1.1 The purpose of this document (“Privacy Notice”) is to inform you of how Barilla Singapore Pte Ltd process, uses and discloses your Personal Data collected through this website (Site”) for the purposes of providing you with the required services or information (“Services”) , in compliance to the Singapore Personal Data Protection Act (No. 26 of 2012) (the “PDPA”).
1.2 By participating in any digital initiative on the Site (“Digital Initiatives”) and interacting with us,on the Site submitting information to us, or signing up for any products and Services offered by us in the process, you agree and consent to Barilla and its related companies (collectively, "Barilla"), as well as their respective representatives and/or agents (collectively referred to herein as “Barilla”, "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Barilla's authorised service providers and relevant third parties in the manner set forth in this Privacy Notice.
2. PERSONAL DATA
2.1 In this Privacy Notice, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
2.2Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, gender, ethnicity and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
3. PURPOSES FOR COLLECTION, USE AND DISCLOSURE
3.1 It is a continuing condition of your participation in the Digital Initiatives and use of the Services that you agree to our collecting, using, disclosing and processing of your Personal Data for the purposes listed below in Clause 3.2.
3.2 In particular but without limiting the generality of the foregoing, you grant to us and to all other persons and entities involved in the operation of the Services and/or the Digital Initiatives your consent for the collection, use, disclosure and processing of your Personal Data for the following purposes:
(a) to facilitate your registration on the Barilla website at www.barilla.com.sg, for which registration is required to access particular sections of the Site and for us to deliver and manage various Services offered through the Site;
(b) to facilitate the publication of content submitted by you (“Contributions”) directly:
(i) on Barilla’ websites ; or
(ii) on websites managed independently by third parties engaged by Barilla such as, but not limited to, social networks e.g. Facebook, Twitter, (each a "Social Network"),
and whether attributed to your real name or via a pseudonym chosen by you during registration on the Site;
(c) to carry out marketing activities such as sending you promotional and advertising material to your email or mailing address (including but not limited to newsletters to provide you with updates on news related to Barilla, recipes, menus, nutritional advice, and other related information);
(d) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by Barilla;
(e) to customize the user experience on the Site and improve services and products offered by Barilla to you or Barilla’s customers;
(f) to conduct market research, analytics and surveys on your consumer habits or choices and define consumer profiles using the Personal Data provided by you in participating in the Digital Initiatives (whether at the time of registration or at the completion of questionnaires) or requiring the Services;
(g) responding to your queries, requests and feedback, including in relation to Barilla products, Services, advertising or the Site;
(h) facilitating any merger, acquisition or sale of any part or the whole of our business;
(i) protecting and enforcing our contractual and legal rights and obligations;
(j) compliance with any applicable law or regulatory requirement or to assist in law enforcement and investigations by relevant authorities; and
(k) processing your Personal Data for purposes which are reasonably related to any of the purposes stated above, including disclosure to and processing by any third party outsourced service providers and/or our marketing partners.
3.3 Without prejudice to any part of this Privacy Notice, you agree that we may share aggregated, non-personally-identifiable information about you with third parties, such as advertisers or our marketing partners for use in marketing, promotional or other activities in our sole discretion.
4. DISCLOSURE OF PERSONAL DATA
4.1 Barilla will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) Barilla’s related corporations;
(b) companies providing services relating to insurance, marketing and consultancy to Barilla;
(c) agents, contractors or third party service providers who provide operational services to Barilla, such as courier services, telecommunications, information technology (including web and data hosting), payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Barilla;
(d) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Barilla group entities;
(e) external banks, credit card companies and their respective service providers;
(f) our professional advisers such as consultants, auditors and lawyers;
(g) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(h) any other party whom you authorise us to disclose your Personal Data to.
5. TRANSFER OF PERSONAL DATA OVERSEAS
5.1 You further understand, acknowledge and agree that in connection with the use of the Services or your participation in the Digital Initiatives, and/or the fulfilment of your instructions or requests may require that we transfer your Personal Data to a jurisdiction outside Singapore, and accordingly, any such transfer of your Personal Data is at your request. Without limiting the generality of the foregoing, we may transfer your Personal Data overseas as follows:
(a) if necessary for the performance of a contract between you and us, such as this Privacy Notice, or to do anything at your request with a view to you entering into a contract with us;
(b) if necessary for the conclusion or performance of a contract between us and a third party which is entered into at your request; and/or
(c) if necessary for the conclusion or performance of a contract between us and a third party in your interest.
5.2 You agree and acknowledge that where your Personal Data is transferred overseas, depending on the jurisdiction in question, the recipient thereof may not be bound by its local laws to provide a standard of protection in relation to such Personal Data that is comparable to that required under Singapore law.
6. PERSONAL DATA SUBMITTED TO BARILLA
6.1 Whilst we will take reasonable steps to accurately record your Personal Data, we require that you provide accurate and complete Personal Data, and update such Personal Data with us from time to time.
6.2 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
6.3 In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
6.4 For the avoidance of doubt, if you should choose to withdraw your participation from the Digital Initiatives, this will not affect any consents you have provided in relation to your Personal Data or the use of your Singapore telephone number for receiving marketing or promotional calls or messages. If you wish to withdraw such consent, please contact our Data Protection Officer in accordance with Clause 9.
7. USE OF THE SITE AND SOCIAL NETWORKS
7.1 You agree and acknowledge that your use of the Site and any of the Social Networks is subject to the prevailing terms and conditions of the respective Site or Social Network.
7.2 You undertake to keep your username and password for the Site secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
8. CONTACTING US - FEEDBACK, WITHDRAWAL OF CONSENT, ACCESS and CORRECTION OF YOUR PERSONAL DATA
8.1 If you:
(a) have any questions or feedback relating to your Personal Data or our Privacy Notice;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Notice; or
(c) would like to obtain access and make corrections to your Personal Data records,
you can contact our Data Protection Officer via the following channel:
- Email: [email protected]
9. GOVERNING LAW
This Privacy Notice shall be governed in all respects by the laws of Singapore.