Privacy Policy

This is the customer privacy policy (“Privacy Policy”) of Spa Esprit Group Pte Ltd
(200707818N), and its respective subsidiaries, related companies and jointly controlled
entities (hereinafter collectively referred to as “Spa Esprit Group”) discloses how “Spa Esprit
Group”, “us” or “we” collect, store and handle the Personal Data (as defined below) of its
customers at Spa Esprit Group and visitors to any of the websites owned and operated by Spa
Esprit Group.

We may update this privacy policy from time to time by publishing the amended version on
our websites. This privacy policy applies to personal information we hold about individuals.
We will only use your personal information in accordance with Personal Data Protection Act
2012 and all other current data protection law in Singapore and this Privacy Policy.

Please read the following Privacy Policy to understand how Spa Esprit Group uses the
Personal Data we may collect from you.

By providing your Personal Data to us, you are voluntarily consenting to this Privacy Policy
and the collection, use, access, transfer, storage and processing of your personal information
as described in this Policy.

OUR WEBSITE

We are committed to keep our website secure. However, we ask you to recognise that
information provided by you to us through our website or when you ask us to send your
Personal Data via email or any other electronic means of communication may not be secure.
We cannot be responsible for any loss or unauthorised interception of information transmitted
via the internet which is beyond our control.

User-supplied information through registration, surveys, polls or other similar vehicles found
in our website are utilised to improve the content of our website and overall customer
experience. It is not shared with other organisations for commercial purposes unless
specifically stated.

Our website may contain links to other websites outside of Spa Esprit Group. Please note that
our Privacy Policy only applies to our website and we are not responsible for the security,
privacy policy or manner in which how other websites collect your Personal Data.

OUR COMMITMENT TO PROTECT YOUR PRIVACY

At Spa Esprit Group, the confidentiality and importance of your Personal Data are our utmost
concern; we are therefore committed in protecting your Personal Data privacy with care and
in accordance with the statutory provisions. To ensure that you can make informed decisions
and feel confident about supplying your Personal Data to us when using our website, mobile
and other services, we provide this notice outlining our practices and the choices you have
concerning how your Personal Data is being collected and used by us.

THE PERSONAL DATA WE COLLECT

We request information from you in several areas of our website, mobile services and other
channels including in-store, which may be used to personally identify you (“Personal Data”).
Personal Data that we receive and process will vary, depending on the types of products and
services requested by you and may include but not limited to the followings:

  1. Your personal information such as your name, gender, date of birth, passport or other
    personally identifiable number and information about your registered status with any
    of our subsidiaries, associated companies and/or business associates;
  2. Your contact information such as your telephone numbers, mailing addresses, email
    addresses, and fax numbers;
  3. Your credit or debit card information and billing information, including name of
    cardholder, card number, billing address and expiry date;
  4. Your business information such as company name, business title and associated
    contact information;
  5. Your responses to market surveys and contests conducted by us or on our behalf.
  6. Your Personal Data provided by governmental agencies, regulatory and statutory
    authorities,
  7. Your Personal Data provided by you such as comments, queries or messages that you
    may submit to Spa Esprit Group in whatever manner,
  8. Other data from publically available sources.

We acknowledge that the provision of your personal data is voluntary. However, should you
decide not to provide us with your Personal Data (particularly relating to your personal
information, contact information and past medical history) or should you provide insufficient or
inaccurate information or decline to provide obligatory information requested by us, we may
not be able to process your requirements and deliver or provide you the products or services
you request whether partially or in full.

PURPOSE FOR WHICH THE PERSONAL DATA ARE COLLECTED AND USED

We may use the Personal Data you provided for one or more of the following purposes:

  1. For your use of the online services available at any of our websites and/or through
    other telecommunication channels;
  2. For the supply of any products and/or services which we may offer to you or you may
    require from us from time to time including text message (SMS) alerts;
  3. For marketing, promotional and customer relationship management purposes, such as
    sending you updates on latest offers and promotions in connection with our products
    and services and conducting market research;
  4. For identification and verification purposes in connection with any of the services or
    products that may be supplied to you;
  5. To contact you regarding your enquiries;
  6. To administer contests and sweepstakes conducted by us or on our behalf;
  7. To disclose to a third party to comply with any law, legal requirements, orders,
    directions or requests from any court, authority or government body of any jurisdiction,
    which may be within or outside of Singapore;
  8. To facilitate the payment for products and services provided by us or our subsidiaries,
    associated companies and/or business associates including verification of credit card
    details with third parties and using the Personal Data you provide to conduct matching
    procedures against databases of known fraudulent transactions (maintained by us or
    third parties).
  9. To improve our security, including in relation to the processing of payment by credit
    card to guard against the risk of fraud including carrying out matching procedures
    against databases of known fraudulent transactions (maintained by us or third parties).

We may from time to time use aggregate non-identifying information about our customers to
better design our website and/or to improve our services and products. This means we may
provide this information to third parties. However, this information will never identify any single
user in particular.

Except as provided below, we will not knowingly or intentionally use or share the Personal
Data you provide to use in ways unrelated to the aforementioned purposes without your prior
consent.

HOW TO ACCESS OR CORRECT YOUR PERSONAL DATA

Subjected to the exception provided under Singapore law, you can obtain information about
your Personal Data stored by Spa Esprit Group and, may request access to any Personal
Data stored about you and request for correction, updating, deletion or disabling of your
Personal Data at any time. If you wish to obtain a copy of any of your Personal Data, or if you
believe that the Personal Data relating to you which we collect and maintain is inaccurate,
incomplete or ceased to be true, or if you believe that the Personal Data held by us was used
beyond the scope of the purpose of use disclosed above or was acquired by fraudulent or
unlawful means or provided to a third party without your prior consent, please write to us at
the address below.

Any queries, complaints, objections or request for access or correction to, or deletion of
Personal Data or for information regarding policies and practices and kinds of Personal Data
held by us, or should you wish to limit the processing of your Personal Data, or to withdraw
any voluntary consent provided by you, must be in writing and sent to us via postal mail at the
following address:

Customer Care
Spa Esprit Group Pte Ltd
60 Jalan Penjara
Singapore 149375

We reserve a right to impose a reasonable fee as permitted under law for the processing of
any data access request. We have the right to refuse your request to access and/or make any
correction to your Personal Data for reasons permitted under law.

USE OF COOKIES ON SPA ESPRIT GROUP SITES

A cookie is an alphanumeric string of identifier that websites of the Spa Esprit Group use to
transfer to the cookie file of the browser on your computer’s hard disk. With the use of cookies,
we can better serve you and/or maintain your information across multiple pages within or
across one or more sessions. Most web browsers automatically accept cookies, but if you
prefer, you can edit your browser options to block them in future.

Two types of cookies are used on the Sites:

Session Cookies, which are temporary cookies that remain in the cookie file of your browser
until you leave the site.

Persistent Cookies, which remain in the cookies file of your browser for much longer (though
how long will depend on the lifetime of the specific cookie).

LINKS TO OTHER SITES

This website contains links to other sites that are operated by third party companies with
different contents, securities and privacy practices. You should remain alert when you leave
our site and read the privacy statements of other websites. We have no control over Personal
Data that you submit to or receive from these third parties and are not responsible for any
Personal Data which you may submit outside of our website.

OUR COMMITMENT TO PERSONAL DATA SECURITY

For example, we use Secure Socket Layer (SSL) protocol – an industry standard for encryption
over the Internet – to protect in transmission the Personal Data we collect online. When you
type in sensitive information such as credit card details, it will be automatically converted into
codes before being securely dispatched over the Internet. All electronic Personal Data that we
maintain is securely stored and further protected through our use of appropriate access
controls. When disposing of Personal Data, paper documents containing Personal Data are
securely destroyed, and electronic files storing Personal Data are permanently deleted.

As stated above, in some instances we may entrust Personal Data to third party service
providers (including service providers outside of your jurisdiction), binding them to protect the
security of Personal Data and only to use it for the purposes we specify.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

Spa Esprit Group Pte Ltd (Co. Registration 200707818N), together with its subsidiaries and
related companies (“Spa Esprit Group”), is a beauty, food and beverage company with
operations, offices, affiliates and business partners located worldwide. As such, the Personal
Data you submit to us in one country may be transferred, used, processed, stored and
accessed worldwide in one or more additional countries, as described in this Privacy Policy.

In addition, we may disclose and transfer Personal Data to and jointly use Personal Data with
(whether within or outside of your jurisdiction) our subsidiaries, associated companies,
business associates, service providers, and other persons who we consider appropriate, in
connection with the services and products provided to or requested by you. We may disclose
this information to facilitate communication of news and information about such services and
products and otherwise for the purposes mentioned above, under “Purpose for which the
Personal Data are Collected and Used.”

The entities with whom we may share your Personal Data include but are not limited to:

  1. Spa Esprit Group and its subsidiaries and related companies;
  2. Any agent, contractor or third party service provider who provides administrative,
    marketing and research, distribution, data processing, telemarketing,
    telecommunications, computer, payment or other services to Spa Esprit Group and its
    subsidiaries in connection with the operation of its business;
  3. Other business associates such as loyalty program operators and other companies
    involved in providing customer service or fulfilling customer requests;
  4. Credit reference agencies;
  5. Credit, debit and /or charge card companies and/or banks;
  6. Government or non-government authorities, agencies and/or regulators;
  7. Medical professionals, insurers and clinics/hospitals.

Where permitted by applicable local law, we may also disclose your Personal Data to third
parties: (i) when required by law, by court order, or in response to a search warrant or other
legally valid inquiry; (ii) to an investigative body; (iii) to enforce our agreements with you; (iv)
when requested by other government or law enforcement authorities; (v) with your express
consent, or, (vi) pursuant to our good faith belief that disclosure is required by law or otherwise
necessary to the establishment of legal claims or defenses, to obtain legal advice, to exercise
and defend our legal rights, to protect our rights or property and those of our subsidiaries or
associated companies, or to protect the life, body or property of an individual. This also applies
when we have reason to believe that disclosing the Personal Data is necessary to identify,
contact or bring legal action against someone who may be causing interference with our rights
or properties, whether intentionally or otherwise, or when anyone else could be harmed by
such activities.

We may also transfer any information we have about you as an asset in connection with a
merger or sale (including transfers made as part of insolvency or bankruptcy proceedings)
involving all or part of Spa Esprit Group or as part of a corporate reorganization or stock sale
or other change in corporate control.

Please be advised that the Personal Data that Spa Esprit Group collects or obtains may be
transferred to jurisdictions that offer lesser protection of Personal Data than that provided in
your jurisdiction. By submitting personal information to Spa Esprit Group or using any Spa
Esprit Group or its related associates’ website, you understand and consent to such transfer.

CONFIDENTIALITY

Personal Data held by us will be kept confidential in accordance with this Privacy Policy
pursuant to any applicable law that may from time to time be in force.

Any questions, comments, suggestions or information other than Personal Data sent or posted
to this Website, or any part of this Website by visitors will be deemed voluntarily provided to
us on a non-confidential and non-proprietary basis.

CHANGES TO PRIVACY POLICY

We reserve the right to amend this Privacy Policy from time to time without prior notice. We
advise that you check this Privacy Policy on a regular basis. We will post on our website any
changes to this policy with the effective date of the changed policy, so that you can be informed
of the way we collect and use your Personal Data any time you so choose. If at any point we
decide to use the Personal Data you submitted under this current policy in a way that differs
materially from the privacy policy that applied at the time of that submission, you will be notified
and given the opportunity via the website, email or in writing to opt out or otherwise prevent
such usage.

YOUR CHOICE

Occasionally, we may use your personal data (including your name and contact details) to
send you marketing communications such as emails containing news, offers, promotions and
joint marketing offers. However, we will first obtain your consent before doing so. Please see
below on how to provide us with your consent.

We may also provide your personal data (including your name and contact details) to third
parties including our marketing partners, travel service partners for the purpose of marketing
their products and services to you. Again, we will only do this if you provide us with your
consent

You may indicate your consent to the above by the following ways:

  1. when providing us with your personal data through our website or a form, ticking boxes
    indicating your consent;
  2. when providing us with your personal data through the telephone, tell our customer
    representative that you consent; or

You may opt-out from receiving marketing communications at any time, free of charge, by:

  1. following the opt-out instructions contained in the communications;
  2. writing to us at the address listed above; or

Any personal data provided to or gathered by Spa Esprit Group is controlled primarily by Spa
Esprit Group Pte Ltd.

RETENTION OF DATA

All Personal Data that has been collected from you will only be stored for a limited duration
that is relevant to the purpose for which it was processed and for as long as required by
applicable law.

This Privacy Policy is written in English language and may be translated into other languages.
In the event of any inconsistency between the English version and the translated version of
this notice, the English version shall prevail.

If you have any questions with regards to our privacy policy, please contact us at

Data Protection Officer
60 Jalan Penjara
Singapore 149375
Contact No: +65 6474 5964
Email Address: dpo@spa-esprit.com

Spa Esprit Group