We at The Whisky Social Pte. Ltd. understand that you, our users, care about how your personal information is collected, used and shared. Please take a moment to read this personal data and privacy policy (“Policy”) to understand how we may collect, use and disclose personal data which is subject to the Personal Data Protection Act (No. 26 of 2012) of Singapore for use of products and services (the “Services“) we offer at www.themaltaffair.com and any subdomain and/or subpage thereof (“The Malt Affair“).  This Policy is supplemental to, and should be read in conjunction with, our Terms of Use, which is accessible at www.themaltaffair.com/terms-and-conditions.

 

1. Consent

By accessing The Malt Affair, accessing/using the Services and/or providing personal data to us, you hereby acknowledge that you have read this Policy and that you consent to our collection, use and disclosure of your personal data in accordance with this Policy. If you do not consent to the terms of this Policy, please do not access The Malt Affair, access/use the Services or provide your personal data to us.

The Services are provided only to persons above the age of 18. We do not knowingly collect or solicit personal data from persons below the age of 18. If you are below the age of 18, please do not access The Malt Affair or access/use the Services or send any personal data to us.

This Policy supplements but does not supersede, terminate or replace any other consents you may have previously provided in respect of your personal data. Any consents provided to us are in addition to any rights to which we may have at law to collect, use and disclose your personal data.

If you provide us with any personal data relating to a third party (such as your spouse, children, relatives, employees etc), by submitting such personal data to us, you also represent to us that you have notified such third party of the terms of this Policy and obtained his/her/their consent thereto.

 

2. What is Personal Data?

“Personal data” means data about a person who can be identified (i) from that data, or (ii) from that data and other information to which we have or are likely to have access.

 

3. What personal data do we collect?

We may collect various types of personal data from you in the course of our providing the Services.

Data that is voluntarily provided – we collect personal data that you voluntarily provide to us. This may be through The Malt Affair or other platforms or channels (such as through social media, email, telephone and other forms of communication). On The Malt Affair, or in the course of your access/use of the Services, you may be required to provide personal data such as your full name, telephone number, email address, country of residence, address, credit card details or other personal information, in order to receive the full benefit of the Services. For instance, we may collect personal data when you purchase products from our online store, enter a contest or promotion, participate in a survey, fill up a form, provide comments, suggestions or feedback, attend an event organised by us, or when you contact us via social media, email, phone or other channels. You are not obliged to provide any personal data to us, but in such cases, we may not be in a position to provide the Services to you.

Data that is sent automatically – we collect data that is sent automatically by your web browser, computer, mobile or tablet device when you access The Malt Affair. This may include your IP address, the address of the web page you were visiting when you accessed The Malt Affair, date and time of your visit, information about the device you are using, details on your social media accounts and other information.  Please check the settings of your browser and/or device if you want to know what data is automatically sent or if you wish to change your settings.  Please also refer to the section on “Use of tracking technologies” below.

 

4. How do we use your data?

Generally, we collect personal data in order to better understand our users, to personalise and improve the quality of our services and your user experience with us.

Personal data collected may be used:

(a) to respond to, process and handle your queries, feedback and suggestions;

(b) to verify your identity, process payments as well as manage, develop, maintain and improve our administrative and business operations;

(c) to better understand our users’ behavior;

(d) to inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;

(e) to conduct marketing research, user profile and statistical analysis;

(f) to customise your online experience according to your chosen interests and preferences and enhance your current and future visits to The Malt Affair or any social media platforms;

(g) to update and back-up our records;

(h) to comply with applicable law and regulations, codes of practice or guidelines, policies, procedures, regulatory requirements, the requests of law enforcement and regulatory officials, or orders of court;

(i) to enforce our legal rights and remedies; or

(j) for such other purposes notified to you on or before collection or use of the personal data.

 

5. Who do we disclose your data to?

We do not sell, trade or rent your personal data. Your personal data will not be disclosed by TWS to any third party, except to:

(a) respond to, process and handle your queries, feedback and suggestions;

(b) any of our affiliates, subsidiaries or partners;

(c) our technology, marketing and logistics service providers;

(d) our lawyers, auditors, professional advisors and investors; or

(e) any other service providers, agents, or subcontractors acting for or on behalf of us,

to the extent required to carry out the purposes set out in Section 4 above, or to perform any action at your request.

We may also disclose your personal data where you expressly consent to such disclosure or where such disclosure is required or permitted by applicable law, regulation, rule, direction, guideline, regulatory or governmental order or court order or any other similar requirement.

Recipients of your personal data may be located outside Singapore. You understand, acknowledge and agree that your personal data may be required to be transferred outside of Singapore in order for us to provide the Services to you, and that you request and consent to our so transferring your personal data outside of Singapore. Personal data may therefore be exported to, processed and accessed in countries whose laws provide a different level of protection, which may not necessarily be comparable to that provided in Singapore.

For the avoidance of doubt, we may disclose statistical, sales and other data which is collected from persons who access The Malt Affair, access/or use the Services or any of our social media platforms to prospective partners, sponsors, advertisers or other reputable third parties for lawful purposes. However, this data will not include personal data which may be used to identify you.

 

6. How long do we retain your data? Personal data you provide will be retained as long as the purpose for which the data was collected continues. Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you, unless the retention of such data is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests.

 

7. Is your data secure?

We understand the importance of keeping your personal data private and secure. We therefore have in place security arrangements to protect your privacy and personal data, in a manner that we believe is in line with generally accepted industry standards to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, please be aware that no security measures are impenetrable, and no information electronically stored or transmitted over the internet can be 100% secure. Unauthorised entry or use, hardware or software failure and other factors may compromise the security of your personal data.

While we will endeavour to take all commercially reasonable measures to protect your personal information or private communications, we cannot warrant or guarantee in any way that such information will always remain private and/or safe. We hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any personal data held or maintained by us, except to the extent caused by our gross negligence.

 

8. Linked Sites

We may provide hyperlinks to other websites or social media (“Links“) that we believe are of relevance and interest to you. We have no control over, and are not responsible for any privacy practices or content of such Links, and you hereby waive any claim against us with respect to such Links.

 

9. Use of tracking technology

In order to improve our products and services, we collect data using tracking technology. Such technology provides us with information such as the number of visits, average time spent, page views and other statistics relating to a visitor’s access to The Malt Affair. This information in turn allows us to better administer, improve and tailor content and services provided on The Malt Affair and our social media platforms. Tracking technology does not access, receive or collect information which are capable of identifying users. Some examples of tracking technology which we may use on The Malt Affair are as follows:

(a) Cookies. A cookie is a small data file sent from The Malt Affair and is stored on your computer’s or device’s hard drive. Each time you visit The Malt Affair from the same computer or device, the cookie will be retrieved from your computer or device, enabling The Malt Affair to recognise your computer or device as having previously visited it, thereby increasing functionality (such as allowing The Malt Affair to display content based on your past activity and preferences, to measure web traffic and regularity of visits). The use of cookies does not allow us to retrieve data from your computer or device, to obtain your email address or any other data that can be traced to you personally. Your computer or device can be configured to notify you when you receive a cookie or to prevent cookies from being sent. If you do so, you may limit the functionality of the Services.

(b) Clear gifs. We employ a software technology called clear gifs (a.k.a. web beacons or web bugs) to help us better manage content on our Services by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.

(c) Flash cookies. We use Flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences on our Services. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

 

10. Data disclosure to Stripe Payments Singapore Pte. Ltd. and/or PayPal Pte. Ltd.

We currently leverage on payment services provided by Stripe Payments Singapore Pte. Ltd. and PayPal Pte. Ltd. As such, there may be circumstances under which your personal data may be disclosed to Stripe Payments Singapore Pte. Ltd. and/or PayPal Pte. Ltd. and their related corporations, including facilitating payments made in connection with the provision of the Services.

We encourage you to read Stripe Payments Singapore Pte. Ltd.’s and PayPal Pte. Ltd.'s privacy policies and terms of use, which can be assessed at https://stripe.com/sg and https://www.paypal.com/sg/home respectively, should you have any concerns about how your personal data is used by Stripe Payments Singapore Pte. Ltd. and PayPal Pte. Ltd.

 

11. Questions or Concerns

Please direct any questions or concerns that you may have regarding our handling of your personal data to:

Email: info@themaltaffair.com

Please provide your name, contact number, email address and all relevant details along with your question or concern, so that we can review and respond to your question or concern in an efficient and effective manner.

 

12. Right to amend Policy

We reserve the right to amend the Policy at our absolute discretion, and will post any such amended Policy on this webpage. By continuing to use the Services, you shall be deemed to have agreed to comply with, and be bound by, any such amended Policy.