CONNOR Singapore & Malaysia Privacy Policy
Welcome to a website (Site) or store (Store) operated by Connor Clothing Singapore Pte Ltd (UEN 202524206D) or Connor Clothing Malaysia Sdn. Bhd (CRN 202501035216). (“Connor”, we or us).
Protecting the trust of customers and any personal data you provide to us is very important to us. We are committed to protecting your privacy in all your dealings with us. In Singapore, we are bound by the Personal Data Protection Act 2012, while in Malaysia, we are bound by the Personal Data Protection Act 2010,
This Policy outlines how we will treat your personal data where it is received in Singapore or in Malaysia, and explains:
the rights you may have under applicable data protection law
what information we collect
how we collect your information
how we use your information
how and with whom we share your information
how long we keep your information and how it is stored and secured
Our approach to sensitive personal information; and
the rights you may have in relation to your personal information.
“The Country” in this Policy shall refer to either Singapore or Malaysia depending on whether your personal data is collected and processed in Singapore or Malaysia, but shall not refer to both countries at the same time in respect of the same transaction.
1.Your Rights
“Personal data” in the context of this Policy refers to to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual) and sensitive personal data which includes but is not limited to, information pertaining to the physical or mental health or condition of an individual and religious beliefs, or any other sensitive personal data (“sensitive personal data”)
The following is a non-exhaustive summary of the rights you may have in relation to your personal data under applicable data protection law:–
The right to be informed whether personal data pertaining to you shall be, are being or have been processed
The right to be furnished the following information before the entry of your personal data into our processing system, or at the next practical opportunity:
Description of the personal data to be entered into the system or our work processes;
Purposes for which they are being or are to be processed;
Scope and method of the personal data processing;
The recipients or classes of recipients to whom they are or may be disclosed;
Methods utilized for automated access, if the same is allowed by you, and the extent to which such access is authorized;
The identity and contact details of Connor or our representative;
The period for which the personal data will be stored; and
The existence of your rights, i.e., to access, to correct, to request for a copy of, to request to update, and to withdraw (in full or in part) consent to process your personal data held by us, as well as the right to lodge a complaint before the relevant data protection authority.
Any changes to this policy will be notified to you as describe in Section 13 below.
To the extent that the applicable law allows, the right to request for access to, request for a copy of, request to update or correct and withdraw (in full or in part) of your consent given previously) in relations to your personal data held by us.
The right to have reasonable access, by notice in writing, to the following information:Contents of your personal data that were processed;
Sources from which personal data were obtained;
Names and addresses of recipients of the personal data;
Manner by which such personal data were processed;
Reasons for the disclosure of the personal data to recipients;
Information on automated processes where the personal data will or likely to be made as the sole basis for any decision significantly affecting or will affect you;
Date when your personal data were last accessed and modified; and
The designation, or name or identity and address of the data user;
Notwithstanding the foregoing, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data.
The right to dispute the inaccuracy or error in the personal data and have Connor correct it accordingly, unless the request is vexatious or otherwise unreasonable.
The right to request us to suspend, withdraw (in full or in part) or order the blocking, removal or destruction of your personal data from our filing system upon discovery and substantial proof that the personal data are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected. Having received any such requests, we will take reasonable steps to comply with the request as long as it is lawful to do so and without compromising the integrity of our systems.
Upon discovery and substantial proof that the personal data are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected.
2. WHAT INFORMATION MAY WE COLLECT FROM YOU
The personal information we collect may include:
your name;
contact details (either personal, billing or delivery details), including your telephone number, email address, street address, and postal address;
country of residence,, gender and date of birth;
usage data, including the history of your dealings with us over time, including the duration of your visit, types of products and/or services you are searching for and/or your purchases and entry into promotions;
transaction data, including your credit card information;
details from your CV and your employment history, if you apply for a job with us;
photos or videos you provide to us (including through social media);
video surveillance footage in our Store;
marketing and communications data, which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular products or services;
technical data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Site; and
other personal information you might supply to us, such as user-generated content (photos, videos, vlog posts, or social media posts), or when you rate and review our products, or when you engage with us through any social media channels.
3. HOW DO WE COLLECT INFORMATION FROM YOU?
Collection of personal information
We may collect personal information from you via our Site when you:
create an account on our Site
place an order for purchases through our Site
fill in forms on our Site, for example to leave feedback, to enter a competition or respond to a survey;
rate and review products
subscribe to our mailing list; or
contact us via the "Contact Us" form on the Site
We may also collect certain information automatically when you visit our Site through your technical data. In particular:
when you access our Site, we use “cookies” to make it easier for you to use our Site. These cookies record data about the pages you browse and the activities you carried out during your visit. Further details about our use of cookies is set out in our Cookie Policy here
we may record details relating to your access to our site (for example, URL addresses, traffic data, website clicks etc.)
we may record information about the type of device you have used to visit our Site, your device settings and the cause of any system errors. Your device manufacturer or operating system provider will have further details on what information your device makes available
we may obtain your personal data from third parties who are located outside of the Country. These include technical data from analytics providers, advertising networks, social media platforms, and contact and transaction data from providers of technical, payment and delivery services.
We will collect personal information that you provide to us in our Stores when you:
ask us to provide you with an electronic receipt
subscribe to our mailing list; or
enter a competition or respond to a survey
contact us directly by telephone, email, or via social media (for example, when you have queries or when your supply feedback or ratings and reviews).
Some of our Stores may also use video surveillance.
We may collect personal information about you if you apply for a job with us through our Site, in-store or through third party websites such as LinkedIn or recruitment companies.
We will generally collect your personal information directly from you, unless it is impracticable or unreasonable to do so. From time to time we may collect personal information about you from third parties where consent is implied or where other bases for collection is available, for example:
Where you have provided feedback on our stores to Google Maps, we may obtain your personal information and use it to contact you about your feedback
we may collect your information (eg emails, street address, name) from online marketplaces and use it to fulfil orders to you
from publicly available sources.
If you provide us with personal information about a third party you represent, we may collect it on the basis that you have that person’s consent for us to collect and handle their personal information in accordance with this privacy policy. Please be mindful when disclosing any personal data relating to other people to us or to our service providers, as you are responsible for the disclosure of such third-party personal data.
Collection of personal data from young people
If you are under the age of 18, please do not use this Site without a parent or guardian nor provide personal data to us of any kind whatsoever. A parent or guardian may supervise their child provide consent on their behalf to collect and use such personal data in accordance with this Policy.
Social listening
If you actively communicate about us or our brands on social media, we may collect a copy of your communication. For example, if you use hashtag of our brands in relation to one of our items in a public post on a social media platform, we may retain a copy of the public post and may use it for our brand campaigns.
4. HOW WE USE YOUR INFORMATION
We will use, process, and disclose your personal data for the purposes for which we collected it, and for other related purposes that you would reasonably expect. Generally, we may use your personal data in the following ways:
to provide you with an account on our Site, if you choose to sign up for one
to verify your identity
to fulfil any order that you place with us and to collect payment from you
to provide you with a receipt, if you ask us to send this to you electronically
to administer competitions that you have entered
to analyse any feedback that you provide on our services, to respond to your feedback and to improve our service
to respond to any queries
to review and assess any job application that you submit to us
to protect and defend our legal rights and interests
for marketing purposes as described below
programmatic interest-based advertising, where we third party advertisers are permitted to place cookies, pixels, and trackers on our Site to provide you with personalized ads
to administer and monitor our Site, including to ensure that content is presented in the most effective manner for you and for your device, to allow you to participate in interactive features when you choose to, to remind you that you have items in your basket or that a transaction is incomplete, to troubleshoot and improve customer experience, and for fraud analysis and protection.
any other incidental business purposes related to or in connection with the above
We might use your personal data for the above purposes (including marketing purposes) regardless of whether the personal data was collected online, on the phone or in person at our stores.
Any footage of you that is captured by video surveillance is used by us for the purposes of preventing theft or fraud, for traffic counting and for store safety (including protection of staff).
We may also use or disclose your personal data:
for our general business operations (e.g. maintaining business records, billing, complying with our legal and insurance obligations and statistical purposes);
to comply with legal requirements and law enforcement requests;
to investigate or prevent conduct that may be fraudulent or criminal; and
to resolve disputes.
If you do not supply personal data we request from you, we may not be able to complete your transaction, deliver your purchases, provide you with the information you have requested, accept your entry into any promotion or competition, or consider your job application.
5. MARKETING MATERIAL
If you have consented to receive marketing information from us, we may use your personal information in the following ways:
we will process details of your previous transactions and contact you by email with information about goods and services similar to the merchandise you have purchased (however we never store your payment details)
if you provide your mobile telephone number and if you have consented for us to do so, we may contact you with marketing messages which have been tailored to match your preferences
Where we send you marketing messages via email, you may unsubscribe from receiving further e-mails through a link at the bottom of every email we send to you or by logging in to your account on the Site via “Log In > Subscriptions and unticking "Email me updates on New Arrivals, Sale and Offers’’ and clicking save.
Where we send you marketing messages via SMS, you may unsubscribe from receiving further messages by sending the word ‘STOP’ to the number specified in the SMS message or clicking on the link provided in the SMS message, or by logging in to your account on the Site via “Log In > Subscriptions and unticking "SMS me updates on New Arrivals, Sale and Offers’’ and clicking save.
Where we send you marketing messages via web push notifications, you may unsubscribe from receiving further messages through your chosen browser’s settings.
If you want to change the details that you have registered online with us, or would like to amend your subscription preferences you may by logging in to your account on the Site via “Log In > Subscriptions and unticking the relevant fields and clicking save.
If you wish to unsubscribe altogether, please click on the ‘One-Click Unsubscribe’ link at the footer of all marketing email messages from us.
If you no longer wish to receive any marketing communication from us, you can contact Customer Service. A request to opt-out will be handled as promptly as possible. Kindly note that an opt-out request will also not stop transactional emails related to your purchases.
6. DIGITAL MARKETING AND ONLINE ADVERTISING
Where you have consented, we will use your personal information for digital marketing, including targeted marketing on social media and other online platforms. We use digital marketing and targeted advertising services offered by social media platforms including but not limited to Google, Meta (Facebook), Instagram, TikTok and SnapChat, to better tailor our marketing communications and for targeted advertising.
As part of this process, some personal data, such as your email address, is provided to the relevant third party (eg to Google), however for security purposes this data is “hashed” prior to being shared. Hashing is a process of identity masking or “pseudonymisation” which means we do not disclose your email but are able to link your social media presence, or your use of the relevant platform, and our Site . You will then receive our advertising on those platforms.
In this process, your personal information may be transmitted to countries outside of the Country.
We also provide your personal information (such as email address) to Meta and Google so that we may receive insights from Meta and Google about the effectiveness of our advertising campaigns which you experience on our Site and social channels, which helps to better target our advertising.
7. DISCLOSURE AND TRANSFER OF YOUR INFORMATION
7.1 Service providers
We may share your personal information with our core service providers and third party platform providers as required for our business to function. These may include:
delivery service providers who assist us with fulfilling deliveries
third parties we engage to provide IT systems support
data storage suppliers (who may be located overseas)
If you provide ratings and/or reviews, third party ratings and reviews service providers, who will capture your ratings, reviews, photos and videos, which we then use to enhance our customer service and offerings to other customers.
website and IT service providers in order to maintain the functionality of our website and database
If you use our online store, service providers who assist us with the operation of our online store and assist you with your use of it, by for example, sending you an e-mail to remind you that there are items in your basket and prompt you to complete a transaction.
if you are a member of our subscription mailing list, service providers such as marketing partners, to contact you on our behalf to invite you to participate in offers, polls, surveys, analysis or research, all of which assist us in enhancing our services. They are not permitted to use your information after you unsubscribe.
where you have consented to receive digital marketing, to social media and search engine platforms (such as Google, Meta (Facebook and Instagram)) so that we may make use of their digital marketing and targeted advertising services as described above.
We may also share your personal information with:
any entity to which we are required or authorised by law to disclose information (including but not limited to the courts, or government bodies, agencies or departments, government investigative or enforcement agencies);
our professional advisers; and
any person to the extent necessary, in our view in order to carry out any instruction you give to us.
Personal information collected will be sent to data processing facilities overseas, principally in Australia. We will ensure that any data processing facility used are subject to privacy laws that provide comparable safeguards to applicable legislation.Every external company we work with has a contract with us which clearly sets out our expectations and requirements in handling personal information and obligates them to meet the appropriate privacy legislation requirements.
We do not disclose your personal information to unaffiliated third parties for their independent use unless we have obtained your consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal information and to treat it in accordance with the applicable law.
7.2 Overseas disclosure of personal information
Some of our service providers and the third parties described above have servers, or are located in countries other than the Country, The main data processing facility used is in Australia, but other facilities used may be located elsewhere including in Asia, Oceania, USA, UK, and Europe, and your personal information may be disclosed in those countries.
7.3 Overseas transfer of personal information
We may transfer your personal information to countries outside of the Country and if we do so, we will take steps to ensure that your personal information continues to receive a standard of protection that is at least comparable to that provided under the PDPA. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.
8. HOW LONG WE KEEP YOUR INFORMATION
We retain the information you provide only for a period of time that is reasonable in the circumstances, for example:
for as long as you subscribe to receive marketing information;
in the case of any contact you may have with our Customer Care team, for as long as is necessary to provide support-related reports and trend analysis; or
for as long as we are otherwise required to retain it by law.
In any case, we will only retain your personal information until it is no longer required for the use for which it is collected (unless we are required to retain it by law, in which case we will not use it for any purpose other than what is legally required). Once your personal information is no longer required for the use which was collected, it will be securely archived and will not be available to use in our live system. If we receive any request from you to remove your personal data, we will take reasonable steps to comply, as long as it is lawful to do so and without compromising the integrity of our systems.
9. HOW WE STORE AND SECURE YOUR INFORMATION
We will take commercially reasonable steps to store and hold your personal information in a secure and restricted manner and to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. We have the necessary technical and organisational security measures in place, as are appropriate, and these security measures ensure a level of security appropriate to the risk that may arise in the processing of your personal information.
You are responsible for keeping your login information and passwords confidential.
We store and hold personal information electronically and/or in hard copy. Electronic information is kept on secure servers.
Any information relating to credit card details is handled by a PCI DSS compliant third party and encrypted using secure server technology.
Access to your personal information is limited to those individuals who require such access in order to perform their duties and responsibilities.
Any personal information held by a third party storage provider is done so under strict contractual obligations of confidentiality and non-disclosure.
Where you have a password to access certain parts of our Site, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone.
10. HIGHLY SENSITIVE PERSONAL INFORMATION
We do not seek to collect highly sensitive personal information (i.e. information relating to race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual orientation or criminal records). We ask that you do not provide such information to us.
11. ACCESSING AND CORRECTING YOUR INFORMATION
Connor will take reasonable steps to keep your personal information up-to-date, complete and accurate and may, from time to time, ask you to update your details. However we encourage you to update your own details as often as possible. To do this, simply use the login prompt at the top of the homepage of our Site, to login to your account and update your details under the “My Information” section.
You may lodge a request to correct personal information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading, in which case please contact our Privacy Officer. These include the right to request access to your personal information, to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified.
You may request that we provide you with access to the personal information we hold about you. Generally, we will provide you with access, except in limited circumstances where the law permits us to deny access. Any such requests must be made in writing to our Privacy Officer.
12. MANAGING YOUR PERSONAL INFORMATION
12.1 Withdraw or erase your personal information
If you would like to receive a copy of the personal information that Connor has collected from or about you, you can contact Customer Service or the Privacy Officer. You will be asked to verify your identity, including providing your name and email address. Upon request, we will provide you with a summary of any personal information collected and retained by us regarding you. We will only send copies of personal information to the email address on file for the visitor name associated with it. We shall have the right to charge you a reasonable fee for processing and complying with your data access request.
When our collection or processing of your personal data is based on your consent, you may request that we erase your personal information if it's no longer necessary for the purpose for which it was collected or used, or when we are no longer legally permitted to use it. 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 thirty (30) business days of receiving it. A request to erase your personal information will be dealt with as described in section 8.
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.
In certain circumstances, it may not be possible for us to accept your request, for example where use of the information is necessary to comply with a legal obligation, or if use is necessary for the performance of a contract. Any such request must be made in writing to our Privacy Officer at contactus@connor.com.sg.
12.2 No Sale of Personal Data
At Connor, we do not share your personal information directly with third parties for their own marketing purposes in exchange for monetary consideration.
13. CHANGES TO THIS POLICY
We may change this Policy from time to time. If we make changes, we will publish the updated version on our Site with a revised publication date. If the changes are significant, we may add a statement to the homepage of the Site or send you an email with the update.
Please check this Policy regularly to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of our Site and service constitutes your acknowledgement and acceptance of such changes.
14. CONTACTING US AND COMPLAINTS
If you have any questions about this Policy or how we collect, use and disclose your personal information, or if you have any queries or complaints about the way that we have handled your personal information, please contact our relevant Privacy Officer or representative at the following details:
The Privacy Officer – Connor Clothing Singapore
Mailing Address: 55 Mentmore Ave, Rosebery NSW 2018, Australia
Email: contactus@connor.com.sg
Phone:+61296990888
The Privacy Officer – Connor Clothing Malaysia
Mailing Address: 55 Mentmore Ave, Rosebery NSW 2018, Australia
Email: contactus@connor.com.sg
Phone:+61296990888
All complaints are reviewed and considered by our Privacy Officer. We will generally respond to complaints within 30 days.
If you are not satisfied with the result of your complaint, you can refer your complaint to the Personal Data Protection Commission (Singapore) or Personal Data Protection Department (Malaysia).