1. INTRODUCTION
1.1 Welcome to the Wing Sing Gallery platform run by Wing Sing Gallery Sdn Bhd and its affiliates (individually and collectively, "Wing Sing Gallery", "we", "us" or "our"). Wing Sing Gallery takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our Wing Sing Gallery website and mobile application (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). Users refers to a user who registers for an account with us for use of the Services, which refer to member (individually and collectively, “Users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.
1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
1.3 By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Services or Platform, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.
1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.
1.5 This Policy applies to member who use the Services except where expressly stated otherwise.
2. WHEN WILL WING SING GALLERY COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
- when you register and/or use our Services or Platform, or register an account with us;
- when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
- when you carry out transactions through our Services;
- when you register for an auction; or
- when you submit your personal data to us for any reason
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
3. WHAT PERSONAL DATA WILL WING SING GALLERY COLLECT?
3.1 The personal data that Wing Sing Gallery may collect includes but is not limited to:
- name;
- email address;
- date of birth;
- telephone number;
- gender;
- any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform; and
- aggregate data on content the User engages with.
3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.
4. COLLECTION OF OTHER DATA
4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Platform. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile application and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site.
4.2 As when you view pages on our website and mobile application, when you watch content and advertising and access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time.
5. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
5.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
- to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
- to manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preference), as well as your relationship and user account with us;
- to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
- to enforce our Terms of Service or any applicable end user license agreements;
- to protect personal safety and the rights, property or safety of others;
- for identification, verification, due diligence, or know your customer purposes;
- to evaluate and make decisions relating to your credit and risk profile and eligibility for credit products;
- to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
- to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
- to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. 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;
- to allow other users to interact, connect with you or see some of your activities on the Platform, including to inform you when another User has sent you a private message, posted a comment for you on the Platform or connected with you using the social features on the Platform;
- to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to recommend products and/or services relevant to your interests, to improve our Services or products and/or to enhance your customer experience;
- to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with Wing Sing Gallery’s Services;
- for marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom Wing Sing Gallery may collaborate or tie up with) that Wing Sing Gallery (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing materials. We may use your contact information to send newsletters or marketing materials from us and from our related companies;
- to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Wing Sing Gallery or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and company details);
- to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
- to audit our Services or Wing Sing Gallery's business;
- to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- to respond to any threatened or actual claims asserted against Wing Sing Gallery or other claim that any Content violates the rights of third parties;
- to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
- to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Wing Sing Gallery as a participant or involves only a related corporation or affiliate of Wing Sing Gallery as a participant or involves Wing Sing Gallery and/or any one or more of Wing Sing Gallery's related corporations or affiliates as participant(s), and there may be other third-party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, 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; and/or
- any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
5.2 You acknowledge, consent and agree that Wing Sing Gallery may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Wing Sing Gallery or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Wing Sing Gallery; (c) enforce the Wing Sing Gallery Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Wing Sing Gallery or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Wing Sing Gallery, its users and/or the public.
5.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
6. HOW DOES WING SING GALLERY PROTECT AND RETAIN CUSTOMER INFORMATION?
6.1 We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.
6.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the Platform, or your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
7. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES
7.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.
7.2 In an attempt to provide you with increased value, we may choose various third-party websites to link to, and frame within the Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third-party web sites (even if offered on or through our Platform) may not be received by us.
7.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
8. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
8.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by Facebook, Instagram, WhatsApp or call us.
Last modified: 10 October 2022