contain links to and from other third-party websites and services, such as our business partners, that are not controlled or operated by LEAP Commerce (collectively, “Third Party Sites”). We are not responsible for the privacy policies and practices of these websites taken care of by third-parties.

We strongly encourage you to check the privacy policy of each website that you visit. Some of these third-party websites may have our logo or trademark acknowledged on their website. However, these websites are not operated and maintained by us. Please contact the owner of the respective websites should you have any questions on their privacy policies. Your use of these Third Party Sites is at your own risk and LEAP Commerce does not accept any responsibility or liability for the privacy practices of these Third Party sites to which you link from the LEAP Commerce sites.


Access, Correction and Withdrawal of Personal Data

Please contact us via dpo@leapcommerce.com should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.


Further Information

If you are concerned about the handling of your Personal Data, or if you have any complaints or queries related to your Personal Data or our Privacy Policy, please contact LEAP Commerce’s Data Protection Officer (“DPO”) at dpo@leapcommerce.com.

LEAP Commerce reserves the right to change this Policy with or without notice from time to time.