Privacy Policy

This Privacy Notice describes how realfit (Singapore) Device Pte. Ltd., herein referred to as “we,” collects, uses, discloses, transfers, stores, and otherwise processes your personal data when you are using our services (altogether referred to as “Services”). Please read carefully and familiarize yourself with our privacy practices before using our Services or providing your personal data, especially on terms marked in bold.

This Privacy Notice will help you understand the following:

  • A. General Provisions
    1. Responsibilities
    2. How We Collect Personal Data
    3. Personal Data We Collect and Process
    4. How We Use Your Personal Data
    5. Legal Bases for the Processing of Personal Data
    6. How We Use Cookies and Similar Technologies
    7. How Long We Keep Your Personal Data
    8. How We Disclose Your Personal Data
    9. How Your Personal Data Is Transferred Globally
    10. How We Protect Your Personal Data
    11. How We Process Children’s Personal Data
    12. Your Rights Regarding Your Personal Data
    13. Third-Party Websites
    14. How This Privacy Notice Is Updated
    15. Contact Us

A. General Provisions

I. Responsibilities

realfit (Singapore) Device Pte. Ltd. (“we”, “our”) acts as the authorized and exclusive distributor for the brands you see displayed on our website in Singapore. We provide Services for products and services from these brands, and we are the controller of the personal data processed in connection with providing our Services to you, which means that we determine the means and purposes of the processing of your personal data.

II. How We Collect Personal Data

The term personal data follows a broad understanding and means any information relating to an identified or identifiable individual. This includes data that directly identifies you, such as your name or address, as well as other data which, when combined with other information accessible to us, enables us to link that data to you – for example, your order number or the IMEI of your device.

We may collect personal data when you provide it to us directly. You are generally free to choose which personal data you provide to us. However, if certain personal data is required for the performance of our Services and you choose not to provide it, we may be unable to provide the Services you request.

We may also obtain certain personal data automatically when you interact with our Services, such as information about how you interact with our Services, and/or from third parties.

III. Personal Data We Collect and Process

Personal data we collect and process includes, in particular, the following:

  1. In connection with marketing activities: Such activities include when you enter prize draws, coupons or other competitions, participate in promotional or marketing activities organized by us or our business partners on our behalf, or complete questionnaires. To this extent, we may request personal data such as your name, address, email address, phone number, user ID, and other personal data as indicated in connection with such activities.
  2. When you subscribe to our newsletters: We may collect your name, email address, and information on how you interact with our promotional communication (such as whether or not you have opened the email or clicked a contained link).
  3. When you interact with us via our Social Media Channels: If you interact with us through a social media site or third-party service, such as when you like, follow or share our content on Facebook, Twitter, or other sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties.
  4. If you order Services from us, or use a paid Service: We may collect your delivery details, bank account number, credit card details, billing address and other financial information relating to the transaction, order number, name and contact details, information on your purchase/return/refund or other request, and any other communication records, so we can process your order.
  5. When you use our website: We may collect your name, address, email address, phone number, user ID, and other personal data as indicated in connection with such activities.
  6. In connection with customer surveys: We may collect your name, email address, and information on how you interact with our promotional communication (such as whether or not you have opened the email or clicked a contained link).

We may request your personal information according to the specific required Services. You are not required to provide the personal information that we may request. However, if you choose not to do so, in many cases we will not be able to provide you with our Services or respond to requests you may have.

IV. How We Use Your Personal Data

  1. We will use your personal data for the following purposes:
    1. To provide you with our Services, process your orders, or fulfill the contract between us;
    2. To diagnose product issues and provide other customer care and support Services;
    3. To conduct customer surveys in order to enhance your user experience and improve our Services along with their security features;
    4. To allow and manage your participation in prize drawings, contests, or similar promotional activities held by us;
    5. To communicate with you and reply to your questions or comments submitted to us;
    6. To ensure the functionality and safety of our Services;
    7. To prevent and investigate fraud, cybersecurity threats, or other improper use;
    8. To pursue or defend against legal claims; and
    9. To comply with our legal obligations.
  2. When we intend to use personal data for other purposes not covered by this Privacy Notice, we will inform you about that and ensure that the use of your personal data complies with applicable law.
  3. We do not make any decisions involving the use of algorithms or profiling that produce legal effects or other effects that similarly significantly affect you.

V. Legal Bases for the Processing of Personal Data

Our processing of your personal data is based on the following legal grounds:

  1. Consent: We may process your personal data based on your consent. We may, in particular, require your consent when sending you promotional messages. You have the right not to provide consent or to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you have granted us consent to use your personal data, we will use it only for the purposes specified in the consent declaration. Please note that to the extent our processing is based on your consent and you deny your consent or withdraw it, we may be unable to provide the service relating thereto. Neither the initial denial nor a withdrawal will have any negative consequences for you.
  2. Performance or entry into a contract with you: We rely on this legal basis in particular in the following cases:
    1. To provide you with our Services, process your orders, or fulfill the contract between us;
    2. To allow and manage your participation in prize drawings, contests, or similar promotional activities held by us; and
    3. To diagnose product issues, repair customer equipment, and provide other customer care and support Services.
  3. Compliance with a legal obligation: We may be obliged to process personal data to comply with our legal obligations, for example where we are required to retain data for tax law or commercial purposes.
  4. Legitimate interests: The processing of your personal data may also be necessary for our legitimate interests. Such cases may include the following in particular:
    1. To conduct customer surveys in order to enhance your user experience;
    2. To analyze the efficiency of our business operations;
    3. To communicate with you and reply to the questions or comments you’ve submitted to us by any means;
    4. To ensure the functionality and safety of our Services;
    5. To conduct internal auditing and to prevent and investigate fraud, cybersecurity threats, or other improper use; and
    6. To pursue or defend against legal claims.

VI. How We Use Cookies and Similar Technologies

We use cookies and similar tracking technologies on our website and other Services.

  1. What Are Cookies?
    Cookies are small text files that are transferred from our Services and stored on your device. Our Services may use “cookies” and other technologies such as pixel tags and web beacons (together “Cookies”). Cookies may be stored on your computer. Cookies not set by us will not be accessible by us.
  2. How We Use Cookies
    We and our third-party partners use Cookies to better understand the functionality of our mobile software on your device to monitor and analyze how you use and interact with our Services so that we can continue to improve them (such as to evaluate the information on how often you use the Services and the events that occur within our Services). We do not link the information we store within the analytics software to any personal data you may submit within our mobile applications.
    We and our third-party partners also use Cookies to analyze trends, administer the websites, track users’ movements around the websites, and to collect aggregate demographic information about our user base.
  3. Types of Personal Data We Collect
    This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.
  4. How Long Will Cookies Stay on Your Device?
    • Session cookies – such Cookies will only last until your browser is closed and will not be stored on your device. Session Cookies are generally used to track the pages on a site that you visit so that information can be customized in relation to a specific visit to a page of the website.
    • Persistent Cookies – such Cookies will be stored on your device until you actively choose to delete them or when each Cookie reaches its expiry date. Such Cookies can be used to store your preferences when you use our website.
  5. Third-Party Tracking and Online Advertising
    We partner with third parties to display advertisements on our websites and applications or to manage our advertisements on other sites. Our third-party partners may use Cookies or similar tracking technologies to provide advertisements to you based on your Browse activities and interests. If you wish to opt out of interest-based advertising, you can manage Cookies as described in the following paragraph. Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that advertisements may no longer be tailored to your interests.
  6. Clear/Disable Cookies
    Depending on your mobile device and operating system, you may not be able to delete or block all Cookies. Please note that if you choose to refuse all Cookies, you may not be able to use the full functionality of our Services. These settings will typically be found in the “options” or “preferences” menu of your browser.

    See below instructions on how to manage cookies on certain popular browsers:
    1. Microsoft Internet Explorer
    2. Microsoft Edge
    3. Mozilla Firefox
    4. Google Chrome
    5. Safari for macOS
    6. Safari for iOS
    For more information about Cookies and instructions on how to configure your browser to accept, delete or reject cookies, see www.allaboutcookies.org.

    Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

VII. How Long We Keep Your Personal Data

We will only store your personal data for as long as necessary to achieve the purposes of collection as set out in this Privacy Notice, unless a longer retention period is required by law. If we are required by law to store your personal data for a time beyond this period (e.g., for tax and commercial law reasons), we will delete the personal data after the end of this storage period.

After the expiry of the aforementioned retention periods, we will delete or anonymize your personal data.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and disclosure of your personal data, the purposes for which we process the personal data, and the applicable legal requirements.

If, after you have signed up to our promotional emails, you unsubscribe from receiving our promotional emails, we will delete your personal data from our mailing lists. However, we will store your email address in a blacklist to ensure that you will not receive any further communication.

VIII. How We Disclose Your Personal Data

At times we may make certain personal data available to other companies that are controlled by or under common control with us (“Affiliates”) and other third parties that work with us in order to provide Services to you. Your personal data will not be shared with third parties for their own independent marketing purposes. We may share your personal data according to the following:

  1. Affiliates: Your personal data may be shared with our Affiliates, in particular our parent company, for purposes of rendering our Services to you.
  2. Service Providers and Partners: We may also share some personal data in particular with our partners to provide better Service to you and to improve your user experience, but we may also share personal data with other service providers that perform services on our behalf, as needed to carry out their work for us, which may include providing mailing services, providing tax and accounting services, contest fulfillment, web hosting, or providing analytic services. Any such service providers will – by appropriate data processing agreements – be bound to only process personal data on our behalf and under our instructions, unless such service providers act as independent controllers.
  3. Purchasers and third parties in connection with a business transaction: Where a merger, acquisition, bankruptcy liquidation, or similar action takes place, we may transfer or disclose your personal data to a limited, but necessary, extent to the applicable third party.
  4. Law enforcement, regulators, and other parties for legal reasons: We may also disclose your personal data with third parties as required by law or if we reasonably believe that such action is necessary (a) to comply with a subpoena or other legal proceedings, legal actions, or government agencies’ requests, (b) when we believe in good faith that a disclosure is necessary to comply with the law and the reasonable requests of law enforcement, (c) to protect and exercise our legal claims, rights, and property, (d) to protect your rights, property, or personal safety or to protect those of others, (e) to investigate fraud, and (f) to protect the security or integrity of our Services.
  5. Otherwise with consent: We may disclose your personal data to certain other third parties with your consent.

IX. How Your Personal Data Is Transferred Globally

  1. We may transfer your personal information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and that does not provide for an equivalent and adequate level of data protection as the country in which you usually reside. To provide you with our Services, we may in particular use tools provided by our brand partners, which means that your data may be transferred internationally.
  2. However, in such cases, we will take measures to ensure that the personal data we collect is processed in accordance with this Privacy Notice and applicable laws, and that your personal data is sufficiently safeguarded. For example, we might rely on accepted transfer mechanisms (such as “model contractual clauses” approved by the European Commission) or ask your permission to transfer your personal data across borders. We will also sign necessary data transmission/sharing agreements with the recipients of your personal data prior to the transfer taking place. For more information about the safeguards relating to personal data transfers outside of the country you reside in, please contact us using the “Contact Us” section.

X. How We Protect Your Personal Data

  1. The security of your personal data is very important to us. We have taken reasonable practical technical and organizational measures in accordance with industry standards to protect the personal data collected in connection with our Service and prevent it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, please note that although we have taken reasonable measures to protect your personal data, no websites, internet transmissions, computer systems, or wireless connections are absolutely secure.
  2. In case of a personal data security incident, we will act in accordance with applicable law and notify you and/or the competent data protection authority of any such security incident, where required, and take measures to mitigate any risks arising thereof.

XI. How We Process Children’s Personal Data

  1. Our Services are mainly adult-oriented. A child should not use our Services without his/her legal guardian’s consent. We treat anyone under 18 years old as a child.
  2. When we find that a child’s personal data is collected accidentally, we will delete the relevant data as soon as possible.
  3. If you believe that we might have any personal data concerning a child, please contact us using the “Contact Us” section.

XII. Your Rights Regarding Your Personal Data

Subject to the legal requirements under the Personal Data Protection Act, you have the following rights:

  1. The right to access: You may request access to the personal data we hold about you.
  2. The right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and to request the completion of your personal data where appropriate.
  3. The right to erasure: You can submit a request to us to delete personal data, and we shall have the obligation to erase it without undue delay in some circumstances – for example if we do not have a legal reason to continue to process the personal data to the extent required by applicable laws and regulations. Please note insofar as you delete all the data that is contained in your device, this does not mean that you have deleted all data that we collect and process about you. Therefore, we encourage you to contact us (please refer to the “Contact Us” section below) to request that your personal data is deleted.
  4. The right to restriction of processing: You have the right, in certain circumstances, to ask us to restrict how we process your personal data, such as where the accuracy of the personal data is contested by you, for a period of time enabling us to verify the accuracy of that personal data. We will keep just enough or process such data necessary for us to make sure we respect your restriction request in the future.
  5. The right to object: You have the right to object to any processing justified by legitimate interests based on grounds relating to your particular situation at any time. Should you decide to object to the processing of your personal data, we will stop processing personal data concerning you, unless we can demonstrate compelling reasons for continuing to process your personal data that override your interests, rights and freedoms or in the case that we establish, exercise or defend our legal claims. You can object to direct marketing activities at any time for any reason whatsoever.
  6. The right to data portability: You have the right to obtain a copy of your personal data in a structured, commonly used, and machine-readable format and transmit such data to another provider or have such data transmitted to another provider under certain circumstances.
  7. The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you want to withdraw your consent with regard to receiving promotional communications, you can unsubscribe through the method described in each promotional message. If you withdraw your consent, we may no longer be able to provide you with the corresponding Service.
  8. The right to lodge a complaint: You have the right to lodge a complaint with a competent supervisory authority about the way we handle or process your personal data, or file a lawsuit in a court with jurisdiction.

XIII. Third-Party Websites

  1. Services may contain links to third-party websites, products, and services. You can choose whether to access websites or accept products and services provided by third parties or not. For example, the “follow us” function on our official website will lead you to access our official social network accounts (e.g., Facebook, Instagram, LinkedIn, Twitter, etc.) where you can view marketing or promotional information published by us.
  2. We do not control third-party privacy and data protection policies and do not accept any responsibility or liability for their policies. At the same time, such third parties are not bound by this Privacy Notice. Before submitting personal data to third parties, we therefore strongly recommend that you refer to the privacy protection practice of such third parties.

XIV. How This Privacy Notice Is Updated

We reserve the right to update or modify this Privacy Notice from time to time. We will update the “last updated” date at the start of this Privacy Notice. If there are no previous records, this will be the most current Privacy Notice.

XV. Contact Us

If you have questions or concerns regarding our Privacy Notice or practices, please submit your request to:

Data Protection Officer: Melvin Tan
E-mail: melvin.tan@realfitsg.net

Company Name: realfit (Singapore) Device Pte. Ltd.
Address: 3791 Jalan Bukit Merah, E-Centre, #05-20, Singapore 159471