Data Protection Policy

This Data Protection Notice (“Notice”) sets out the basis which OmniShelf PTE LTD (including all of its subsidiaries, brands, related and/or associated companies/brands) (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with  the privacy laws.

This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes. OmniShelf PTE LTD is committed to respecting and protecting your privacy online. This Privacy Policy explains our practices regarding the collection, use, disclosure and transfer of your personal data.

This Privacy Policy is incorporated as part of OmniShelf PTE LTD Terms of Use. Your use of the Platform and/or Service, DRNK web/mobile application is subject to the Terms of Use and this Privacy Policy. Unless specifically defined in this Privacy Policy, the defined terms shall have the same meaning as defined in the Terms of Use.

To process, administer and/or manage your relationship with us, we will necessarily need to collect, use, disclose and/or transfer your personal data.

This Privacy Policy applies to personal data about you (OmniShelf PTE LTD members/users, OmniShelf PTE LTD Partners, business/marketing partners, agents, vendors, distributors, suppliers, contractors, service providers, etc.) and/or individuals provided by you, possessed by us or that we obtain about you, whether now or in the future. We will only process your personal data in accordance with the prevailing personal data protection and privacy laws of the countries we operate in and this Privacy Policy.

If you are a company, an entity or an organization, references to the term “you” and “your” shall also include your employees, representatives and agents.

By giving your consent, you acknowledge that you have read and understood this Data Protection Policy and agree to us collecting and processing your personal data in accordance with the manner as set out in this Data Protection Policy.

We may revise or update this Privacy Policy at any time by posting a revised/an updated version on the www.omnishelf.io/legal-pages/privacy. Unless stated otherwise, any revision or update takes effect immediately.

We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

It is necessary for us to collect and process your personal data. If you do not provide us with your personal data, or do not consent to this Data ProtectionPolicy or any amendments to this policy, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using the Platform and/or Service. Alternatively, for some services you have an option to use a limited scope of our services as anonymized/guest account.

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Personal Data

As used in this Notice:

• “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
• “personal data” means data, whether true or not, about a customer who can be identified:
• from that data; or (b) from that data and other information to which we have or are likely to have access.
• Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your contact information such as your email address or telephone number, nationality, gender, date of birth, photographs and other audio-visual information, and financial information such as credit card numbers or debit card numbers.

Other terms used in this Notice shall have the meanings given to them in the privacy laws (where the context so permits).

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Collection of Personal Data

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the privacy or other laws.

Your personal data may be collected from you during your course of dealing with us in any way or manner including pursuant to any transactions and/or communications made from/with us. We may also collect your personal data from a variety of sources, including without limitation, at any meetings, events, activities, contests, customer satisfaction surveys organized and/or sponsored by us, as well as from publicly available sources such as directories and OmniShelf PTE LTD social media pages, if you follow, like or are a fan of such pages. Further information may also be collected when we exchange communications with you, for example, if you submit a request, file a complaint or contact our support team.

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In addition, we may also receive, store and process your personal data which are provided or made available by any third parties whom you have authorized, credit reference/reporting bodies, regulatory and law enforcement authorities, for reasons including delivery of our Service, performance of conditions of agreements and/or to comply with our legal and regulatory obligations.

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We may collect and use your personal data for any or all of the following purposes:

1. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
2. verifying your identity;
3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
4. managing your relationship with us;
5. processing payment or credit transactions; (In the Future)
6. sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
7. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
8. any other purposes for which you have provided the information;
9. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
10. any other incidental business purposes related to or in connection with the above.

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And more specifically, to:
Where you are a OmniShelf member/user:

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11. to register for a user Account with us;
12. to provide, maintain and improve the Platform and/or Service to you;
13. to fulfil and validate your purchases/coupons;
14. to personalize and improve your user experience with the Platform and/or Service;
15. to provide you with support and handle requests and complaints;
16. to facilitate your participation in, and our administration of, any of our activities including contests, promotions, campaigns, polls or surveys;
17. to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, usage and activity trends analysis in relation to the Platform and/or Service and our users’ demographics (on an anonymised basis);
18. providing you with recommendations of products or services based on the information we collected from you or the other users of the service;
19. to protect and/or enforce our legal rights and interests, including defending any claim;
20. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
21. to detect, investigate and prevent any fraudulent, prohibited or illegal activities or misuse of the Platform and/or Service;
22. to transfer or assign our rights, interests and obligations under any agreements entered into with us;
23. for internal administrative and updating purposes, such as auditing, data analysis, record keeping, contact lists, risk management, security, etc; and/or
24. for our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside your country
25. sending notification to you about any incident regarding your personal information, according to the laws and regulations. For breach notification we will use electronic communication methods to the contact details you have provided to us

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Additional information related to the collection of your personal data are listed below:

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• If any part of the Platform links you to other websites, those websites do not operate under this Privacy Policy and we do not accept any responsibility or liability arising from those websites.
• We use cookies to monitor your use of the Platform. All such demographic data collected through cookies are not personal data and we may use this data in aggregated, statistical and/or anonymized form. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

• In addition to using cookies and related technologies as described above, we may also permit certain third-party companies to help us tailor advertising that we think may be of interest to users and use other data about user activities on our Platform and/or Service. These companies may deliver ads that might also place cookies and otherwise track user behavior, for example Google Analytics, Google Remarketing, Mixpanel and Facebook. We use Google Analytics to collect data about website usage. This data does not include personally identifiable information. You can view the Google Privacy Policy here: www.google.com/policies/privacy/. We use a Facebook pixel to obtain information regarding the activities that users engage in while visiting our web pages. For information on Facebook’s Privacy and Cookie policy, visit https://www.facebook.com/policies/cookies/.  We use a Mixpanel to collect information on how users interact with our platform and applications.  For Mixpanel Privacy Policy visit https://mixpanel.com/legal/privacy-policy/. We use Branch.io to track download conversion from the app stores. For Branch.io Privacy Policy visit  https://branch.io/policies/
• In connection to our services we use third-party service provider MailChimp. We use MailChimp API to send our email communications to you. This data includes your email address. You may view MailChimp privacy policy here: https://mailchimp.com/legal/privacy/
• The Platform and/or Service may integrate with social sharing features and other related tools which allow you to share information with your friends or the public, depending on the settings you establish with the social sharing network. The social sharing network’s use of your personal data is governed by that social sharing network’s privacy policy, not by this Privacy Policy. By connecting your social sharing network account through the Platform and/or Service, you agree that we may collect your personal data from your social sharing network account only in accordance with your privacy settings you have set up under your social sharing network account and for the Purposes provided under this Privacy Policy.
• We may automatically receive, record and store location services information from your computer or mobile device when you interact with us. You hereby consent to our use of anonymized location services information collected from you. Depending on the functionalities available on your computer or mobile device, you may benefit from advanced options to manage the location services information. A computer or mobile device may report its GPS location at the time you interact with us if the location services settings are enabled.
• Our collection of your computer or mobile device location information is solely at your discretion. You can enable or disable location services when you use the Platform and/or Service at any time, through your computer or mobile device settings. You consent to our collection and dissemination of your computer or mobile device location information through the Platform, as specified in this Data Protection Policy.
• Under no circumstances shall we be liable for claims or for any damages therefrom, arising out of your informed decision to allow other users to see your computer or mobile device location information, as specified in this Data ProtectionPolicy.

You agree and consent to us using and processing your personal data for the Purposes as identified in this Privacy Policy.

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Disclosure of Personal Data

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We will not sell, rent, transfer or disclose any of your personal data to any third party without your consent. When transferring your personal data to any of the reasons described below, we will make sure by any means available that your personal data is protected equally according to the privacy laws.  We may disclose some of your personal data:

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• where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
• to third party service providers, agents and other organizations we have engaged to perform any of the functions listed in clauses  above for us.
• to any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our obligations to you;
• any party in relation to legal proceedings or prospective legal proceedings;
• auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us; any party nominated or appointed by us either solely or jointly with other service providers, who provide services or conduct data processing on our behalf, or for data centralization and/or logistics purposes;
• data centers and/or servers located within or outside your country for data storage purposes;
• government agencies, law enforcement agencies, courts, tribunals, regulatory/professional bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any country, if required or authorized to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
• our business/marketing partners, third party product and/or service providers, suppliers, vendors, distributors, contractors or agents, on a need to know basis;
• banks and financial institutions, merchants and credit/debit card companies in connection with your commercial transactions with us;
• the general public when you become a winner in a contest, participate in our events or activities, submit your rating and/or review or other features of the Platform and/or Service that are viewable by the general public without compensation for advertising and publicity purposes;
• any third party (and its advisers/representatives) in connection with any proposed or actual reorganization, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset/share sale relating to all or any portion of our business or in the unlikely event of insolvency, bankruptcy or receivership; and/or
• any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the Purposes or as instructed/authorized by you.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

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Withdrawing Your Consent

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The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing or by deleting your account in our service. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

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If you want to withdraw your consent for direct marketing, you can do this either by submitting your request in writing or changing the relevant setting in your account profile.

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Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (30) business days of receiving it.

In case you delete you account from our service your personal data will be deleted within 30 days.

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Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in this privacy notice.

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Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

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Access To And Correction of Personal Data

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If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

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You may also view and edit your account profile to correct your personal information.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

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We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the privacy laws).

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Protection Of Personal Data

To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures including but not limited to up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis. We are also following strict risk management framework, allowing to address all risks accordingly for the best of your interest.

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You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

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Accuracy of Personal Data

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We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

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Retention of Personal Data

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We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes. If you do not use your account for 12 months, we will consider your account inactive and proceed to delete your personal data.

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Transfer of Personal Data to Singapore

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Our cloud-based storage and servers are located in Singapore or your country of residence. This may include, but not limited to, instances where your personal data may be stored on servers located outside of your country. In addition, your personal data may be disclosed or transferred to entities located outside your country.

We provide our best effort to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the privacy laws.

You hereby expressly consent to us transferring your personal data to Singapore for such purpose.

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Data Protection Officer

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You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner: Name: Marc Giovannini, Title: Data Protection Officer, Email: dpo@omnishelf.io

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Effect of Notice and Changes to Notice

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This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

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