1. General

1.1 This Policy statement provides information on the obligations and policies of Bareness Skin Pte Ltd in respect of an individual customer’s Personal Data. Bareness Skin Pte Ltd undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

1.2 Bareness Skin Pte Ltd’s members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, Bareness Skin Pte Ltd. Bareness Skin Pte Ltd shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by Bareness Skin Pte Ltd shall be done in an appropriate manner and in accordance with the Act and this Policy.

1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Bareness Skin Pte Ltd as well as to its respective representatives and/or agents ("Representatives") (collectively referred to herein as "Bareness Skin Pte Ltd", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Bareness Skin Pte Ltd’s authorized service providers and relevant third parties in the manner set forth in this Privacy Statement.

1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Bareness Skin Pte Ltd or that which shall be collected by Bareness Skin Pte Ltd in future.

2. Contacting the Company for Data Protection

2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Bareness Skin Pte Ltd, Bareness Skin Pte Ltd shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.

2.2 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to Bareness Skin Pte Ltd on your behalf.

2.3 Should you not wish Bareness Skin Pte Ltd to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from Bareness Skin Pte Ltd, you may opt out by sending a clearly worded email to the our support team. Your request shall be processed within 30 days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.

3. Statement of Practices Types of Personal Data Collected:

3.1 As part of its day-to-day operations, Bareness Skin Pte Ltd may collect from you, through various means, including via our websites, smartphone applications, marketing events such as events, pop ups and any forms used by Bareness Skin Pte Ltd from time to time, some or all of the following Personal Data:

• Name (first and surname)
• Date of Birth
• Postal Address
• Phone number (including mobile)
• Office number
• Email address
• Bank account/credit card details
• Age
• Gender;
• Lifestyle preferences
• Medical history
• Skin information
• Personal Data of your emergency contacts
• IP addresses and
• Photographs and images.
• Biometric data.

Purpose of Collection of Personal Data

3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of:

• processing your application and registration of your membership and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes
• evaluating your skin-type and needs
• customising your skincare products
• to conduct market research and analysis
• for direct marketing through voice calls; text messages; email; direct mail and facsimile messages
• 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
• for identification and treatment area access
• maintaining and updating your membership details and
• informing you of new developments, services, promotions of Bareness Skin Pte Ltd and other third parties which we are associated with.

Optional Provision of Personal Data

3.3 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve Bareness Skin Pte Ltd’s products and services. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent Bareness Skin Pte Ltd from providing the service to you. This type of data includes, but is not limited to:

• Your age
• Gender
• Salary range and employment details
• Education and Profession
• Hobbies and leisure activities
• Other related products and services subscribed to and
• Family and household demographics.

3.4 Under certain circumstances, telephone calls made to any of Bareness Skin Pte Ltd’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.

4.The accuracy of Personal Data

Where possible, Bareness Skin Pte Ltd will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers.

6. Protection of Personal Data

Bareness Skin Pte Ltd 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 Bareness Skin Pte Ltd, other than to you or as described in this Policy. However, Bareness Skin Pte Ltd cannot ensure or warrant the security of any information you transmit to Bareness Skin Pte Ltd and you do so entirely at your own risk. 

7. Changes in Policy

Bareness Skin Pte Ltd reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Bareness Skin Pte Ltd. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

8. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.

9. Minors

9.1 Bareness Skin Pte Ltd’s websites do not target and are not intended to attract children under the age of 21 years old. Bareness Skin Pte Ltd does not knowingly solicit personal information from children under the age of 21 years old or send them requests for personal data.