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Privacy Policy

Privacy Policy

Effective date: October 17, 2019


1.1 This Privacy Policy (“Privacy Policy”) is issued by Brillar Co Pte Ltd, (UEN No. 201902079R) and its related, associated or affiliated companies (individually or collectively referred to as “Brillar“, “we”, “our“ or “us”). This Privacy Policy applies to the products, services and/or website(s) provided by Brillar Co.

1.2 Brillar Co is committed to protecting your privacy and Personal Data (as defined in Singapore’s Personal Data Protection Act (“PDPA”). This Privacy Policy explains how we collect, use,disclose and/or process your Personal Data and the choices you have associated with the collection, use, disclosure and processing of your Personal Data. This Privacy Policy should be read in conjunction with the Brillar Co Terms and Conditions at the Site.

1.3 Brillar Co reserves the right to amend and we may amend this Privacy Policy from time to time. We will notify you of any changes to the Privacy Policy by publishing the updated Privacy Policy on our Site at .

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Please check the Site or send your request by email to  if you would like to receive the latest updated Privacy Policy. Our “Site(s)” are our Websites and online applications.



Service is the website owned and operated by Brillar Co Pte Ltd and the products and services stated in the Website (“the Site”).

Personal Data

Personal Data means data about a living individual in Singapore who can be identified from those Data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is Data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


Cookies are small files stored on your device (computer, tablet or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data or information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the Personal Data on behalf of the Data Controller.

We may use the services of various Service Providers and/or Third Parties, Associates and Affiliates in order to process your Personal Data effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data under the PDPA.


3.1 Generally, the Personal Data we collect, use, disclose, process and/or store include your name, address (including email address) and contact details (which may include home, business and mobile phone numbers). It is possible that where a specific product or service is involved, we may collect Personal Data from you that relates to that particular product or service. The types of Personal Data that we may collect, use, disclose and/or process as part of our day-to-day operations or in the ordinary course of our business and depending on the nature of interaction with the individual in question and the circumstances in question, include but may not be limited to following:

    • Full name, personal identification number of individual, mobile/residential telephone number, personal email address and/or residential address;
    • Financial data such as bank account numbers and/or credit card details;
    • Age or birth date;
    • Personal product or service preferences;
    • Products and services an individual may have purchased/enquired about together with any data necessary to deliver, provide or maintain those products and services or to respond to enquiries and feedback;
    • Usage Data of Individuals. We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Such Usage Data can arise from your use of products and services provided by Brillar Co directly through its websites or indirectly through your use of Brillar Co’s websites, or through Brillar Co’s Associates, Affiliates, Third Parties or otherwise.

    • Data provided to Brillar Co through its customer service channels, surveys, visits by and to Brillar Co Customer Service Personnel, Agents or any Representatives from time to time;
    • Tracking Cookies Data. Cookies and pixel tags or web beacons, IP addresses and navigational data.

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

    • Session Cookies.We use Session Cookies to operate our Service.
    • Preference Cookies.We use Preference Cookies to remember your preferences and various settings.
    • Security Cookies.We use Security Cookies for security purposes.

3.2 The information that we collect from you when you interact with us online depends on the tasks you complete on the Site, the products or services that you obtain from us and/or your interactions with us. From time to time, you may be able to interact with us anonymously or by pseudonym.

3.3 You have no obligation to provide any of the Personal Data requested by us. However, if you choose not to provide us with certain Personal Data, we may not be able to deal with your request, and/or provide you with the products or services that depend on our ability to collect, use, disclose or process, or which require, your Personal Data. We, our Associates, Affiliates, or Third Parties also may not be able to respond to your inquiry or instructions without your Personal Data being provided as required.



3.4 When you visit and browse through our Site or purchase or use our products or services, we may collect Data for statistical and maintenance purposes that enables us to evaluate the performance of our Site or products. Such general data or information includes: –

    • the number of users visiting our Site or using our products and the number of pages viewed;
    • the date, time and duration of visits; and
    • the path taken through our Site.

Such data or information will not identify you and we will not combine it with any information in a manner whereby we can identify you.


3.5 When you interact with us for matters where reasonably, practically, necessarily or logically your Personal Data is required by us in order to deal with your interaction, your request or activity, we would need to obtain Personal Data from you in order to complete such interaction, such as your online application for our products or services. When requesting any product or service or when using the “Contact Us” function on our Site, you may need to complete an online form on the Site.

Our online forms will ask you to provide Personal Data and such Personal Data will/may be collected, used, disclosed and/or processed by us for one or more of the Purposes (as defined below) and/or any other purposes stated in that Form or otherwise. You will have the right to choose whether or not to provide Personal Data, although if certain necessary Personal Data is not provided to us, it will mean that we may not be able to deal with your request or transaction.


3.6 You can contact us by e-mail via the link on this Site. In such instances, you have the choice whether or not to provide personal data other than your name and email address.


3.7 The Site is not intended for use by any person below the age of 18. We do not and do not intend to, transact through the Site directly with anyone we know to be under the age of 18. Our Service does not intend to nor does it address anyone under the age of 18 (“Children”).

Thus, we do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Thus, if you are under the age of 18, you should use the Site only with the involvement of and through your parent or guardian and should not submit any personal data to us. By providing any personal data to us, you affirm that you are at least 18 years of age and above and agree to the terms set out in this Privacy Policy.


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:

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

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.


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

    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.comand 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 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;
    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. 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.


6.1 Brillar Co takes great care to protect your privacy. In this regard, we will take reasonable steps to ensure that your Personal Data is kept confidential and secure, and take reasonable appropriate technical and organizational measures to protect your personal data from unlawful or accidental destruction, accidental loss, unauthorized collection, use, disclosure, access, copying, modification, leakage, damage, alteration or other unlawful forms of processing.

6.2 Any information provided to us on the Site may be protected using Secure Sockets Layer (“SSL”) protocols.

6.3 Any information stored in documents or on Brillar Co’s systems is protected from unauthorised access by the use of a number of security procedures including user passwords.

6.4 Security of Data

Please be aware that the transmission of data over the internet is never completely secure, and while we aim to use our best efforts to secure and protect the information, we cannot guarantee the security of any information that is provided or transmitted to us by you. Any such provision of information is at your own risk.

6.5 Retention of Data

Brillar Co Pte Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Brillar Co Pte Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:-

(i) the purpose for which that Personal Data was collected is no longer being served by the retention of such personal data; and/or

(ii) retention is no longer necessary for any legal or business purposes.

6.6    Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Singapore and choose to provide information to us, please note that we transfer the data, including Personal Data, to Singapore and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Brillar Co Pte Ltd will take all the steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.


7.1 Brillar Co may/will need to disclose your personal data to third party organisations outside of Brillar Co including to Brillar Co’s affiliates, and those organisations may be located (and your Personal Data may be disclosed) overseas and outside of Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes.

In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. These disclosures are made subject to suitable protection for privacy and confidentiality being in place. The third party organisations to which we would usually disclose your information include:

    • third party organisations who have been retained by Brillar Co to assist us in providing services to you including delivery, installation, maintenance and repair;
    • Associates, Affiliates, Suppliers, Agents and other third parties with whom we have commercial or contractual relationships, for business, marketing, re-marketing and/or related purposes including but not limited to those which provide administrative or other services to us such as mailing houses, call centres, telecommunication companies, logistics companies, information technology companies and data centres;
    • market research, marketing and/or telemarketing service providers;
    • our professional advisers, for example, our Auditors and Lawyers, as well as our Insurers;
    • Government, Regulatory or other Organisations to whom we are required to disclose your Personal Data by Law;
    • our related Companies, Associates, Affiliates, Product Partners or Agents, including without limitation where we have received a product complaint or claim, for example, to our contract manufacturers, logistic service providers or other third parties in the supply chain, who may be located overseas, depending on where the relevant product or part was manufactured;
    • any actual or proposed Assignee or Transferee of the business of Brillar Co, or a merged entity in the event Brillar Co is merged to create the said merged entity;
    • Third Parties, including independent Financial Advisors (eg. from AIA, Prudential, GEL, NTUC, Aviva, FAs etc), to whom disclosure by Brillar Co is for one or more of the Purposes and such Third Parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.

7.2 We may disclose your Personal Data to overseas members of the Brillar Co group of companies (and their Associates, Affiliates, Agents or Partners), who may communicate with you about certain products or special offers, for one or more of the above Purposes.

7.3 We may disclose your information to a Purchaser or Successor Entity in connection with the sale of Brillar Co or a related body corporate, or a business unit owned by Brillar Co or a related body corporate, or the sale of substantially all of the assets of Brillar Co or a related body corporate.

7.4 Where your Personal Data is to be transferred out of Singapore, we will comply with the requirements of applicable local data protection law (i.e. the PDPA) in doing so. In this regard, this includes taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.

7.5 Disclosure for Law Enforcement or Legal Requirements

Under certain circumstances, Brillar Co Pte Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Brillar Co Pte Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

    • To comply with a legal obligation, including our contractual obligations with our Associates, Affiliates, Representatives, Partners, Agents or Third Parties (including independent Financial Advisors eg. from AIA, Prudential, GEL, NTUC, Aviva, FAs etc) who may contact you relating to their products and services if they deem such products or services may be appropriate or relevant to your needs, whether as a parent or personally,
    • To protect and defend the rights or property of Brillar Co Pte Ltd,
    • To prevent or investigate possible wrongdoing in connection with the Service,
    • To protect the personal safety of users of the Service or the public,
    • To protect against legal liability


8.1 Should you provide Brillar Co with Personal Data of individual(s) other than yourself, you represent and warrant to Brillar Co and you hereby confirm that :

    1. prior to disclosing such Personal Data to us, you would have and had obtained consent from the individuals whose Personal Data are being disclosed to us, to:
      1. permit you to disclose the individuals’ Personal Data to Brillar Co for the Purposes; and
      2. permit Brillar Co to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes, as set out in paragraph [5] above;
    2. any Personal Data of individuals that you disclose to us is accurate;
    3. you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to Brillar Co and for Brillar Co to collect, use, disclose and process such personal data for the Purposes; and
    4. the terms of this Privacy Policy have been brought to their attention and they are agreeable to the same.


9.1 Brillar Co takes reasonable steps to ensure that any Personal Data we collect, disclose and use is accurate and complete, if your Personal Data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your Personal Data or if there are any errors in the Personal Data we hold about you. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from your not updating us of any changes in your Personal Data that you had initially provided us with.

9.2 Subject to certain exceptions allowed by Law, everyone who has provided Personal Data has the right to access or correct that Personal Data. For security reasons you will be required to put any request for access to or correction of your Personal Data into writing. You may obtain access to or correction of your own Personal Data by contacting us via our email address We will need enough information from you in order to ascertain your identity as well as the nature of your request, to deal with your request.

9.3 Brillar Co may charge you a fee to deal with a request by you to access your Personal Data in order to cover our reasonable administration costs and will notify you in such an event.

9.4 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant Personal Data within the required timeline under applicable local data protection law (30 days in the case of the PDPA). Where we are unable to respond to you within the timeline, we will notify you of the soonest possible time within which we can provide you with the information requested. The PDPA exempts certain types of Personal Data from being subject to your access request.

9.5 For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will deal with your request in compliance with applicable local data protection law (i.e. the PDPA), including correcting your Personal Data within the required timeline under local data protection law (30 days in the case of the PDPA). Where we are unable to do so within the said timeline, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.

9.6 You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by submitting your request to the email address set out below. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will subsequently not collect, use and/or disclose your Personal Data in the manner stated in your request, unless the law or applicable local data protection law (i.e. the PDPA) allows us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we, our Associates, Affiliates, Financial Representatives or Agents may not be able to fulfill the transaction you have entered into with us or continue with your relationship with us, or send you information that you have requested, as examples depending on the circumstances.


10.1 If you have any concerns about our handling or treatment of your Personal Data or if you believe that your privacy has been breached, please contact us by email at the address below setting out the nature of your query, concern or complaint .

10.2 We will expeditiously deal with your query or concern and/or investigate your complaint and endeavour to provide you with our response within a reasonable time of receiving your query, concern or complaint.


11.1 If you have any queries relating to our Privacy Policy, or if you wish to request for access to or correction of your personal data or to withdraw your consent, please contact or send your request to us at

Data Protection Officer/Officer in Charge

Brillar Co Pte. Ltd.



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.