Overview and Scope

Owndays Singapore Pte Ltd (“OWNDAYS”) is committed to protecting your privacy and will do everything in its power to ensure that your Personal Data is treated with respect to your fundamental rights as well as with personal dignity, with particular reference to confidentiality.

We have thus prepared this Privacy Policy in order to briefly explain to you how we will collect, use, share and secure your Personal Data. It also describes your choices regarding use, access and correction of your Personal Data.

This Privacy Policy sets out the collection, use and disclosure of your Personal Data. "Personal Data" means any data or information, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which OWNDAYS is likely to have access to.

When and what kind of Personal Data do we collect?

We may collect, use and disclose the following data about you:

When you furnish Personal Data by filling up forms (either online or in hardcopy)when applying for OWNDAYS’ products and services or feedback (i.e., surveys) and/orasking queries;
If and when you contact OWNDAYS (i.e., telephone calls, emails, social media, liveweb chat and face to face meetings) which we may keep a record of thatcorrespondence;
If you enter into any contract with OWNDAYS or purchase any products or servicesfrom OWNDAYS;
If you make contact with any of our authorised representatives, agents and partners,we may keep a record of that correspondence;
If and when you respond to any of OWNDAYS’ marketing promotions, newsletters, othercommunication materials, contests and competitions.

We may collect the following kinds of Personal Data through the different channelsmentioned above:

Full name
Age and gender
Date of birth
Business and/or residential addresses
Business and/or personal email addresses
Mobile and business telephone numbers
Bank account and last 4 digits of credit card numbers, if necessary
Voice, photos and CCTV images/videos, if applicable
Medical records and eyeglass prescriptions
Website cookie data
Photos, Scans, and Images: When you use our “3D Try On” services and submit your consent (or grant us permission to take), photo, facial scan, or other image of you. We don’t share those photos, scans, or images, or any facial data captured in the facial scans, with any third parties. We may use them for purposes as described below: to measure your pupillary distance and face width, and to gather other optical information, to map and measure your facial features, to address certain problems or concerns you may have with your glasses, to help better understand how our frames fit our customers and provide frame recommendations, to provide, personalize, and improve our products and our Service.We store the pupillary distance and face width measurements of the users submitted through the iPhone X TrueDepth camera.

What purposes does OWNDAYS collect, use and disclose Personal Data?

We may use the information we collect from you for any of the following purposes:

To provide answers or services which you request, to receive information from OWNDAYS; to verify your identity and provide assistance in case of lost or forgotten login/password details for your OWNDAYS membership accounts; to allow you to create and maintain a registered user profile/account, to process transactions you request, to contact you when necessary and respond to your requests and enquiries, including emails; to process payments and to provide any other services which you may request; to send you newsletters you have subscribed to as a service (containing only informative content).
For current and future marketing, promotional and publicity purposes, including to carry out direct marketing, as well as to carry out research, market statistics or surveys, regarding OWNDAYS products and services (“Marketing”) and to send you offers, promotions or other information about goods and services for these purposes. Individuals may withdraw consent given at a later stage.
For compliance with laws which impose upon OWNDAYS, the collection and/or further processing of certain kinds of Personal Data. When individuals provide Personal Data to OWNDAYS, OWNDAYS must process it in accordance with applicable laws, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
To prevent and detect any misuse or any fraudulent activities. Processing for this purpose is necessary to pursue OWNDAYS’ legitimate interests in preventing and detecting fraudulent activities or misuse of the Website (for potentially criminal purposes).
To analyse and improve OWNDAYS’ service provision, enhance OWNDAYS’ website, evaluate the effectiveness of OWNDAYS’ marketing activities and services, perform statistical and demographics analyses on OWNDAYS’ customers and registered users (“Analytics”). Processing for this purpose is necessary to pursue OWNDAYS’ legitimate interests in the development and administration of its services and to improve the services provided.

We may also contact you by any communication means which you have given us your contact details, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you.

You also consent to the onward disclosure of your Personal Data to the agents or service providers (as set out in “What purposes does OWNDAYS collect, use and disclose Personal Data?”) and the processing of your Personal Data by these agents and/or service providers.

We only collect, process, use or disclose such Personal Data, in accordance with this Privacy Policy. If you are acting as an intermediary, or otherwise on behalf of a third party, or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, processing, use and disclosure of his/her Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this Privacy Policy by referring the third party to our website.

Consent for the collection and use of your Personal Data

You consent to the collection, use and disclosure of your Personal Data for the above-mentioned purposes and agree to be bound by the obligations it imposes on you, when you accept this Privacy Policy. You accept this Privacy Policy when you continue to browse on OWNDAYS’ website or continuing to engage with OWNDAYS.

When you consent to us collecting and/or processing your Personal Data, it is on you to ensure that all Personal Data submitted to us is complete, accurate, true and correct at the time of submission. You are also requested to inform us should there be any changes to the Personal Data that you had submitted to us. Failure to do so may result in our inability to provide you with products and services you have requested.

Please note that if you do not consent to any of the above business purposes, OWNDAYS may not be able to satisfy the purposes for which the information was collected.

Does OWNDAYS disclose Personal Data to third parties?

We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap. 50).

On occasion, we may use third party agents and service providers to assist us in the use of your Personal Data as outlined under "What purposes does OWNDAYS collect, use and disclose Personal Data?" You consent to such use of your Personal Data by continuing to browse on OWNDAYS’ website or continuing to engage with OWNDAYS.

OWNDAYS will not transfer Personal Data within or outside Singapore unless we have assurance the Personal Data will be accorded a level of protection which is comparable to those of PDPA.

For how long does OWNDAYS retain your Personal Data?

We will cease retaining your Personal Data, as soon as it is reasonable to assume that the purpose for collecting/processing your Personal Data has been fulfilled, and there is no other legal or business purpose to continue retaining your Personal Data.

How does OWNDAYS protect your Personal Data?

OWNDAYS will ensure that there is a variety of reasonable security measures to maintain the safety of your Personal Data. All electronic storage and transmission of Personal Data is secured and stored on managed servers with controlled access and appropriate security technologies.

Although every reasonable effort has been made to ensure that all Personal Data will be so protected, OWNDAYS cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.

Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.

Access and Correction of Personal Data

Please contact us should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.

We will respond to your request as soon as reasonably possible. In the event we are not able to respond to your request within thirty (30) days after receiving your request, we will inform you before the deadline. If we are unable to provide you with any Personal Data or to make a correction you have requested, we shall inform you of the reasons unless where we are not required to do so under PDPA.

Further Information and Contact

If you are concerned about the handling of your Personal Data, wish to be removed from our email subscription or contact lists, or if you have any complaints or queries related to your Personal Data or our Privacy Policy, please contact OWNDAYS’ Data Protection Officer (“DPO”) at dpo@owndays.co.jp. Please clearly identify yourself and the purpose of your query.

Amendments and updates of this Privacy Policy

OWNDAYS reserves the right to revise this Privacy Policy with or without prior notice from time to time and your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Updated as at 6 Oct 2022