E. Purposes for Collection, Use or Disclosure of Your Personal Data
- General Purposes. Generally, we collect, use, disclose and process your Personal Data for purposes connected or relevant to our business or to manage your relationship with us. Depending on the jurisdiction you are in and where the relevant TPL GROUP entity operates, the TPL GROUP and our third party service providers as the case may be, may use your Personal Data:
- to facilitate and process your transactions with us, or to provide products and services to you;
- for administrative purposes, including to facilitate your participation in our promotions, sales initiatives or contests, to evaluate your preferences, to facilitate your access to Group Websites and for the maintenance of the Group Websites and other quality assurance purposes;
- to register you as a member of any of our programmes (including loyalty programmes) and to provide you the benefits of such membership;
- to send you promotional and marketing material via email, post or telephone where appropriate;
- to carry out research and statistical analysis including development of new products and services or evaluation and improvement of our existing products and services;
- to answer your queries or provide you with assistance in any other way including resolving complaints and assisting you with your requests enquiries and feedback;
- to comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory body which are binding on us;
- enforcing legal obligations owed to us or responding to complaints, litigation or investigations concerning us;
- such other purposes that may be informed to you when your Personal Data is collected; and/or
- any other reasonable purpose related to the aforesaid.
- Marketing Purposes. If you have given your consent, we may use your Personal Data for the purposes of marketing our products and services and those of our strategic partners and business associates for marketing and communication purposes e.g. informing you of our latest activities, special offers and promotions. In order for us to market products and services which are of special interest and relevant to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).
- How We Share Your Personal Data Depending on the jurisdiction you are in or where the relevant TPL GROUP entity operates, in order to fulfil the above purposes, we may share your Personal Data with the following entities:
- Other entities of the TPL GROUP;
- The holding company of Times Publishing Limited, Fraser and Neave, Limited and its subsidiaries;
- Third-party vendors and service providers (such as subcontractors, agents or network operators) who are employed to perform business, support, operational and/or administrative functions such as marketing, payment, fulfillment and delivery of orders;
- Third parties with whom we conduct joint marketing and/or cross-promotions, including providing rewards or benefits; and
- Our professional advisers such as auditors and lawyers.
Some of the above entities may be located outside of the country/region where your data was first collected by the relevant TPL GROUP Entity. Where this is the case, your Personal Data may be transferred overseas from time to time. Such transfers will be carried out in accordance with relevant data protection laws.
Third parties are subject to confidentiality obligations and may only use your Personal Data to perform the necessary functions and not for other purposes.
- Use of Cookies. A cookie is a small piece of information that is placed on your Internet browsing software (the “browser”) by a website that you visit. It helps the website to remember information about your visit to make your next visit easier and the site more useful to you.
We may use cookies on Group Websites for the following purposes:
- To enable certain features and functions on Group Websites (e.g. remembering your user-ID, browsing and other product and/or service preferences);
- To identify the causes of problems arising at web servers and to resolve these problems or improve efficiency of Group Websites;
- To improve the contents of Group Websites and emails from us;
- To customize the contents of Group Websites and emails from us to suit your individual interests or preferences;
- To utilize your browsing history on Group Websites and the results of questionnaires for market research or marketing, including sending you advertisements via Group Websites;
- To obtain aggregated Group Website usage and visitation statistics;
- To administer services to you; and
- For purposes which are reasonably related to the aforesaid.
You may reject the use of cookies on Group Websites by configuring your browser to disable the use of cookies. However, this may result in the loss of functionality which may restrict your use of Group Websites and/or delay or affect the way in which it operates. If you disable the use of cookies, you may no longer be able to receive personalized features of Group Websites, which rely on the use of cookies.
- Links to Third Party Websites. Group Websites may contain links to other third party websites and microsites, whose privacy practices may differ from ours. If you submit Personal Data to any of those sites, your Personal Data is not subject to this Data Protection and Privacy Statement.
We encourage you to review the privacy statement of any site you visit. By clicking on or activating such links and leaving Group Websites, we can no longer exercise control over any data or information which you give to any other entity after leaving Group Websites. Any access to such other sites or pages is therefore entirely at your own risk. We are not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to or from Group Websites.
- Legitimate Interests and other legal basis for processing. In addition to collecting, using, disclosing and processing your Personal Data with your consent or for performance of a contract entered with you, we may also use and process your Personal Data to support our legitimate business interests in accordance with applicable data protection laws.
- Use permitted under applicable laws. We may also collect, use, disclose and process your Personal Data without your knowledge or consent where this is required or permitted under law.
- Contacting you. When we contact or send you information for the purposes described in Part E above, we may do so by post, e-mail, SMS, telephone or such other means provided by you. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with Paragraph 26.