Privacy Policy

Privacy Policy

4. HOW WE COLLECT PERSONAL DATA

4.1 Brillar Co collects Personal Data in a number of ways, including but not limited to the following instances:

• • when you request information concerning a product of interest to you, make other enquiries or place an order for our products or services;
  • when you interact with us such as with our staff, financial representatives or agents during site visits, or through your access and use of the Site, or through email or otherwise;
  • when you purchase Brillar Co products and/or service;
  • when you attend an event, enter a competition or participate in a promotion or campaign organised or run by us or our Associates, Affiliates, Financial Representatives or Agents;
  • when you enter your personal details on our Site, when you provide information in documents or other manner;
  • when you provide feedback (if any) on our products or services, or when you complete any application forms, purchase orders, questionnaires or surveys, or participate in our campaigns or any competitions;
  • when you engage with us by social media, such as by posting on our Facebook page;
  • from third parties such as our related Companies, Associates, Affiliates, Financial Representatives or Agents;
  • from sources of information which are available to the public;
  • from records relating to the use Brillar Co products and service or that of our Associates, Affiliates, Representatives or Agents;
  • when you provide us with your Personal Data; and
  • from our other Sites (if any).

4.2 Any information which is not capable of identifying you, such as the number of users visiting this Site, is collected through code embedded in the pages of this Site. You are unable to disable the code on these pages.

4.3 Other information, such as browser type, is included in a “cookie”. Cookies are pieces of information that a website can transfer to an individual’s computer hard drive for record keeping. Cookies make using our Site easier by storing information about your choices on a particular website. This will enable you to take full advantage of the services offered to you. The use of cookies is an industry standard utilised by most major websites. Most Internet browsers are set to accept cookies. If you would prefer not to receive cookies you are able to adjust your Internet browser to disable cookies or to warn you when cookies are being used.

4.4 We may use cookies to identify you from other users on the Site. As mentioned above, a cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. You can block or deactivate cookies in your browser settings. We use log-in cookies in order to remember you when you have logged in for a seamless experience. We use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information. The Site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Site and ways that we can improve your experience. These cookies may track things such as how long you spend on the Site and the pages that you visit so we can continue to produce engaging content.

For clarity, Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

By continuing to use the Site, you are agreeing to the use of cookies on the Site as outlined above. However, please note that we have no control over the cookies used by third parties. For further information on types of cookies and how they work visit www.allaboutcookies.org.

4.5 We may use flash cookies. “Flash Cookies” (also called Local Shared Objects or “LSOs”) are data files similar to cookies, except that they can store more complex data. Flash Cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.

4.6 We may use web beacons. Web beacons are small graphic images on a web page or in an email that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of email marketing campaigns.

We may use analytics tags. If so, we use analytical tags to analyse what our customers like to do and the effectiveness of our features and advertising. They can also help us customize your Site browsing experience. We may use information collected through analytical tags or tracked links in combination with your Personal Data for the Purposes. We may also combine Personal Data you provide to us with other of your Personal Data for the Purposes stated herein.

4.7 This Site may in future include hyperlinks that enable you to access a number of other websites and/or future online applications to be operated by Brillar Co or by our related Companies, Associates, Affiliates, Financial Representatives or Agents. These other Brillar Co or associated websites and/or online applications are subject to their specific Privacy Policy and if there is none, then they are subject to this Privacy Policy.

Where this Site may include hyperlinks to third party websites not operated by Brillar Co, we recommend that you read the Privacy and Security Policy or Provisions relevant to those sites so that you understand clearly how those Third Parties will deal with your Personal Data. We are not responsible for the content or privacy practices of those third party sites.

5. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF YOUR PERSONAL DATA

5.1 Brillar Co will/may collect, use, disclose and/or process your Personal Data for one or more of the following purposes:

1. 1. administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Site, including identifying you for login to the Site, our portals and other online services provided by or on behalf of us by Associates, Affiliates, Financial Representatives, Agents or Third Parties. Without limiting the generality of the foregoing, if you:
      1. gain access to or sign in to the Site, using your login credentials of a Social Networking Site, or
      2. use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Site, it may result in information or your personal data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your Personal Data;
   2. monitoring, processing and/or tracking your use of the Site in order to provide you with a seamless experience, facilitating or administering your use of the Site, and/or to assist us in improving your experience in using the Site;
   3. assessing and processing your request for the purchase of and/or subscription to our products and/or services;
   4. registering you as a customer of Brillar Co and/or to facilitate your transactions or activities on the Site, or your transactions or activities with us;
   5. processing any payment relating to your purchase of our products and/or services;
   6. administering, facilitating, processing and/or dealing with your relationship with us, any transactions or activities carried out by you on the Site. This includes processing your application and transactions; implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a purchase or require a product or service to be delivered to a third party recipient, you consent to us disclosing personal data that identifies you, to the said third party recipient (such as but not limited to your name).
      Further, you acknowledge and agree that any such delivery could involve disclosure of certain personal data about you to bring about delivery of the same such as your name and contact details, which may be disclosed on the cover of the parcel, on an envelope or a delivery related document, as the case may be, which could be seen by third parties who view such parcel, envelope or said document;
   7. carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your enquiries and complaints; or responding to or dealing with your interactions with us;
   8. contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Site, your interactions with us, your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
   9. providing services to you, as our customer, as a member of our loyalty or other program(s) or campaign(s) or when requested by you; dealing with or administering your participation in any campaigns, contests, gamification or social events that may be organized by us;
   10. sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively “Feedback”) that you provide through Social Networking Sites, to the Site or to us, with other users of the Site or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business, products or services of Brillar Co, their Associates, Affiliates, Financial Representatives, Agents or Third Parties.
   11. and/or to market to potential customers and/or acquire customers, and/or for the purpose of providing feedback to the public or our Associates, Affiliates, Financial Representatives, Agents or Third Parties.
   12. with your Feedback which may be useful for the public’s purchasing decision or for the public’s information or otherwise.
       This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our Associates’ or Affiliates’) Annual Reports (if any) etc., and/or incorporated as part of Brillar Co’s marketing collaterals/materials or corporate video (if any) to be disclosed to the public, and you hereby consent to the same. Do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately email to us at contact@parentstepbystep.com and head the subject of your email with the word “Confidential Feedback”;
   13. understanding your interests, concerns and preferences;
   14. to comply with or enforce the terms and conditions of any contract or agreement entered into by or on behalf of Brillar Co (and/or its associated entity) to which Brillar Co (and/or its associated entity) is otherwise bound or is obliged to observe, including with our Associates, Affiliates, Financial Representatives, Agents or Third Parties;
   15. identifying you and assisting you in your use of our products, services and website services and the products, services and website services of our Associates, Affiliates, Financial Representatives, Agents or Third Parties;
   16. for marketing purpose and in this regard, we would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including those of our Associates, Affiliates, Financial Representatives, Agents or third party organisations with which Brillar Co may collaborate with) that Brillar Co (including its said Associates, Affiliates, Financial Representatives or Agents) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future:
       1. by way of postal mail, electronic transmission to your email address(es), push notifications, other forms of in-app notifications or harnessing other technologies (such as geo-location technology) for our or third party’s future mobile application(s) (“App”) (if any) on your mobile device(s) or other technologies on your computers, and/or through other modes of communication that is not the 3 DNC Modes, in compliance with applicable local data protection law (i.e. the PDPA). You may opt out of this or withdraw from this at any time by sending an email to contact@parentstepbystep.com. For the avoidance of doubt, the application of or your acceptance of or your consent to, this Privacy Policy, constitutes your consent to this subparagraph (i);
       2. if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of applicable local data protection law (i.e. the PDPA); and/or
       3. Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, Brillar Co reserves its right to send a specified fax message (as defined in Singapore’s Personal Data Protection (Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified text message (as defined in the Exemption Order) (i.e. a marketing fax message or marketing text message) to your Singapore telephone number, if :
          1. there is an ongoing relationship between Brillar Co and you and the purpose of the message is related to the subject of the ongoing relationship, pursuant to the requirements and conditions of the Exemption Order; or
          2. the law permits.For the avoidance of doubt, this sub-paragraph is without prejudice to subparagraph [(r)] below for which you have hereby consented to us contacting you for a survey (if any), which you may subsequently opt out of by sending email to contact@parentstepbystep.com;
   17. carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations (whether in Singapore or a foreign country) applicable to us or our Associates, Affiliates, Financial Representatives or Agents, the requirements or guidelines of governmental authorities (whether Singapore or foreign country) which we determine are applicable to us or our Associates, Affiliates, Financial Representatives or Agents, and/or our risk management procedures that may be required by law (whether Singapore or foreign country) or that may have been put in place by us or our Associates, Affiliates, Financial Representatives or Agents;
   18. to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating feedback and complaints;
   19. complying with or as required by any applicable Law, Court Order, Order of a regulatory body, governmental or regulatory requirements, of any jurisdiction applicable to us or our Associates, Affiliates, Financial Representatives or Agents, including meeting the requirements to make disclosure under the requirements of any law binding on us or our Associates, Affiliates, Financial Representatives or Agents, and/or for the purposes of any guidelines issued by legal, regulatory, investigative or other authorities (whether of Singapore or elsewhere), with which we or our Associates, Affiliates, Financial Representatives or Agents are required or expected to comply;
   20. complying with or as required by any request or direction of any governmental authority (whether Singapore or foreign country) which we are required or expected to comply with; or responding to requests for information from Public Agencies, Ministries, Statutory Boards or other similar authorities (whether Singapore or foreign country). For the avoidance of doubt, this means that we may/will disclose your Personal Data to such parties upon their request, direction or order;
   21. conducting research (including customer research), surveys, market surveys, analysis and/or development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities, or to improve our understanding of your interests, concerns and preferences, in order to enhance any continued interaction between yourself and us connected or in relation to the Site, or improve any of our products or services. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face or phone interview survey, by way of email or postal mail;
   22. storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
   23. facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Brillar Co or that of its affiliates/related corporations;
   24. to create reports with respect to our transactions with you, and/or producing statistics and research of such transactions for internal and/or statutory reporting and/or record-keeping requirements;
   25. maintaining and developing our business systems and infrastructure including testing and upgrading of these systems;
   26. dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves Brillar Co as a participant or involves only a related corporation or affiliated company of Brillar Co as a participant or involves Brillar Co and/or any one or more of Brillar Co’s related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
   27. anonymization of your personal data. In this regard, you acknowledge that personal data that has been anonymized is no longer personal data and the requirements of applicable local data protection law (i.e. the PDPA) would no longer apply to such anonymized data;
   28. Brillar Co, Brillar Co Group Companies’ or Brillar Co’s parent corporation’s reporting purposes including but not limited to reporting on Brillar Co’s business performance (“Brillar Co Group Companies” means Brillar Co, its affiliates, related corporations and associated companies globally); including producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of Brillar Co or of its affiliates/related corporations; and/or

(the purposes set out above shall be collectively referred to as the “Purposes”).

5.2 With respect to the marketing purpose above, you may notify us at any time that you no longer wish to receive any of these marketing communications and opt out of receiving the particular communication by responding via the channel in which you received the marketing communication, or by contacting us at the contact address given below. If you have installed a mobile application and you want to stop receiving push notifications, you can do so by changing the settings on your mobile phone or in the mobile application.

5.3 For the avoidance of doubt, you acknowledge and consent to Brillar Co sharing anonymised information with third parties. For the further avoidance of doubt, applicable local data protection law (i.e. the PDPA) does not apply to anonymised data that does Brillar Co not identify an individual and applicable local data protection law (i.e. the PDPA) does not provide you with a right to object to an organisation handling or processing anonymised data.

5.4 Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Brillar Co Pte Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Brillar Co Pte Ltd may process your Personal Data because:

1. 1. We need to perform a contract with you,
   2. You have given us permission to do so,
   3. The processing is in our legitimate interests and it is not overridden by your rights,
   4. To comply with the law.

12. GENERAL

12.1 Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you provided to Brillar Co with regard to collecting, storing, sharing or processing of your Personal Data for the Purposes herein.

12.2 For the avoidance of doubt, in the event that applicable local data protection Law permits an organisation such as us to collect, use or disclose your Personal Data without your consent, such permission granted by the Law shall continue to apply.