PLEASE READ THIS PRIVACY AND DATA PROTECTION POLICY (“POLICY”) CAREFULLY BEFORE ENGAGING IN AND/OR UTILISING ANY SERVICES PROVIDED BY BLACKJACKET.COM.SG PRIVATE LIMITED (“Blackjacket”) AT ITS PHYSICAL STORE, WEBSITE (WWW.BJLUXURY.COM), OR ANY AVENUE OPERATED BY BLACKJACKET INCLUDING BUT NOT LIMITED TO AVENUES UTILISING THE TRADING NAME OF “BJ LUXURY”. SUCH SERVICES INCLUDE BUT ARE NOT LIMITED TO CONSIGNING, RESERVING AND/OR PURCHASING ANY PRODUCTS FROM THE AFOREMENTIONED AVENUES (“SERVICES”). BLACKJACKET IS A COMPANY INCORPORATED IN SINGAPORE WITH REGISTERED ADDRESS AT 9 SCOTTS ROAD, #01-08 PACIFIC PLAZA, SINGAPORE 228210. THE PERSONAL DATA PROTECTION ACT OF 2012 (“PDPA”) ESTABLISHES A DATA PROTECTION LAW THAT GOVERNS THE COLLECTION, USE, DISCLOSURE, AND CARE OF PERSONAL DATA. THIS POLICY AIMS TO HELP YOU UNDERSTAND HOW BLACKJACKET COLLECTS, USES, SHARES AND PROTECTS YOUR PERSONAL DATA, AND SHOULD BE READ TOGETHER WITH THE APPLICABLE TERMS OF SALE AND/OR CONSIGNMENT AGREEMENT.
By engaging in and/or utilising the services provided by Blackjacket whether at the physical store, the website or by Consignment, you agree that you have read this Policy and accept the terms stated herein. Blackjacket reserves the right to modify this Policy, without notice, at any time. You understand that your continued engagement in and/or utilisation of services via Consignment or at Blackjacket’s physical store or website after the Policy has been revised constitutes your acceptance of the Policy as amended, provided that if such revision materially impacts your engagement in and/or utilisation of the services provided by Blackjacket, Blackjacket may notify you through such avenues as Blackjacket deems appropriate. What constitutes a “material change” will be determined at Blackjacket’s sole discretion, in good faith, and using reasonable judgment.
1.1. Blackjacket and/or its vendors as may be appointed at our discretion collect information from you when you consign, reserve and/or purchase hand bags, leather goods, and other accessories (collectively, the “Goods”) from Blackjacket’s physical store(s) or website.
1.2. Blackjacket recognises that the privacy of your personal data is important to you. Blackjacket is committed to treat all personal data with due confidentiality and in accordance with the relevant data protection laws of Singapore.
1.3. In this Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified:
a) from that data; or
b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
2. Collection, Usage and Disclosure of Personal Data
2.1. Collection of Personal Data
a) Blackjacket and/or its vendors as may be appointed at our discretion collect your Personal Data in the following ways:
i. When you provide Blackjacket and/or its vendors with your Personal Data directly, as such when you:
ii. When you Consign Goods to Blackjacket, use Blackjacket’s website or purchase Goods at the physical store, such as when you:
b) You agree that your consignment of Goods to Blackjacket or purchase of Goods on Blackjacket’s website and/or at Blackjacket’s physical store shall be deemed as your conclusive consent to modes of collection listed above.
c) For the avoidance of doubt, you may withdraw your consent to any mode of collection of your Personal Data as set out above, prior to collection of the same. Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Clause 2.2 (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.
2.2. Use of Personal Data
a) Blackjacket and/or its vendors use your Personal Data for the following purposes:
i. Performing obligations in the course of or in connection with our provision of the Consignment, Goods and/or services requested by you;
ii. Verifying your identity;
iii. To respond to, handle and process your enquiries, requests, applications and feedback;
iv. Managing your relationship with Blackjacket;
v. Processing payment or credit transactions;
vi. Sending your marketing information about our Consignment, Goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
vii. Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
viii. Any other incidental business purposes related to or in connection with the above.
b) Blackjacket and/or its vendors will not use your Personal Data for purposes other than what you have been informed of, or which are not permitted under local laws and regulations.
c) You agree that your continued Consignment of Goods to, access to and/or use of Blackjacket’s website and/or engagement in and/or utilisation of the services provided by Blackjacket at Blackjacket’s physical store shall be deemed as your conclusive consent to the non-exhaustive purposes listed above.
d) If you no longer want Blackjacket and/or its vendors to use your information to provide you services, you may write to Blackjacket to inform us of the same and should you have created an account, you may close your account and Blackjacket will take the relevant further steps as set out below.
2.3. Disclosure of Personal Data
a) Blackjacket and/or its vendors will not disclose your Personal Data to third parties outside of Blackjacket, its affiliates, and/or subsidiaries, without first seeking your consent, except as at Clauses 2 and 7 of the Consignment Agreement and as specified in this Policy.
b) You accept that Blackjacket and/or its vendors may disclose your Personal Data to law enforcement officials and/or government authorities if requested by the relevant government, or law enforcement, agencies in accordance with any laws, rules, guidelines, regulations, or schemes imposed by any governmental authority in Singapore.
c) You agree to allow Blackjacket and/or its vendors to disclose your Personal Data to Couriers for the purposes of providing the service you requested such as delivery of the Goods.
d) You also agree to allow Blackjacket and/or its vendors to disclose your Personal Data to third parties for the purposes of providing the service you requested through Blackjacket.
e) You agree that your continued Consignment of Goods to, access to and/or use of Blackjacket’s website and/or engagement in and/or utilisation of the services provided by Blackjacket at Blackjacket’s physical store shall be deemed as your conclusive consent to the non-exhaustive purposes listed above.
3. Third Party Websites
3.1. Blackjacket’s website may contain hyperlinks to other websites or resources. Similarly, other websites or resources may contain links Blackjacket’s website. When you access third-party websites, you do so at your own risk. Those other websites are not under Blackjacket’s control, and you agree that Blackjacket is not liable for the content, functions, accuracy, legality, appropriateness, or any other aspect of those other websites or resources. If you are accessing these other web sites, please refer to personal data protection or privacy policies of these other websites. The inclusion on another website of any link to Blackjacket’s website does not imply endorsement by, or affiliation with, Blackjacket. You further acknowledge and agree that Blackjacket shall not be liable for any loss or damage related to the use of any content, Goods, or services available through such third-party website or resource.
3.2. Blackjacket may partner with third party services who may use various tracking technologies, such as browser cookies or Flash cookies, to provide certain services or features. These technologies allow a partner to recognise your computer each time you visit Blackjacket’s website, but do not allow access to personally identifiable information from Blackjacket. Blackjacket does not have access or control over these third party technologies, and you agree that Blackjacket shall not be liable for any loss or damage related to the use of any content, Goods, or services available through such third-party.
4.1. To safeguard your Personal Data, all electronic storage and transmission of Personal Data are protected by commercially acceptable means, such as security technology. However, as no method of electronic storage is fully secure, Blackjacket and/or its vendors cannot guarantee its absolute security, though we shall strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
5.1. Blackjacket and/or its vendors will retain your Personal Data for as long as there is a business or legal need.
5.2. If you no longer want Blackjacket and/or its vendors to use your information to provide you services, you may write to Blackjacket to inform us of the same and should you have created an account, you may close your account and Blackjacket will take the further relevant steps as set out below.
6. Withdrawal of Consent, Access and Correction of Your Personal Data
6.1. Withdrawal of Consent
a) The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us and/or our vendors to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
b) 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 10 business days of receiving it.
c) Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email to our Data Protection Officer at the contact details provided below.
d) Please note that withdrawing consent does not affect our and/or our vendors’ right to retain personal data that we deem necessary in relation to Goods purchased or consigned to us and further does not affect our and/or our vendors’ right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
6.2. Access to and Correction of Personal Data
a) If you wish to make (a) an access request for access to a copy of the personal data which we and/or our vendors hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
b) Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
c) We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
7. Transfers of Personal Data Outside of Singapore
7.1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, by using our services you hereby grant to Blackjacket and/or its vendors your consent for the transfer to be made to the extent necessary for us to properly service you, and we will also take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
8. Data Protection Officer
8.1 You may contact our Data Protection Officer at [email protected], if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.
Any correspondence to the Data Protection Officer may also be addressed to Blackjacket’s office address at:
9 Scotts Road
#01-08 Pacific Plaza