xoxojstar Privacy Policy and Cookies Policy

Last Updated: 22 September 2022

This privacy and cookies policy has been compiled to inform you how xoxojstar (referred to herein as “xoxojstar”, “we”, “us” or “our”) collects, uses, discloses or shares Personal Data (as defined below).  This policy (“Policy”) applies to information we collect about visits and visitors to our Sites, uses and users of our Sites and Services, and people who provide their emails and other personal information to us.

This Policy forms a part of our Terms of Use.  Defined terms used in this Policy have the same meaning as defined in the Terms of Use.  If you have not yet read our Terms of Use, please do so.

1. Personal Data

”Personal Data”, refers to data, whether true or not, that can be used on its own or with other information that we have or is likely to have access to, to identify an individual. 

Please read this Policy carefully to get a clear understanding of how we collect, use, protect, share, disclose or otherwise handle Personal Data.

2. You Consent to the Collection, Use and Disclosure of your Personal Data

By using the Site(s) or Services, interacting with us, submitting information to us or signing up for any promotions, newsletters or services offered by us or third parties on our Sites and/or Services, you agree and consent to Big Secret Life, as well as our representatives collecting, using, disclosing, transferring and/or sharing your Personal Data in the manner and for the purposes  set out in this Policy, including disclosing, in some circumstances, such personal data to our authorised service providers and relevant third parties. 

3. How We Collect Your Information

3.1 We will obtain personal data about you when you:

(a) visit the Site(s) or use the Services(s), through the use of cookies and similar tracking devices. For example, we may monitor the number of times you visit our Site(s) or which pages you go to. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.  Please see further the section on “Our Use of Cookies” below;

(b) create an account or register your details on our Sites or Services, if we provide you with the ability to do the same from time to time;

(c) complete transactions or purchase orders, requests or applications for any products or services that may be made available by us or any third parties on our Sites or Services;

(d) communicate with us directly in relation to the Sites and/or Services, any products or services that may be made available by us or any third parties on our Sites or Services;

(e) enter or interact with us during promotions, competitions, contests, lucky draws, live streams or special events;

(f) subscribe to any loyalty or membership programmes or newsletter; or

(g) if you are a candidate for employment, when you complete forms in relation to the recruitment and selection process for the purpose of assessment. We may also collect information about you from your nominated referees where you have authorised us to do so.

3.2 If you provide us with the information of another person, then you take full responsibility for doing so, and represent that you are authorised to do so.

3.3 You also represent and warrant that all information that you provide to us is true, accurate and complete.

4. Purposes of Collection of Personal Data

4.1 We may use Personal Data collected for the following purposes:

(a) to provide and personalise our Site and Services or their contents for you, verify your identify and personal particulars, and/or verify your payment for and to deliver products and services which you may purchase or acquire from time to time;

(b) to send you newsletters, and contact you about products, events and services we think may be of interest to you from us or any third party (via any direct marketing channel such as email).  You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us;

(c) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Big Secret Life or other third parties;

(d) to keep our Site(s) and Services secure and prevent fraud;

(e) to verify compliance with the terms and conditions governing the use of our Sites, Services or other products and services;

(f) to communicate with you for any reason whatsoever;

(g) to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;

(h) to award points in a loyalty or rewards programme;

(i) for internal administrative purposes;

(j) to monitor, review and improve our Sites, Services, events and promotions, products and/or services;

(k) to administer and give effect to your transactions with us, including for audit, risk management and security purposes;

(l) to process and analyse your Personal Data either individually or collectively with other individuals;

(m) to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our Sites, Services and other products and/or services;

(n) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;

(o) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;

(p) to transfer or assign our rights, interests and obligations under any agreements entered into with us;

(q) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us; and/or

(r) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations.

4.2 If you agree to us providing you with the information set out in paragraph (a) above, you can always opt out at a later date. 

4.3 By submitting your email you consent to the use of that email as set out in this Policy.

4.4 We may request for or require you to verify your identity when you register for an account (if the same is made available from time to time) with us, when you wish to complete a transaction on our Site(s) or using our Services, or at any time we may deem reasonably necessary in order to fulfil our legal obligations, to facilitate our fraud prevention efforts or to protect our rights.  You also agree and authorise us to take steps to verify your identity and your legal capacity and ability to enter into transactions using the Site(s) and the Services.

4.5 In relation to particular products or services or in your interactions with us, we may from time to time specifically notify you of other purposes for which we collect, use or disclose your Personal Data. If so, then you consent to the collection, use and disclosure of your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

5. Disclosure of Personal Data

You consent to the disclosure of your Personal Data to the following, as may be reasonably necessary under the circumstances, and from time to time:

(a) xoxojstar’s subsidiaries, holding company, the subsidiaries of its holding company or its affiliates;

(b) Third parties which provide services to us, such as payment gateway service providers, ecommerce platform and shop service providers, network service providers, and cloud storage service providers, whether they are located in Singapore or elsewhere;

(c) Business partners who jointly organize, sponsor or hold contests, prizes, events with us or on our behalf;

(d) Our professional advisers or consultants including but not limited to banks, auditors, corporate finance advisers, business advisers, IT consultants, security consultants, lawyers and/or accountants;

(e) Third parties which may acquire xoxojstar and/or our business assets or invest in xoxojstar, and/or which undertake investigations into the business, legal or financial affairs of Big Secret Life and/or its subsidiaries, holding company, the subsidiaries of its holding company or its affiliates, whether pursuant to a merger, acquisition, consolidation or re-structuring of Big Secret Life, and/or its subsidiaries, holding company, the subsidiaries of its holding company or its affiliates or otherwise;

(f) any government, statutory body, regulatory authority or law enforcement agency, whether in Singapore or otherwise; and/pr

(g) any other party you may consent to.

6. Do Not Call Registry

If you have registered your telephone number with the national Do Not Call (DNC) registry, we will not send you promotional and marketing messages via your telephone number unless you have provided us consent to do so.  

7. Our Use Of Cookies 

Cookies are text files placed on your device to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the Sites or Services and to compile statistical reports on activity on the Sites or Services.  You can set your browser not to accept cookies and you can remove cookies from your browser. However, there may be cases some features on our Sites or Services may not function if you remove cookies from your browser.  Please note that advertisements or other third party material may contain cookies over which we have no control.

8. Security and Protection of Your Information 

We are committed to maintaining the security of Personal Data. We have put in place reasonable security procedures and technical and organisational measures to safeguard your Personal Data such as firewalls.  However, no method of transmission over the Internet, or method of electronic storage, can be 100% secure.  Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its security.

9. Access To Your Information And Updating And Correcting Your Information 

Subject to the exceptions referred to in Section 21(2) of the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”), you have the right to request a copy of the Personal Data that we hold about you and information about the ways in which the Personal Data that we hold about you has been or may have been used or disclosed by us within a year before the date of your request.  If you would like a copy of some or all of your Personal Data, please contact our Personal Data Protection Officer.  

10. Maintaining the Accuracy of Personal Data

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address, name or payment details, or if you wish to cancel your account, please let us know the correct details by sending an email to our Personal Data Protection Officer. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information that is inaccurate. 

11. Non-Disclosure And Exceptions To Non-Disclosure 

We do not sell, trade, or otherwise transfer to third parties your Personal Data. This does not include (a) our subsidiaries, the subsidiaries of our holding company or associate companies, or (b) trusted third parties who assist us in operating the Sites or Services, conducting our business, or servicing you, as long as these parties agree not to transfer your Personal Data.

We reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights; to comply with a judicial proceeding, court order, or legal process served on us; or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the Personal Data pertains.  We may also release your Personal Data when we believe release is appropriate to protect our property or safety, or any third parties’.

Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

12. Withdrawal of Consent

If you wish to stop using the Sites and the Services and withdraw your consent to our use of your Personal Data, please email our Personal Data Protection Officer.  Please note that the withdrawal of your consent may result in xoxojstar unable to provide the Sites and Services to you, and does not excuse you from any legally binding obligations that you have entered into prior to the withdrawal of your consent.

13. Links To Other Websites

Our Sites and Services may contain hyperlinks and details of, other websites or applications. This Policy only applies to the Sites and Services so when you link to other websites or use other applications you should read the terms of use and privacy policies of those websites or applications.

14. Sale Of Business

If xoxojstar’s business is sold or integrated with another business your Personal Data may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

15. Period Of Retention Of Your Personal Data

We review the Personal Data we hold on a regular basis to determine if the data is still needed for the purposes it was collected or for legal purposes. We may continue to retain your Personal Data even after you delete your account with us, or you have completed your intended transactions using our Sites or Services.

16. Transfer Of Your Personal Data Overseas

If we transfer Personal Data overseas, we will take appropriate steps to ensure that we will comply with the PDPA in respect of the transferred personal data while such Personal Data remains in our possession or control; and if the Personal Data is transferred to a recipient in a country or territory outside Singapore, that the recipient is bound by legally enforceable obligations to provide to the Personal Data transferred a standard of protection that is comparable to that under the PDPA.

17. Changes To This Policy

We keep this Policy under regular review. If we change this Policy we will post the changes on the Sites and/or Services, so that you may be aware of the information we collect and how we use it at all times. This Policy was last updated on the date stated at the start of this Policy. 

18. How To Contact Us 

We welcome your views about our Sites, Services and this Policy. If you would like to contact us with any queries or comments please send an email to the Data Protection Officer at privacy@bigsecretlife.com.