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GOLD GEAR PRIVACY POLICY

 

Last Updated: 22 August 2023

 

1. GOLD GEAR AS THE DATA CONTROLLER

 

1.1 - This Privacy Policy applies to the User’s access and use of the Website, as well as to the use of (which includes any participation in) the Services.

 

1.2 - This Privacy Policy is incorporated as part of the Terms and Conditions, accessible at www.vinophiliawines.com.

1.3 - The User’s privacy is important to Gold Gear, and Gold Gear has adopted this Privacy Policy to inform the User of how Gold Gear as the Data Controller collect, process, use and disclose the User’s Personal Data derived from the User’s access and use of the Website and the Services.

 

1.4 - If the User has any questions about this Privacy Policy, or if the User wishes to access, update or correct the User’s Personal Data or withdraw the User’s consent to the use, collection and disclosure of the User’s Personal Data in accordance with this Privacy Policy, please email Gold Gear at enquiry@vinophiliawines.com

 

2. GENERAL DEFINITIONS

2.1 - In this Privacy Policy, unless the context otherwise requires, the following general definitions apply:

 

(a) “Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Website and the Services.

 

(b) “Data Protection Laws” means applicable laws and regulations relating to the use and/or processing of personally identifiable information and data and privacy.

 

(c) “Personal Data” means:

 

(i) data, whether true or not, about an individual who can be identified:

 

(1) from that data; or

 

(2) from that data and other information to which Gold Gear has or are likely to have access; and

 

(ii) any data that is analogous to the foregoing, as defined in Data Protection Laws.

 

(d) “Purposes” means the purposes for which Gold Gear collects the User’s Personal Data as set out in this Privacy Policy.

 

2.2 - Except as otherwise defined above, capitalised terms in this Privacy Policy have the same meanings as those given in the Terms and Conditions.

 

2.3 - Unless otherwise stated, this Privacy Policy does not cover any collection, use or disclosure by third-parties, including through any applications, websites, products or services that Gold Gear does not control or own.

 

3. COLLECTION OF PERSONAL DATA

3.1 - Gold Gear may collect and process the following Personal Data pertaining to the User when the User:

(a) uses the Website and any of the Services;

 

(b) register for any participation in any of the Services; and/or

 

(c) contact or engage with Gold Gear for any of the Purposes.

 

3.2 - In connection with the User’s use of the Website or the Services, Gold Gear may collect the following Personal Data from the User:

 

(a) the User’s contact and registration information such as the User’s name, identification number, date of birth, email and mailing addresses and/or telephone number;

 

(b) information pertaining to the User’s organisation such as the organisation name, registration number, registered address and organisation status;

 

(c) geographical-specific information such as nationality and country of residence;

 

(d) specific usage data from the User’s use of the Website and the Services;

 

(e) technical information related to the User’s use of the Website and the Services, such as IP addresses, browser information and mobile device information;

 

(f) if applicable, payment details in order to process payments for purchases made on the Website or as part of the Services;

 

(g) aggregated information such as statistical or usage data (note that such aggregated and statistical data may be derived from the User’s Personal Data but is anonymised);

 

(h) unique social media identifiers (e.g. profile names, in-game names) on certain social networking Websites (e.g. Facebook, Discord), where the User’s use of the Services involves the use of third-party Websites or services;

 

(i) details of transactions the User carries out through the Website and details pertaining to fulfilment of the User’s order(s); and

 

 

 

 

3.3 - Note on collection of the User’s national identification number (e.g. NRIC for Singapore Users): Gold Gear is fully aware of the sensitive nature of the User’s national identification number, and Gold Gear only collects, use and disclose such information to the extent necessary under applicable laws and regulations, as well as in order to accurately establish and verify the User’s identity to a high degree of fidelity.

 

3.4 - In connection with the Services, and to the extent permitted by applicable laws (including Data Protection Laws), Gold Gear may also be collecting from sources other than the User, the User’s Personal Data, for one or more of the Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the Purposes.

 

3.5 - Gold Gear may combine information it receives from other sources with information the User gives to Gold Gear and information Gold Gear collect on the User. Gold Gear may use this information and the combined information for the Purposes (depending on the types of information Gold Gear receives). If the User suspects that any of the User’s Personal Data has not been lawfully disclosed to Gold Gear, please contact Gold Gear (details are set out at the start of this Privacy Policy).

 

3.6 - Other than as stated in this Privacy Policy, Gold Gear does not collect or process any other Personal Data.

 

3.7 - Gold Gear may hold the User’s Personal Data on servers in Singapore and/or any other territories as Gold Gear sees fit from time to time.

 

3.8 - Gold Gear shall only retain the User’s Personal Data for so long as it is necessary. Such Personal Data may be archived for as long as the purpose for the said Personal Data still exists. Gold Gear will put in place measures such that the User’s Personal Data in Gold Gear’s possession or under Gold Gear’s control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which the User’s Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.

 

4. USE OF PERSONAL DATA

 

4.1 - The purposes for which User’s Personal Data may be used by Gold Gear in and outside Singapore shall include:

 

(a) ensuring that content on the Website is presented in the most effective manner for the User;

 

(b) providing the User with alerts, newsletter, education materials or information that the User has requested or signed up to;

 

(c) carrying out Gold Gear’s obligations arising from any contracts entered into with the User;

 

(d) allowing the User to participate in features of the Services;

 

(e) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision of Gold Gear’s products and services (including the Services);

 

(f) complying with laws and regulations applicable to Gold Gear in or outside Singapore;

 

(g) legal proceedings, including collecting overdue amounts and seeking professional advices;

 

(h) researching, designing and launching services or products including seminars/events/forums;

 

(i) promoting and marketing services and products (including the Services);

 

(j) promoting reward, loyalty or privileges programmers, promotional offers and related services;

 

(k) promoting invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events; or

 

(l) purposes directly related or incidental to the above.

 

4.2 - Gold Gear may collect, use, disclose or process the User’s Personal Data for other purposes that do not appear in this Privacy Policy. However, Gold Gear will notify the User of such other purposes at or before the time of obtaining the User’s consent, unless processing of the User’s Personal Data without the User’s consent is permitted by Data Protection Laws.

4.3 - Gold Gear’s legal basis to process and use the Personal Data of Users as the Data Controller is where:

(a) Users have given their consent for one or more specific purposes (such as the Purposes).

(b) Data Protection Laws permit a Data Controller to process Personal Data until the User objects to such processing (also known as opting-out), without having to rely on consent or any other legal basis. Note that this does not apply, whenever the processing of Personal Data is subject to the General Data Protection Regulation governing the Personal Data of Users from the European Union;

(c) processing and use of Personal Data is necessary for:

(i) the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

(ii) the establishment, exercise or defence of legal claims or proceedings;

(iii) compliance with a legal and regulatory obligation to which the Data Controller is subject;

(d) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller;

(e) processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third-party; and

(f) where otherwise permitted or not prohibited under Data Protection Laws.

5. DISCLOSURE OF PERSONAL DATA

 

5.1 - Gold Gear may need to disclose the User’s Personal Data to trusted third-parties, whether located within or outside Singapore, for one or more of the Purposes, as such third-parties, would be processing your Personal Data for one or more of the above Purposes (“Third-Party Processors”). In this regard, the User hereby acknowledges, agrees and consents that Gold Gear is permitted to disclose the User’s Personal Data to such Third-Party Processors (whether located within or outside Singapore) for one or more of the above Purposes and for the Third-Party Processors to subsequently collect, use, disclose and/or process the User’s Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing, such Third-Party Processors include:

 

(a) any of Gold Gear’s agents, contractors or third-party service providers that process or will be processing the User’s Personal Data on Gold Gear’s behalf including but not limited to those which provide administrative or other services to Gold Gear;

 

(b) Gold Gear’s professional advisers, for example, Gold Gear’s auditors and lawyers, as well as Gold Gear’s insurers;

 

(c) third-parties to whom disclosure by Gold Gear is for one or more of the Purposes and such third-parties would in turn be collecting and processing the User’s Personal Data for one or more of the Purposes; and

 

(d) any actual or proposed assignee or transferee of the business of Gold Gear, or a merged entity in the event Gold Gear is merged to create the said merged entity.

 

5.2 - Where Gold Gear discloses the User’s Personal Data, Gold Gear will do so only in accordance with Data Protection Laws. This includes taking steps to ensure the security and privacy of the User’s Personal Data, and where required, it will be subject to contractual terms ensuring the security and protection of any Personal Data under any sub-processor or data intermediary, whether within or outside of Singapore.

 

6. PROVISION OF THIRD-PARTY PERSONAL DATA

 

6.1 - The User should only provide Gold Gear with Personal Data of third-parties where expressly permitted by Gold Gear. Should the User provide Gold Gear with Personal Data of any individual other than the User, the User represents, undertakes and warrants to Gold Gear that:

 

(a) for any Personal Data of individuals that the User discloses to Gold Gear, Gold Gear would have prior to disclosing such Personal Data to Gold Gear obtained consent from the individuals whose Personal Data are being disclosed, to:

 

(i) permit the User to disclose the individuals’ Personal Data to Gold Gear for the Purposes; and

 

(ii) permit the User to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes;

 

(b) at Gold Gear’s request, the User will use such form(s) or document(s) provided by Gold Gear in obtaining such consents from the individuals in question (for the avoidance of doubt, Gold Gear is under no obligation to you to create any such form(s) or document(s));

 

(c) any Personal Data of individuals that the User discloses to Gold Gear are accurate; and

 

(d) for any Personal Data of individuals that the User discloses to Gold Gear, that the User is validly acting on behalf of such individuals and that the User has the authority of such individuals to provide their Personal Data to Gold Gear and for Gold Gear to collect, use, disclose and process such Personal Data for the Purposes.

 

6.2 - Should the User provide Gold Gear with Personal Data of the User’s child or children, the User confirms, declares and agrees that the User is the parent and/or legal guardian of such child/children, and that Gold Gear may collect, use and/or disclose the User’s child’s or children’s Personal Data for the Purposes and in the manner as set out in this Privacy Policy.

 

7. SECURITY

 

7.1 - All Personal Data the User has provided to Gold Gear is stored in a cloud-based environment which is highly secure, scalable, and redundant by design. Where Gold Gear has given the User (or where the User has chosen) a password which enables the User to access certain parts of the Website, the User is responsible for keeping this password confidential. The User should not share a password with any other person. Regular patching and security upgrades are performed on the infrastructure components. All publicly accessible endpoints are protected using data encryption security protocols and are enabled with intrusion detection and DDoS protection. Firewall rules are defined for each and every infrastructure component at network and application layer along with IP whitelisting and VPN wherever applicable.

 

7.2 - Data encryption is enabled for storage of data. Direct access to the data storage system is strictly prohibited. Data in flight is always encrypted using HTTPS/SSL/TLS protocols. Logging of PII data, passwords, financial information and other business critical data in log files is strictly prohibited.

 

7.3 - Gold Gear shall do its best to protect the User’s information, but cannot guarantee the security of the User’s Personal Data transmitted on the Website; any transmission is at the User’s own risk and the User agrees not to hold Gold Gear responsible for any breach of security while accessing the internet that is out of Gold Gear’s control.

 

7.4 - In the event of a breach of the confidentiality or security of the User’s information, Gold Gear shall reasonably attempt to notify the User as necessary so that the User can take the appropriate protective steps. Unless the User indicates otherwise, Gold Gear may notify the User under such circumstances using the User’s most current email address on record.

 

8. COOKIES

 

8.1 - The Website uses cookies to distinguish the various Users of the Website. This helps Gold Gear provide the User with the best experience when browsing the Website and also allows Gold Gear to improve the Website. By continuing to browse the Website, the User is hereby agreeing to Gold Gear’s use of cookies.

 

8.2 - A cookie is a small file of letters and numbers that Gold Gear stores on the User’s browser or on the User’s device. Cookies contain that is transferred to the User’s device.

 

8.3 - Gold Gear uses the following cookies:

 

(a) Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable Gold Gear to log into secure areas of the Website, use a shopping cart or make use of e-billing services.

 

(b) Analytical/performance cookies. These cookies allow Gold Gear to recognise and count the number of Users and to see how Users navigate the Website. This helps Gold Gear improve the manner by which the Website is operated, including ensuring that Users are able to conveniently access their required resource and/or service.

 

(c) Functionality cookies. These are used to recognise the User when the User returns to the Website. This enables Gold Gear to personalise its content to the User, to greet the User by name and remember the User’s preferences (for example, the User’s choice of language or region).

 

8.4 - Please note that third-parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which Gold Gear has no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

 

8.5 - The User blocks cookies by activating the setting on the User’s browser that allows the User to refuse the setting of all or some cookies. However, if the User uses browser settings to block all cookies (including essential cookies) the User may not be able to access all or parts of the Website.

 

9. THIRD-PARTY WEBSITES

 

The Website may contain links to other Linked Sites. Gold Gear is not responsible for the privacy policies or practices of such other Linked Sites. The Users are encouraged to read the privacy policies or statements of each Linked Site. The User hereby agrees to waive any claim against Gold Gear with respect to the Linked Sites.

 

10. USERS’ RIGHTS IN RESPECT OF THE PERSONAL DATA

 

10.1 - If the User has any questions about the processing of the User’s Personal Data or about this Privacy Policy, if the User does not accept an amended Privacy Policy, if the User wishes to withdraw any consent the User has given Gold Gear at any time, or if the User wishes to update or have access to the User’s Personal Data, the User is welcome to contact Gold Gear through the contact details listed at the end of this Privacy Policy.

 

10.2 - The User has the right to access and/or correct any Personal Data that Gold Gear hold about the User, subject to exceptions under the law. This right can be exercised at any time by contacting Gold Gear through the contact details listed at the end of this Privacy Policy. Gold Gear will need enough information from the User in order to ascertain the User’s identity as well as the nature of the User’s request, so as to be able to deal with the User’s request. All requests for correction or for access to the User’s Personal Data must be in writing. Gold Gear will endeavour to respond to the User’s request within 30 days, and if that is not possible, Gold Gear will inform the User of the time by which Gold Gear will respond to the User.

 

10.3 - Gold Gear may be prevented by law from complying with any request that the User may make. Gold Gear may also decline any request that the User may make if the law permits Gold Gear to do so.

 

10.4 - In many circumstances, Gold Gear need to use the User’s Personal Data in order for Gold Gear to enable the User’s use of the Website and the Services. If the User does not provide Gold Gear with the required Personal Data, or if the User does not accept an amended Privacy Policy or withdraw the User’s consent to Gold Gear’s use and/or disclosure of the User’s Personal Data for the Purposes, it may not be possible for Gold Gear to continue to enable the User’s use of the Website and the Services.

 

10.5 - Gold Gear may charge the User with a fee for responding to the User’s request for access to the User’s Personal Data which Gold Gear holds, or for information about the ways in which Gold Gear has (or may have) used the User’s Personal Data. If a fee is to be charged, Gold Gear will inform the User of the amount beforehand and respond to the User’s request after payment is received.

 

10.6 - Gold Gear is fully committed to protecting the User’s Personal Data and ensuring that the User is able to enjoy all the rights granted to the User in relation to the User’s Personal Data under Data Protection Laws. Nothing in this Privacy Policy should be construed as limiting any of the User’s rights prescribed for under Data Protection Laws.

11. CHANGES TO THIS PRIVACY POLICY

 

11.1 - Gold Gear reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page and possibly within the Website and/or, as far as technically and legally feasible, sending a notice to Users via any contact information available to Gold Gear. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. It is strongly recommended to review the Website and this Privacy Policy periodically for updates.

 

11.2 - Should the changes affect the processing activities performed on the basis of the User’s consent, Gold Gear shall collect consent from the User, where required.

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