1.                  Sbagliato Pte Ltd (UEN: 201801665G) (“Sbagliato”)

takes its responsibilities stipulated under the Personal Data Protection Act, 2012, Singapore (“PDPA”) seriously. We would like to take this opportunity to state that we recognise the importance of safeguarding the personal data you have provided us and will responsibly manage and protect your data. This Privacy and Data Protection Policy (the “Policy”) details the manner with which we collect, use, disclose and/or process your personal data (including “Personal Data” as defined under the PDPA) you have provided to us. We hope that it will assist you in making an informed decision before providing us with any of your personal data.

2. Sbagliato distinguishes between personal and non-personal data.  Personal data is information that relates to a natural person from which that person’s identity may be directly or indirectly determined; it includes names, addresses and telephone numbers (“Personal Data”).  Non-personal data is that is not personal information.

3.                  Sbagliato uses or otherwise deal with personal data, solely to provide the applicable services and undertake the applicable transactions (“Services”) to you and for no other purposes whatsoever.   When Sbagliato uses or deals with Personal Data, we only use or deal with personal information which is provided voluntarily and obtained in compliance with all applicable laws.  In order for Sbagliato to use Personal Data, the natural person must voluntarily submit it.

4. If you would like to remove or update your personal information in our databases, please contact our Data Protection Officer on [67879660] or email info@sbagliato.sg.  The removal of your personal information is subject to our data retention obligations and requirements under applicable laws.

5.                  Subject to the next clause, Sbagliato requires the natural person’s specific consent before it obtains Personal Data, which may  include the following:

(a)                Government issued identification numbers, including social security, passport and identity card numbers;

(b)               Insurance plan numbers, financial account numbers and similar sensitive financial information;

(c)                Information that describes the precise real-time geographic location of the natural person derived through location-based services such as through GPS-enabled devices; and

(d)               Precise information about past, present, or potential future health or medical conditions or treatments, including genetic, genomic, and family medical history.

6.                  Sbagliato may collect Personal Data in a variety of ways, including, but not limited to, when you join events, activities or courses organised or provided by Sbagliato, subscribe to a newsletter or a mailing list, submit to a competition, and in connection with other Sbagliato activities, services, surveys, market research, publications, events, features, or resources we make available at Sbagliato. You may visit Sbagliato anonymously. We will collect Personal Data from you only if you voluntarily submit such information to us. You can refuse to supply Personal Data but doing so may prevent you from engaging in certain Sbagliato related activities.

7. Sbagliato will notify you of the purposes for which your Personal Data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your Personal Data for the intended purposes, unless an exception under the law permits us to collect and process your Personal Data without your consent.

8. Sbagliato may collect and use your Personal Data for the following purposes (the “Purposes”):

•To improve customer service
Information you provide helps us respond to your customer service requests and support needs more efficiently.

•To personalize user experience
We may use information in the aggregate to understand how our Users as a group use the services and resources provided in by Sbagliato.

•To send periodic emails
We may use your email addresses to send you information and updates on Sbagliato activities, events, publications, surveys, services and programmes. Your email addresses may also be used to respond to your inquiries, questions, or other requests.

Should Sbagliato be required to disclose the Personal Data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the Purposes, Sbagliato will make known any such disclosures to you for your approval and opt-in. In any such cases, the disclosure will be for these third party service providers, agents and/or affiliates or related corporations and/or other third parties to process your personal data either on our behalf or otherwise, for one or more of the Purposes.

9. However, please note that Sbagliato may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :

(a) cases in which the disclosure is required or authorised based on the applicable laws and/or regulations; 
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely manner;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings; 
(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the Personal Data is disclosed to protect Sbagliato’s rights or property;

(g) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(h) where such disclosure without your consent is permitted by the PDPA or by law.

10.                  Sbagliato retains Personal Data collected (in accordance with the previous clause) only as long as necessary to fulfil a legitimate business need, or as required by law.

11.                  Non-personal data is used by Sbagliato solely to provide Services and to improve its Services.

12.                  Cookies are data stored on a user’s hard drive that contain information such as banners seen or sites visited. Sbagliato may use cookies for:

(a)                keeping track of items in the shopping cart. No other data will be collected or tracked by this cookie, which acts purely as a storage facility for the shopping cart;

(b)               keeping track of session variables. This cookie expires at the end of the session. No other data will be collected or tracked by the cookie, which is purely for the management of the variables required for the user to view the site once logged in; and

(c)                other purposes solely for the provision of Sbagliato services.

13.                  Sbagliato does not use cookies to obtain Personal Data.

14. Sbagliato has the discretion to update this Privacy Policy at any time. We encourage you to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

15. By transacting with Sbagliato and/or enrolling in Sbagliato activities, events, competitions, publications, courses, workshops or programmes, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not transact with Sbagliato and/or enrol in Sbagliato activities, events competitions, publications, courses, workshops or programmes. Your continued transactions with Sbagliato and/or enrolment in Sbagliato activities, events competitions, publications, courses, workshops or programmes following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

16.                  If you have any concerns or comments about our policy, please email us on info@sbagliato.sg .