Privacy Policy

PRIVACY POLICY

www.astraex.com

Effective date: 1^st August 2021

Astralis Pte Ltd. (“AstraEx”, “we”, “us” and “our”) respects the privacy and confidentiality of personal data in possession or under control.

This Privacy Policy applies to personal data collected, used, disclosed (including AstraEx out of Singapore), and otherwise processed by our website. Such personal data will be processed in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”), its associated regulations and subsidiary legislation, and guidelines issued by the Singapore Personal Data Protection Commission (“PDPC”). Jurisdictions outside of Singapore may have different local data protection standards. For users from EU, the GDPR shall apply and for users from the U.S. the CCPA shall apply. Other international privacy regulations/laws applicable to the jurisdiction of Singapore shall also apply.

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THROUGH THE FOLLOWING PRIVACY POLICY BEFORE PROVIDING US WITH ANY OF YOUR PERSONAL DATA. YOUR CONTINUED USE OF OUR WEBSITE CONSTITUTES YOUR ACKNOWLEDGEMENT AND UNDERSTANDING OF, AND AGREEMENT WITH, OUR TERMS AND CONDITIONS AND THIS PRIVACY POLICY.

Collection and Use of Personal Data

We collect your personal data and other information when you make a purchase, use or register into our products and services, take part in campaigns or research or otherwise interact with us which include:

• your details such as your name, gender, address, date of birth, mobile number, and email address;
• your online browsing activities;
• your interests, preferences, feedback, and survey responses;
• your correspondence and communications with AstraEx.

 Your personal data is collected when you:

• visit our website with a cookies-enabled browser, or (if applicable) register a user account with our website;
• request services from us such as subscribing to our newsletter or mailing lists for post or phone updates;
• fill in any forms on our website;
• submit any comment, question or feedback to us, or contact or correspond with us in any way; and

The above personal data is collected for the purposes of processing  your application and registration of your account and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes; to conduct market research and analysis; for direct marketing through SMS, email, and direct mail; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; maintaining and updating your membership details; to provide you with personalized services; to enable us to develop, deliver and improve our products, services, content and advertising; to administer our websites; to improve your experience with us; and informing you of new developments, services, promotions of AstraEx and other third parties which we are associated with.

Marketing, advertising and making recommendations

We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying AstraEx and third party content.

Opting-Out / Withdrawal Of Consent / Retention Of Data

If you would like to unsubscribe from our newsletter, detailed instructions are provided at the bottom of all emails sent out. Your personal data will be retained for as long as it is necessary to fulfill the purpose for which it is collected or for business or legal purposes, or in accordance with applicable laws. Your personal data may also continue to be retained on our databases to the extent permitted by law.

Accessing And Correcting Your Personal Data

You may review and correct your personal data by signing into your user account in the profile section, or by contacting us at [email protected]. We will only disclose personal data to the individual who registered his/her personal data with our website, and only after confirming the identity of the registered party. Please allow fourteen (14) working days for your request to be processed.

Cookies

When you visit our website, we may assign your web browser one or more website cookies. Cookies are small text files used to enhance your shopping experience, including, but not limited to, maintaining current login, and providing a unique identifier for website statistics.

If you wish to prevent cookies from being stored on your computer, you can change the settings on your browser. For more information on this section, please refer to our cookie policy.

Disclosure of Personal Data

We disclose some of the personal data we have collected from you to the following parties or organisations outside AstraEx in order to fulfil our services to you:

• IT/Technical Support
• Third Parties
• Business Process Outsourcing service providers

In addition to the above, where required to do so by law, we will disclose personal data about you to the relevant authorities or to law enforcement agencies. We may also share some of your personal data, after they are anonymised, with third parties for research purposes in order to improve our products and services to you.

Protection of Personal Data

AstraEx uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside AstraEx, other than to you or as described in this Policy. However, AstraEx cannot ensure or warrant the security of any information you transmit to AstraEx and you do so entirely at your own risk. In particular, AstraEx does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of AstraEx physical, technical, or managerial safeguards.

Storage and Retention of Personal Data

We will delete, as reasonably possible, or otherwise anonymise any personal data in the event that the personal data is not required for any reasonable business or legal purposes of AstraEx and where the personal data is deleted from AstraEx electronic, manual, and other filing systems in accordance with AstraEx internal procedures and/or other agreements.

Links to Third-Party Websites

The website may contain links to other third-party websites and microsites, whose privacy practices may differ from those of ours. If you submit personal data to any of those sites, your personal data is not subject to this Privacy Policy.

We encourage you to review the privacy policy of any website you visit. By clicking on or activating such links and leaving our website, we can no longer exercise control over any personal data which you give to any other entity after leaving our website. Any access to such other third-party website is therefore entirely at your own risk.

Amendments

We reserve the right to amend this Privacy Policy at any time. You are encouraged to review this page periodically to see any updates or changes to our Privacy Policy.

Mergers and Acquisitions

If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.

Data Protection Rights Under the GDPR (EU)

AstraEx is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:

• Right to information, Art. 15 of the GDPR
• Right to correction, Art. 16 of the GDPR
• Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
• Right to limit processing, Art. 18 of the GDPR
• Right to data transmissibility, Art. 20 of the GDPR
• Right to object, Art. 21 of the GDPR

To exercise your right, please contact us as indicated in the “Contact Us” section below.

In order to be able to process your request, as well as for identification purposes, please note that we will use your personal information in accordance with Art. 6 para. 1 (c) of the GDPR.

You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR.

CCPA (U.S.)

We are required by the California Consumer Privacy Act (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices, we offer to California residents concerning that Personal Information. 

Personal information that we collect, use, and share.  We do not sell personal information.  As we explain in this Privacy Policy, we use cookies and other tracking tools to analyze website traffic and facilitate advertising. 

Your California privacy rights.  The CCPA grants California residents the following rights.  However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with whom we share Personal Information.
• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
• Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.

You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

How to exercise your California rights.  You may exercise your California privacy rights described above as follows:

• Right to information, access and deletion. You can request to exercise your information, access and deletion rights, by emailing [email protected]. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.  Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
• Request a list of third party marketers. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any).  You can submit such a request by sending an email to [email protected] with “Shine the Light” in the subject line.  The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others in accordance with the CCPA. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

External Vendors of personal data

Our products and services may be provided using resources, third parties (e.g. Google Analytics) and servers located in various countries around the world. Therefore your personal data may be vendors across international borders outside the country where you use our services, including to countries outside the Singapore that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a Vendor and that adequate protection for your personal data is provided as required by applicable law, for example, by using Personal Data Protection Act (PDPC) clauses approved by the Singapore or relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures. You may contact the AstraEx Privacy Office at [email protected] to obtain additional information about the safeguards we take in connection with these Vendors. A copy of the unchangeable PDPC can be accessed at https://www.pdpc.gov.sg/Legislation-and-Guidelines/Personal-Data-Protection-Act-Overview

Who is the controller of your Personal Data?

Data Controller: Astralis Pte Ltd. (Astraex)

Email: [email protected]