Privacy Policy


 
Imprintu Privacy Policy

Last updated: September 27, 2023 

Thank you for choosing to be part of our community at LG H&H Co., Ltd., doing business as Imprintu ("we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy (“Policy”) or our practices with regard to your personal information, please contact us at privacy@lghnh.com.

This Policy describes how we might use your information if you: 

  • Download and use our mobile application
  • Contact us via email or other means
  • Engage with us in other related ways ― including visiting any website that links to this policy, including http://www.imprintu.com, or engaging in any sales, marketing, or events with us

In this Policy:

"App" means the Apple iOS or Google Android mobile application necessary for controlling our Imprintu portable printer; and

"Services" means services that we provide via our App and other related services, including any sales, marketing, or events.

 

The purpose of this Policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this Policy that you do not agree with, please discontinue use of our App and Services immediately. It is at your discretion whether to provide your personal information to us. However, if you choose not to provide personal information or provide incomplete personal information, we will not be able to provide you with the requested services.

 

Please read this Policy carefully, as it will help you understand what we do with the information that we collect.

 

Please pay careful attention to the appropriate 'Additional Information' section below if you are resident in California, or located in the UK, the European Economic Area (“EEA”), Thailand, Mongolia, Philippines, Taiwan, Australia, Singapore, UAE, Vietnam, Turkey, Malaysia, Japan or Indonesia as this section contains important information that applies specifically to you.

 

 

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect the following categories of personal information: (i) when you disclose it to us; (ii) when we collect it automatically; and (iii) when you give us permission to collect it:

  • Identifiers and other personal information, such as your name, email address, username, physical address, mobile phone number, IP address, payment information, date of birth, gender, login ID, password, 
  • Commercial information, such as the products and services you have purchased from us
  • Internet or other electronic activity information, including service usage records, access logs, cookies, advertising identifiers (AAID, IDFA) and how you have interacted with our App or Services
  • Geolocation data, to the extent this information is inferred from your physical address or IP address
  • Audio or visual information, to the extent you call us or upload photos to the App or interact with us in related ways, including the App, websites, or email, we may collect audio recordings or images

For more information about how we collect each category of personal information, please see below.

Personal information you disclose to us 

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you create an account to use the Services, express an interest in obtaining information about us or our products and Services, or participate in activities related to the Services (such as by writing product reviews), or otherwise when you contact us.

 

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

 

Personal Information Provided by You. We collect names; email addresses; passwords; contact preferences; contact or authentication data; usernames; and other similar information. 

 

Sensitive Personal Information. Sensitive personal information shall include special categories of personal information (i.e., data capable of identifying a person) as defined by applicable law, and may include by way of example: (i) financial information (such as bank account, payment instrument details or creditworthiness), (ii) details relating to race , physical, psychological and mental health, (iii) religion or political beliefs, (iii) sexual orientation and gender identity, (iv) medical records and history, and (v) biometric information,  received for processing, or to be stored or processed under a lawful contract.

 

Payment Data. There are a number of different ways to make a payment relating to the App and the Services, which will require you to provide data necessary to process your payment, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. If you are using the App from India, any payment data may need to be retained solely within India to comply with directives of the Reserve Bank of India that apply to the payment service providers we engage to provide the services.

 

If you are purchasing a drawing through the App, you should make a payment on Toss. All payment data is stored by Toss and will be collected, used, and disclosed as described in the Toss privacy policy. You may find their privacy policy link(s) here: https://toss.im/docs/11293. You can see your purchase history in the App.

 

Payments for purchases made through an Imprintu website can be made with a credit/debit card, which will require us to process data relating to this payment method, as well as other personal data including your address and identification details necessary for processing the payment.

 

Payments for purchases made through an Imprintu website can also be made using PayPal. In that case, all payment data is stored by Toss and will be collected, used, and disclosed as described in the PayPal privacy policy relating to your jurisdiction. You can find this on the paypal.com website for your location and clicking the 'privacy' link at the bottom of the page.

 

All personal information that you provide to us should be true, complete and accurate, and you must notify us of any changes to such personal information.

 

Information automatically collected

 

In Short: Some information — such as your device characteristics — is collected automatically when you use our Services.

 

We automatically collect certain information when you use the Services. This may include device and usage information, such as your device characteristics, operating system, language preferences, referring URLs, device name, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. For more information, please see the “COOKIES AND OTHER TRACKING TECHNOLOGY” Section of this Policy.

 

The information we collect includes:

- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include device information, settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings). 

- Device Data. We may collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as device and application identification numbers, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information. 

 

Information collected at your option

 

In Short: We collect certain information with your permission, specifically your push notification preferences.

 

If you select certain options within the App, or use it in a particular way, we will also collect certain information regarding those options, or arising from the way you have used the App, and we may use this information in a particular way

- Push Notifications. With your permission, we may send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. 

 

 

We use this information for the purposes described in the “HOW DO WE USE YOUR PERSONAL INFORMATION?” Section. We do not sell your personal information for money, however, we may share it for personalized advertising purposes. For more information about how long we retain this information, see the “HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?” Section.

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

In Short: To the extent allowed by applicable law, we process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We use the information we collect or receive:

To enable you to create or log in to your account. We may use your information to help you create and/or log in to your account.

To manage user accounts. We may use your information for the purposes of managing your user account and keeping it in working order.

To enable upload of review messages. We may use your information to enable you to upload review messages, such as photo reviews.

To request feedback. We may use your information to request feedback and to contact you about your use of our Services. 

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent. 

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention). 

To enforce our terms, conditions and policies to comply with legal and regulatory requirements or in connection with our contract.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To administer prize draws and competitions. We may use your information to administer prize draws and promotions or competitions when you elect to participate in our promotions or competitions.

To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

To send you marketing and promotional communications. We may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences and applicable law. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing communications, including emails, SMS/MMS messages, phone calls and push notifications, at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below). 

For other business purposes. We may use your information with your consent for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

WILL YOUR PERSONAL INFORMATION BE DISCLOSED TO ANYONE?

In Short: We share your personal information as needed to fulfill the purposes described in this Policy and as permitted by applicable law. 

We may disclose your personal information as described below.

  1. With Our Service Providers. We may share your personal information with our payments provider Toss and other third-party service providers acting on our behalf to help us operate our Services. Service providers and vendors provide us with support services such as credit card processing, website hosting, community and feedback management, analytics services, surveys and research services, and network maintenance. These third parties can only use your information in accordance with our written instructions and must comply with the information security protections we have put in place.
  2. Within Our Corporate Organization. We may share your personal information within our organization, to provide you with the Services and take actions based on your request, such as our parent company, subsidiaries, and corporate affiliates, joint venturers, or other companies under common control with us. 
  3. During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information. We will notify you in the event of any such change in ownership or control of your personal information.
  4. For Legal Compliance & Safety. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners or other regulators; (c) exercise, establish or defend our legal rights; or (d) protect your, our, or others’ rights, property or safety.
  5. With Our Business Partners. Subject to applicable law, we may share your personal information with our business partners, such as, for permitted marketing purposes, or for co-sponsored events based on your voluntary participation. 
  6. With Your Consent.  We may share your personal information with other companies if you give us permission or direct us to share your information.

 

IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?

 

In Short: We may transfer, store, and process your information in countries other than your own.

 

Our servers and personnel engaged in the processing of personal information to which this Policy relates are located in the Republic of Korea. Accordingly, any personal information to which this Policy relates will be transferred to the Republic of Korea and processed there in accordance with this Policy. Where any personal information is transferred to a service provider or third party outside your country, we require such third parties to maintain security standards at least equivalent to those upheld by us for the protection of your personal information including Sensitive Personal Information. Additionally, they must take necessary precautions to ensure the safety and integrity of the personal information. 

 

(For users in the UK, EEA, Switzerland, or Thailand, please see ‘restricted Transfers in the ‘Additional Information’ section below) 

 

(For users in Singapore, please see ‘Transfer Outside of Singapore’ in the ‘Additional Information’ section below) 

 

We will always apply appropriate safeguards to protect personal information concerning you, and your rights and freedoms in relation to that personal information, when it is processed outside the jurisdiction of the GDPR, and we will take all necessary measures to protect your personal information in accordance with this Policy and applicable laws.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Policy unless otherwise required by law.

 

We will retain your information for as long as your account is active, as needed to provide you Services or for other purposes stated in this Policy. We will cease to retain your personal information or remove the means by which the personal information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at privacy@lghnh.com. Please note that, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For users in Macau, we may retain your information for up to 5 years after you cancel your account or your account is deactivated. For users in Indonesia, we will retain your information for a minimum of 5 years, subject to any request by you to delete, modify, erase or destroy such information or you revoke your consent to process your information.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we collect and use. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from us is at your own risk. You should only access the Services within a secure environment.

 

DO WE COLLECT PERSONAL INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@lghnh.com

 

(For users in Thailand, please refer to the “Additional Information for Individuals Located in Thailand”  below for details regarding the collection of personal information from minors in Thailand.)

 

(For users in Malaysia, please see “Personal Information of Minors” in the “Additional Information” section below.)

WHAT ARE YOUR PRIVACY RIGHTS?

The rights you have in relation to your personal information, and how we use it depend to a great extent on where you are located, or where you reside.  Please see the appropriate ‘Additional Information’ section.

 

However, if you contact us with a request concerning your personal information, we will try to accommodate it where possible within the constraints off our business and the applicable law.

 

Account Information 

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account. 
  • Contact us using the contact information provided. 

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our agreements with you and/or comply with applicable legal requirements. 

 

Caches: App is set to accept caches by default. If you prefer, you can usually choose to remove or reject caches in your device’s settings.

 

Opting out of our marketing communicationsYou can unsubscribe from our marketing emails, SMS/MMS messages, phone calls and push notifications at any time by clicking on the unsubscribe button on our website or in the App. You will then be removed from the marketing list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

  • Access your account settings and update your preferences.
  • Contact us using the contact information provided.
  • Click on the unsubscribe link on any marketing emails from us.

 

Before fulfilling your request, we may need to verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. 

 

You may use an authorized agent to submit a rights request on your behalf.  If you use an authorized agent to submit requests on your behalf, we may require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.

 

Cookies and Other Tracking Technology

In this section, we explain how we use cookies and similar digital tracking technologies (such as pixels, web beacons, and tags) (collectively “cookies”) on our website and other online services. We use cookies for a number of purposes as set out below. Cookies can be placed on our website by us or by third-party partners we engage for our purposes. Third-party cookies may also be deployed on our behalf on third-party websites (e.g. to measure the effectiveness of ads). In any case, you may opt-out from cookies at any time here, or by changing your browser settings accordingly. However, as a consequence of your opt-out, certain functions, portions or features of our website may cease working or may prevent you from fully benefiting of our online services.

Categories of Cookies. Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and these types enable us to remember things about you as a returning visitor. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. The main categories of cookies we use include:

  • Strictly Necessary. These cookies are essential to enable you to move around the online services and use its features and ensuring the security of your online transactions with us and online access to our website. Without these cookies, services you have asked for, such as completing a transaction, cannot be provided. These cookies don’t gather information about you for the purposes of marketing. Example: cookies that allow the website to hold items in your cart while you are shopping online.
  • Performance. These cookies allow us to count the number of visitors and collect information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is used to improve how a website works and the user experience. By using our Services, we can place these types of cookies on your device. However you can block these cookies using your browser settings (please see “How to manage your cookies” section below). Example: cookies that count page visits, bounce rates, or load times.
  • Functionality. These cookies allow us to recognize you when you return to our website and allows the website to remember choices you make (such as your user name). They may also be used to provide services you have requested such as watching a video. The information these cookies collect is de-identified (i.e. it does not contain your name, address, account details, etc.) and they do not track your browsing activity across other websites. By using our online services, we can place these types of cookies on your device. However, you can block these cookies using your browser settings (please see “How to manage your cookies” section below). Example: social sharing cookies.
  • Targeting/Marketing. These cookies make marketing messages more relevant to you. We or a third-party advertising network may collect information relating to your browsing history and interests to tailor relevant advertising to you. The advertisement network partner may use marketing cookies to collect usage, navigational or other data about your activities on our websites and mobile applications to provide you targeted advertising based upon your interests, limit the number of times you see the same advertisement on our websites or mobile applications and to help measure the effectiveness of advertising campaigns. Example: retargeting cookies for ad networks.
  • Personalization. These cookies may also be used on our website to personalize your shopping experience and enable you to use certain functions, to deliver ads which might be relevant to you, or for us to conduct internal testing on what works best for our customers.

Why We Use Cookies. We use cookies for the following purposes:

  • to enable basic functioning of our website or to fix any technical issue through gathering relevant technical data;
  • for web analytics to improve our website (structure, features, accessibility and usability, content) or to fix any technical issue through gathering relevant technical data;
  • to enable certain basic functions of online browsing and shopping with us (for example, save information you generated or provided on our website such as preferred items, items placed in the cart, billing address to save time and effort when you next return to our website or shop with us);
  • to monitor the effectiveness of our online ads and marketing (by recording your interactions with our ads on third-party websites, our social media platforms or our marketing communications); and
  • to learn more about your preferences and Internet browsing tastes to provide you with tailored advertising (you certainly don’t want to hear from us about something you are not interested in).

How to Manage Your Cookies. The browsers of most computers, smartphones and other web-enabled devices are typically set up to accept cookies. If you wish to amend your cookie preferences for this website or any other websites, you can do this through your browser settings. Your browser’s ‘help’ function will tell you how to do this. If you do not want the benefit of cookies, there is a simple procedure to manually delete your cookies at https://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html, but please visit the links below to opt-out of marketing cookies from over 50+ major third party behavioral advertising providers:

Please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it may affect the user experience.

Analytics. We use Google Analytics, which uses cookies and other similar tracking technologies, to perform website analytics. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.

Do Not Track Signals. Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.  However, you can always stop using the App or the Services at any time. 

Mobile App Advertising: When you use our mobile application, we or our Third Party Marketing Partners may use one or more of several different identifiers for your mobile device, including Apple Identifier For Advertising (IDFA) or Android Advertising ID (AAID), to target and deliver ads to you in our app or other apps. This means that your device identifier may be accessed by third-party ad networks and used to (a) help manage the number and types of ads you see; (b) track the source of installs related to ads seen in other apps; and (c) identify your interests and behavior and target advertising to you based on those interests and behavior.  However, you can always stop using the App or the Services at any time.

Apple requires app developers to ask for permission before they can track your activity across apps or websites they do not own in order to target advertising to you, measure your actions due to advertising, or to share your information with data brokers.  If you previously gave our mobile app permission to track, you can tell our app to stop tracking your activity.  On iOS or IPadOS, go to Settings, tap on our app, then tap to turn off Allow Tracking.   You can also reset your IDFA from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous IDFA. 

If you have an Android device, and are running Android 12 or above, you can delete your AAID permanently by opening Settings, navigating to Privacy > Ads, tapping “Delete advertising ID,” then tapping it again on the next page to confirm. This will prevent any app on your phone from accessing it in the future. Please note that if you do so, you will still see advertisements, but they will not be tailored to your inferred interests.

You may also access industry-provided opt-out tools, although they are not tailored to our mobile applications.  For instance, to opt-out of data collection by the Digital Advertising Alliance’s participating member companies for interest-based advertising across mobile applications, download the DAA’s App Choices mobile application opt-out offering at https://youradchoices.com/appchoices.

If you are located in the UK, EEA, Switzerland or Singapore, you can find further information on the cookies we use and the legal basis of processing here.

DO WE MAKE UPDATES TO THIS POLICY?

 

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

 

We may update this Policy from time to time. The updated version will be indicated by an updated revised date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes and/or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are collecting, using, disclosing and protecting your information.

 

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 

If you have questions or comments about this policy, you may call us at +82-31-8045-1431 (Monday – Friday 9:00 AM ~ 6:00 PM (KST), except on holidays), or email us at privacy@lghnh.com.

 

If you are located in the EEA, you may also contact our EU representative: LG H&H UK LTD. at WeWork, 198 avenue de France, 75013 Paris, France; e-mail: contact-us@lghnhuk.com.

 

If you are located in the UK, you may also contact our UK representative: LG H&H UK LTD. at 100 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1FH; e-mail: contact-us@lghnhuk.com.

 

If you are located in Australia, you may also contact our Australia representative: LG H&H Co., Ltd. at LG GwangHwaMun Bldg., 58 Saemunan-ro, Jongno-gu, Seoul, Korea 03184; e-mail: privacy@lghnh.com.

 

If you are located in India, you may also contact our grievance officer: LG H&H Singapore Private Ltd. at 158 Kallang Way, #05-01 Performance Building, 349245, Singapore; e-mail: sharifah.z@lghnh.com.sg.

 

If you are located in Japan, you may also contact our Japan representative: Gunhee Park at Minato Mirai Business Sq. 14F, 3-6-4 Minatomirai, Nishi-ku, Yokohama, Kanagawa, 220-0012; e-mail: guneypark@lghnh.com ; phone: +81-045-305-6251. 


 

 

If you are located in Indonesia, you may also contact our Indonesia representative: Muhammad Yusran Raba at LG Household & Health Care Malaysia Sdn Bhd Lot 468-7B & 7C, 1st Floor, Rivercity, Jalan Sultan Azlan Shah, 51200 Kuala Lumpur, Malaysia; e-mail: banie@lghnh.com.my; phone: +60-03-40449266 Ext: 122.

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE UK, EEA OR SWITZERLAND

 

In the following section:

“Controller” means LG H&H Co., Ltd., the company acting as controller of your personal information as that term is defined in the GDPR and Swiss Data Protection Law.

"GDPR" means the General Data Protection Regulation (EU) 2016/619 (“GDPR”), unless you are located in the UK in which case “GDPR” means the GDPR as it is saved and incorporated into United Kingdom law by the European Union (Withdrawal) Act 2018 and as modified by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

"Swiss Data Protection Law" means the Swiss Data Protection Act ("DPA"), the revised Swiss Data Protection Act ("revDPA") as well as the Swiss Ordinance on Data Protection ("ODP").

"Personal information" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Where we have referred to 'your information' in this Policy, we are referring to personal information concerning you.

"Services" means any services we provide through your interaction with the Website, and other related services, including any sales, after-sales, marketing, or events.

 

This Policy is directed at data subjects located in the UK and EEA specifically and provides all the information required to be provided by Articles 13 and 14 GDPR.

 

Purposes and legal basis of processing.  We use personal information collected via our Services for a variety of business purposes as described below.   In most cases we process your personal information for these purposes in order to pursue our legitimate business interests.

In some many situations we will have more than one purpose. For example, if you have purchased one of our products or services, we will also collect and process your personal information in order to perform our contract with you. 

In certain situation we may also process personal information concerning you in order to comply with a specific legal obligation, for instance where specific rules apply in the context of prize draws, competitions, and other promotions.  

Restricted Transfers

By its Implementing Decision of 17 December 2021 on the adequate protection of personal information by the Republic of Korea under the Personal Information Protection Act, the EU Commission determined that the Republic of Korea ensure(s) an adequate level of protection for personal information. Pursuant to this decision, transfers of personal information to the Republic of Korea may take place without the need to obtain any further authorization.  This Implementing Decision of 17 December 2021 has been recognized by the UK Secretary of State.

The foregoing decision does not apply to transfers of personal information from Switzerland to the Republic of Korea. If you provide us with your personal information by using our Services or the App, please acknowledge that you are providing personal information to a controller in a country that, from a Swiss perspective, provides no adequate level of data protection. 

UK/EU/SWITZERLAND DATA PROTECTION RIGHTS

Under the GDPR, and other data protection law applicable in the EEA, UK and Switzerland, including Swiss Data Protection Law, you have certain specific rights relating to your personal information which are set out below.  

  1. Access – In all circumstances you have the right to access your personal information and certain information about how and why we are processing it, including, in most cases copies of personal information that we process
  2. Rectification – In all circumstances you have the right to have any inaccurate or incomplete personal information rectified without undue delay

The following rights do not apply in all circumstances.  However, you are always welcome to contact us with any request relating to processing of your personal information and, even if we are not obliged by law to comply with your request, we will try to accommodate your wishes.

  1. Erasure – sometimes called the ‘right to be forgotten’, in certain circumstances, you have the right to have your personal information erased without undue delay
  2. Restriction - in certain circumstances, you have the right to have our processing of your personal information restricted
  3. Data portability - in certain limited circumstances, you have the right to receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance
  4. Objection - in circumstances where we are processing personal information that concerns you on the lawful basis of legitimate interest only, you have the right to object to the processing of your personal information carried out by us or on our behalf.
  5. Withdrawal of Consent – If you have provided us with your consent to process your data, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

Making A Complaint

Although we would strongly encourage you to let us try and resolve any issue you have regarding your personal information first, in all cases where you think we have not complied with the requirements of the GDPR or Swiss Data Protection Law as it applies to your personal information, and in addition to your rights set out above, you have a right to lodge a complaint with a Data Protection Supervisory Authority.

If you are located in the UK, you can send your complaint directly to the Office of the Information Commissioner (ICO): casework@ico.org.uk or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk.

If you are located in the EEA, you can send your complaint directly to the Supervisory Authority in the relevant EU member state, details of which can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are located in Switzerland, you can send your complaint directly to the Swiss Supervisory Authority: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

If you are located in Australia, you may contact the Office of the Australian Information Commissioner (OAIC) by:

  • calling their Privacy Hotline on 1300 363 992;
  • visiting the OAIC website; or
  • writing to:

The Australian Information Commissioner

GPO Box 5218

Sydney NSW 1042

 

ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA

 

California Privacy Rights. If you are a resident of the state of California, you have the following additional rights:

  1. Right to Know/Access. You have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information. 
  2. Right to Correct/Rectification. You have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate. As described above, you may be able to update certain types of information through your account settings.
  3. Right to Delete/Erasure. Under certain circumstances, you have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation, or if there are compelling legitimate grounds for keeping your personal information. As described above, you can exercise this right through your account settings.
  4. Right to Portability. Under certain circumstances, you have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.
  5. Right to Opt-Out of Selling and Sharing for Targeted Advertising. You may have the right to opt-out of: (i) the sale of your personal information; and (ii) the sharing of your personal information for targeted advertising. While we do not sell your personal information for money, like many websites, we use cookies, pixels, and similar technology, and we share certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under California privacy law’s broad definition of “sell”, this could be considered a sale, and it would be considered sharing of your personal information for targeted, behavioral advertising purposes. You have the right to direct us not to sell your personal information, and to direct us not to share or use your personal information for targeted advertising purposes. To exercise your right to opt-out, please submit a request by clicking here. You may also opt-out by using an opt-out preference signal, which we will honor and process for you in a frictionless manner. To start using an opt-out preference signal, please refer to the instructions provided here. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our website.  Please note that you may still receive generalized ads after opting out of targeted advertising. For information about how to opt-out of sharing or selling on our mobile application, please see refer to the “Mobile App Advertising” subsection within the Cookies and Other Tracking Technologies Section of this Policy.
  6. Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
  7. Right to Limit the Use of Sensitive Personal information. You have the right to limit the use of sensitive personal information used to infer characteristics about you. We do not collect sensitive personal information or use it to infer characteristics.
  8. Right to Object to Automated Decision-Making. Upon issuance of regulations by the California Privacy Protection Agency, you will have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
  9. Shine the Light. California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. As we do not disclose any categories of personal information to third parties for direct marketing purposes, we do not offer you the right to request and obtain such information.  

In addition to the methods specified above, you may exercise these CA privacy rights by: (i) emailing us at privacy@lghnh.com with the subject line “CA Privacy Rights Request”, or (ii) calling us at +82-31-8045-1431 (Monday – Friday 9:00 AM ~ 6:00 PM (KST), except on holidays). 

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THAILAND

 

“PDPA” means the Personal Data Protection Act B.E. 2562 (2019).

“PDPC” means the Personal Data Protection Committee, which acts as the supervisory authority responsible for overseeing the protection of personal information in Thailand.

 

Collection of Personal Information from Minors in Thailand

We do not knowingly solicit data from or market to children under 20 years of age. By using the Services, you represent that you are at least 20 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 20 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 20 years of age, please contact us at privacy@lghnh.com.   

 

Restricted Transfers

If you are located in Thailand, we may transfer your personal information outside Thailand when it meets one of the following conditions, in accordance with the PDPA:

  1. The destination countries that receive your personal information have an adequate level of data protection as prescribed by the PDPC.
  2. The privacy policy regarding the transfer of your personal information to a foreign affiliated company or group of undertakings, known as Binding Corporate Rules, has been put in place and certified by the PDPC.
  3. The data controller has implemented appropriate protection measures that enable the execution of your rights under the PDPA, including appropriate remedial measures, as prescribed by the PDPC.
  4. The transfer of your personal information is for compliance with Thai law.
  5. Your consent has been obtained, authorizing the transfer of your personal information to a destination country that may have inadequate personal data protection standards.
  6. The transfer of your personal information is necessary to fulfil contractual obligations with you.
  7. The transfer of your personal information is necessary to carry out a contractual agreement between two entities for your benefit.
  8. The transfer of your information is required to ensure your safety to prevent further harm to your health when you are unable to provide consent at the time.
  9. The transfer of your information is necessary for substantial public interest.

 

Data Protection Rights

Under the PDPA, you have rights relating to your personal information which are set out below.  

  1. Withdrawal of Consent – If you have provided us with your consent to process your information, you have the right to withdraw your consent at any time, unless there is a restriction of the withdrawal of consent by law, or the contract that benefits you. The withdrawal of your consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

 

  1. Right to Access – You have the right to access and request a copy of your personal information. You also have the right to request disclosure of the acquisition of your personal information obtained without your consent.

 

  1. Right to Data Portability - In cases where we arrange your personal information in a structured, commonly used, and machine-readable format that can be transmitted via automated means, you have the right to transmit that data to another data controller using automated means. You also have the right to receive your personal information in such a format, except in situations where technological limitations prevent this.

 

  1. Right to Objection - In circumstances where we are processing personal information that concerns you on the lawful basis of legitimate interest or for direct marketing purposes, you have the right to object to the processing of your personal information carried out by us or on our behalf.

 

  1. Right to Erasure – You have the right to have your personal information erased or disposed of, or anonymized in the following circumstances:

(i) When the purpose of personal information processing has expired.

(ii) When you withdraw your consent, and we have no legal basis to retain your personal           information.
                   (iii) When you raise objections during the processing of your personal information.

(iv) When your personal information has been unlawfully processed.

 

  1. Right to Restriction - You have the right to have our processing of your personal information restricted in the following circumstances:

(i) When your request for rectification of your personal data is pending. 

(ii) When your personal information should be erased, but you have requested restriction of processing instead.

(iii) When the periods of the processing have expired, but you have requested restriction of processing instead due to legal reasons

(iv) During the verification process of your objection to the processing of personal information.

 

  1. Right to Rectification – You have the right to rectify your personal information to be accurate, up-to-date, complete, and not misleading.

 

  1. Right to File a Complaint Although we would strongly encourage you to let us try and resolve any issue you think we have not complied with the requirements of the PDPA as it applies to your personal information, and in addition to your rights set out above, you have a right to lodge a complaint with the Personal Data Protection Commission Office (PDPC). You can send your complaint directly to the Personal Data Protection Commission Office (PDPC): saraban@pdpc.or.th

 

ADDITIONAL INFORMATION FOR RESIDENTS OF MONGOLIA

 

Mongolia Privacy Rights. If you are a resident of Mongolia, you have the following additional rights pursuant to the Law of Mongolia on the Protection of Personal Information:

  1. Right to opt out - you have the right to voluntarily give or refuse to give consent to collect and transfer your personal information; 
  2. Right to know - you have a right to know whether your personal information has been collected, processed, or used; the terms and conditions of the consent; and about any third party, if your data has been transferred to such; or is to be transferred; 
  3. Right to correct - you have a right to inquire us to correct the erroneous information and provide additional information; 
  4. Right to delete - you have a right to inquire us to delete your personal information in accordance with the laws of Mongolia; 
  5. Right to demand - if it is prohibited to collect or prescribed to be erased in accordance with the laws of Mongolia, you have a right to inquire us to erase such information; 
  6. Right to portability - you have a right to obtain from us a copy of the information concerning you in paper or electronic form; 
  7. Right to transfer - you have a right to inquire us to transfer the copy of the information concerning you to other data controller of your choice;  
  8. Right to withdraw - you have a right to withdraw your consent in the process of data collection, processing, and use, and notify us about it in writing; and
  9. Right to complain - you have a right to file a complaint or comment on the decision made as a result of the processing of your personal information, to inquire to add additional information, or reprocess the information. 

In addition to the methods specified above, you may exercise these privacy rights by: (i) emailing us at privacy@lghnh.com with the subject line “MN Privacy Rights Request”, or (ii) calling us at +82-31-8045-1431 (Monday – Friday 9:00 AM ~ 6:00 PM (KST), except on holidays).

 

ADDITIONAL INFORMATION FOR CITIZENS AND RESIDENTS OF THE PHILIPPINES

 

Philippine Privacy Rights. If you are a citizen or resident of the Philippines, you have the following rights:

  1. Right to be Informed. You have the right to be informed whether your personal data shall be, are being, or have been processed, including the existence of automated decision-making and profiling. You will be notified and furnished with information regarding the processing of your personal data before it is entered into our processing system, or at the next practical opportunity.
  2. Right to Object. You have the right to object to the processing of your personal data, including processing for direct marketing purposes, or processing involving automated processing, or profiling.
  3. Right to Access. You have the right to reasonable access to: (i) contents of your personal data that were processed; (ii) sources from which your personal data were obtained; (iii) names and addresses of recipients of your personal data; (iv) manner by which such data were processed; (v) reasons for the disclosure of your personal data to recipients, if any; (vi) information on automated processes where the data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you; (vii) date when your personal data were last accessed and modified; and, (viii) the designation, name or identity, and address of the controller.

 

  1. Right to Rectification. You have the right to dispute the inaccuracy or error in your personal data and have the controller correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable.

 

  1. Right to Erasure or Blocking. Under certain circumstances, you have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from our filing system.

 

  1. Right to Data Portability. You have a right to obtain a copy of your data in an electronic or structured format that is commonly used and allows for your further use.

 

  1. Right to Damages. You have the right be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal data.

 

Processing for personalized advertising purposes or processing of sensitive personal information. Where

we process and share your personal information for personalized advertising purposes or where we

process your sensitive personal information, we will obtain your informed, specific, and opt‐in consent to

such processing.

 

Making a Complaint. Although we would strongly encourage you to let us try and resolve any issue you have regarding your personal information first, in all cases where you think we have not complied with the requirements of applicable law as it applies to your personal information, and in addition to your rights set out above, you have a right to lodge a complaint with the Philippine National Privacy Commission.

In addition to the methods specified above, you may exercise these privacy rights by: (i) emailing us at privacy@lghnh.com with the subject line “PH Privacy Rights Request”, or (ii) calling us at +82-31-8045-1431 (Monday – Friday 9:00 AM ~ 6:00 PM (KST), except on holidays).

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN TAIWAN

 

Taiwan Privacy Rights. Pursuant to Article 3 of Personal Data Protection Act, if you are a citizen or resident of Taiwan, you are able to exercise the following rights with regard to your personal data and such rights shall not be waived or limited contractually in advance: 

  1. The right to make an inquiry of and to review your personal data;
  2. The right to request a copy of your personal data;
  3. The right to demand the cessation of the collection, processing or use of your personal data; and
  4. The right to erase your personal data.

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN AUSTRALIA

 

Access and Correction

Under the Privacy Act 1988 (Cth), you have a right to access your Personal Information that is held by us. You also have a right to request corrections to any personal information we hold about you if you think it is inaccurate, out-of-date, incomplete, irrelevant or misleading. To access, update or correct your personal information, please contact us at privacy@lghnh.com with the subject line “AU Privacy Rights Request” or call us at +82-31-8045-1431 (Monday – Friday 9:00 AM ~ 6:00 PM (KST), except on holidays). 

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN SINGAPORE

 

In the following section:

"PDPA" means the Singapore Personal Data Protection Act 2012 and its accompanying subsidiary legislation as amended from time to time.

"Personal Data" means data, whether true or not, about an individual who can be identified – 

  1. from that data; or
  2. from that data and other information to which we have or is likely to have access.

This privacy policy is directed at data subjects located in Singapore specifically. All references to “personal information” in this privacy policy shall be deemed to be a reference to “Personal Data”.

Purposes and legal basis of processing.  We collect, use and disclose Personal Data for a variety of legal and business purposes as described in this privacy policy or otherwise notified to you.  In most cases we process your Personal Data for these purposes in order to pursue our legitimate interests.

In some many situations we will have more than one purpose. For example, if you have purchased one of our products or services, we will also collect and process your Personal Data for the purposes for which you voluntarily provided the data and in order to perform our contract with you. 

We will seek your prior consent in respect of marketing and promotional communications as well as targeted advertising. You have the right to withdraw your consent or opt-out as described in this privacy policy. 

Transfer Outside of Singapore

If we transfer Personal Data to a country or territory outside Singapore, we shall ensure that it is protected to a standard of protection that is at least comparable to the protection under the PDPA in the manner prescribed in the relevant regulations under the PDPA. 

Protection of Personal Data and Data Breach Notification

We shall protect Personal Data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks and the loss of any storage medium or device on which Personal Data is stored.

We shall notify you (in accordance with and subject to the PDPA) in the event of a data breach affecting your Personal Data which may cause significant harm.

SINGAPORE DATA PROTECTION RIGHTS

  1. Access – You may request to access your Personal Data in our possession or enquire about the ways in which your Personal Data may have been used or disclosed by us for the past year.
    1. Correction – You may request to correct any error or omission in your Personal Data records.
    2. Withdrawal of Consent – If you have provided us with your consent to process your data, you have the right to withdraw your consent at any time. Please note that the withdrawal of your consent does not affect (i) the legality of the processing carried out on the basis of the consent until the withdrawal and (ii) our collection, use and disclosure of your Personal Data without your consent as permitted or required by law

You may exercise these rights by: (i) emailing us at sharifah.z@lghnh.com.sg, or (ii) calling us at +65 6287 3094 (Monday – Friday 9:00 AM ~ 6:00 PM (SGT), except on holidays).

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE UAE

 

UAE DATA PROTECTION RIGHTS

Under the data protection laws applicable in the UAE, you have certain specific rights relating to your personal information which are set out below.  

  1. Access – In all circumstances you have the right to access your personal information and certain information about how and why we are processing it, including, in most cases copies of personal information that we process
    1. Rectification – In all circumstances you have the right to have any inaccurate or incomplete personal information rectified without undue delay

The following rights do not apply in all circumstances.  However, you are always welcome to contact us with any request relating to processing of your personal information and, even if we are not obliged by law to comply with your request, we will try to accommodate your wishes.

  1. Erasure – sometimes called the ‘right to be forgotten’, in certain circumstances, you have the right to have your personal information erased without undue delay
  2. Restriction - in certain circumstances, you have the right to have our processing of your personal information restricted
  3. Data portability - in certain limited circumstances, you have the right to receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance
  4. Objection and Stop Processing- in circumstances where we are processing personal information that concerns you, you have the right to object to the processing of your personal information carried out by us or on our behalf. 
  5. Withdrawal of Consent – If you have provided us with your consent to process your data, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal. 

ADDITIONAL INFORMATION FOR RESIDENTS OF VIETNAM

If you are a resident of Vietnam, you have the following additional rights and obligations:

  1. Your rights as a data subject

You shall have the rights set out below, together with and any other rights as may be provided by the laws of Vietnam from time to time:

  1. Right to be informed. you have the right to be informed of your personal information processing, unless otherwise provided by the laws of Vietnam.
  2. Right to give consent. You have the right to give consent to the processing of your personal information, unless otherwise provided by the laws of Vietnam.
  3. Right to access your personal information. You have the right to access your personal information in order to view, rectify or request rectification of your personal information, unless otherwise provided by the laws of Vietnam.
  4. Right to withdraw consent. You have the right to withdraw your consent, unless otherwise provided by the laws of Vietnam. 
  5. Right to delete your personal information. You have the right to delete or request deletion of your personal information, unless otherwise provided by the laws of Vietnam.
  6. Right to obtain restriction on processing of your personal information. You have the right to obtain restriction on the processing of your personal information, unless otherwise provided by the laws of Vietnam.  
  7. Right to obtain your personal information. You have the right to request your personal information to be provided, unless otherwise provided by the laws of Vietnam.
  8. Right to object to processing of your personal information. You have the right to object your personal information to be processed in order to prevent or restrict the disclosure of your personal information or the use of your personal information for advertising and marketing purposes, unless otherwise provided by the laws of Vietnam.   
  9. Right to file complaints, denunciations and lawsuits. You have the right to file complaints, denunciations and lawsuits as prescribed by the laws of Vietnam.
  10. Right to claim damage. You have the right to claim damage as prescribed by the laws of Vietnam when there are violations against regulations on protection of your personal information, unless otherwise agreed by parties or unless otherwise prescribed by the laws of Vietnam.
  11. Right to self-protection. You have the right to self-protection or request the relevant State agencies and organisations to implement civil right protection methods in accordance with the laws of Vietnam. 
  1. You obligations as a data subject 

You shall have the following obligations:

  1. To protect your personal information, request other relevant organisations and individuals to protect your personal information. 

 

  1. To respect and protect personal information of others. 

 

  1. To provide complete and accurate your personal information when agreeing to allow the processing of your personal information. 

 

  1. To participate in propagating and disseminating skills to protect personal information.

 

  1. To implement relevant provisions of the laws of Vietnam relating to personal data protection and participate in preventing and combating violations of regulations on personal data protection.

ADDITIONAL INFORMATION FOR TURKISH DATA SUBJECTS

If you are a Turkish data subject, you have the following additional rights in accordance with Article 11 of the Law No. 6698 on Protection of Personal Data (“DPL”), 

  1. You have the right to learn whether your personal data is being processed, 
  2. You have the right to request relevant information if your personal data have been processed, 
  3. You have the right to obtain information as to the purpose of processing and whether such data have been processed accordingly, 
  4. You have the right to know the third parties within or outside the country to whom personal data is transferred, 
  5. You have the right to ask for the rectification of any incomplete or inaccurate personal data process, 
  6. You have the right to ask for the erasure or destruction of the personal data within the framework of the conditions stipulated under Article 7 of DPL, 
  7. You have the right to request the notification to third parties to whom the personal data have been transferred of operations carried out within the meaning of correction, erasure or destruction of the personal data, 
  8. You have the right to object to any conclusion to the detriment of yourself which results from analysis of the processed data exclusively by means of automated systems, and 
  9. You have the right to request compensation for the damages incurred as a result of an unlawful personal data processing.

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN MALAYSIA

This section applies to data subjects located in Malaysia specifically. In this section, the term “processing” shall have the same meaning as prescribed in the Malaysia Personal Data Protection Act 2010 (“MY PDPA”).

 

Consent 

This Policy serves to inform you that your personal information is being processed by us or on our behalf and you hereby give your consent to the processing of your personal information in accordance with this Policy. 

 

Your rights as a data subject

As a data subject you have the following legal rights granted by the MY PDPA relating to the personal information we process about you, if the MY PDPA applies to you or the processing of your personal information:

 

  1. Data access and correction requests   You have the right to request access to and to request correction of your personal information subject to the following and subject to provisions of the MY PDPA: (a) you may, upon payment of a prescribed fee (if any), make a data access request or a data correction request in writing to us; and (b) we may refuse to comply with your data access request or a data correction request pursuant to the MY PDPA and shall, by notice in writing, inform you of our refusal and the reasons of our refusal. 

 

  1. Limiting the Processing of Personal Information  You may, by providing us with a notice in writing, limit the processing of your personal information (including to request us to cease or not begin processing your personal information for purposes of direct marketing) or withdraw your consent previously given to us (in full or in part) to the processing of your personal information. If you limit the processing or withdraw your consent to any or all use of your personal information, we may not be in a position to continue to administer any arrangement or contractual relationship in place, which in turn may result in: (i) us being unable to (or continue to) process your personal information for any of the purposes stipulated in this Policy; (ii) unable to (or continue to) perform our contractual obligations owed to you (if any); and/or (iii) the termination of any arrangements/agreements/contracts you have with us, without any liability on our part. 

 

Additional Contact Details 

You may contact us with any inquiries or complaints in respect of your personal information via the methods below:

Items

Details

Designation:

Malaysia representative (staff)

Telephone No.:

+60-03-40449266 Ext: 132

Address:

LG Household & Health Care Malaysia Sdn Bhd Lot 468-7B & 7C, 1st Floor, Rivercity, Jalan Sultan Azlan Shah, 51200 Kuala Lumpur, Malaysia

E-mail address:

vivianchoo@lghnh.com.my

 

Personal Information of Minors 

In respect of personal information relating to a minor (i.e. individuals under the age of 18), you confirm that you are the parent or legal guardian or person who has the parental responsibility for the said minor to consent on his/her behalf to the processing of his/her personal information in accordance with this Privacy Policy. 

 

Obligatory Personal Information

It is obligatory that you supply us the details marked or specified as compulsory in our forms (collectively, “compulsory personal information”).  If you fail to supply us with any of the compulsory personal information, we may refuse to, or may be unable to, process your personal information for any of the purposes specified in this Policy. 

 

Language

In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Policy, the English version shall prevail over the Bahasa Malaysia version.

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN JAPAN

“APPI” means the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003).

TBA” means Telecommunications Business Act (Act No. 86 of 1984).

User Related Information” means cookie ID, IP address, device IDs, advertising IDs and other identifiers transmitted via technologies such as cookies or pixels about you (whether a natural person or legal entity) that is recorded in your electronic device(s) (such as a computer, laptop, tablet, smartphone, etc.).

 

Transactions involving Third Parties: We make available to you services, products, applications, or skills provided by third parties for use on or through the Services. For example, you can order products from third parties through our stores, download applications from third-party application providers from our store, and enable third-party skills through our Services. When you place an order from a third party, information related to the order will be provided to such third-party seller, including to sellers located outside of Japan, and such information will be subject to the third-party seller’s privacy policy. Foreign sellers who sell products on our store are required to commit to us that they adopt measures to protect personal information. You can see more information about a third-party seller on that seller’s information page. 

Other than those provided in this Policy, you will receive a notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

INFORMATION PROVIDED UNDER TELECOMMUNICATIONS BUSINESS ACT OF JAPAN 

External transmission of User Related Information.

We and/or third-party service providers may request to transmit information about any User Related Information to the electronic equipment (e.g., web servers) of a third party when the Services are provided to you.

User Related Information.

We use the User Related Information to recognize your browser or device, learn more about your interests, provide you with essential features and the Services, and for additional purposes. Approved third parties may also utilize User Related Information when you interact with the Services. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies, among others. Third parties use User Related Information to deliver content (including ads relevant to your interests), measure effectiveness, and perform services on behalf of us.

Use of User Related Information for Third-Party Advertising Services, etc.

We provide ad companies and third-party service providers with information that allows them to serve you with more useful and relevant the Services and to measure their effectiveness. We never share your name or other information that identifies you when we do this. Instead, we use an advertising identifier like a cookie, a device identifier, or a code derived from applying irreversible cryptography to other information like an email address. For example, if you have already downloaded one of our apps, we will share your advertising identifier and data about that event so that you will not be served an ad to download the app again. Some ad companies also use this information to serve you relevant ads from other advertisers.

Third Party Recipients of User Related Information.

When you use any Service, it may include sharing your User Related Information with our entity or affiliate, or a third-party (collectively “Recipients”). Recipients may collect your User Related Information when you interact with their content, advertising, and/or services. The third-party recipients of User Related Information, and the purposes of using the User Related Information, include the following:

  1. EXIMBAY

Address: 111, Digital-ro 26-gil, Guro-gu, Seoul, Republic of Korea

Purpose: EXIMBAY is a payment service provider and may use the User Related information for processing payments securely.  

  1. EXUS

Address: 72, Mangwon-ro 11-gil, Mapo-gu, Seoul, Republic of Korea

Purpose: EXUS may use the User Related information for developing and building a Direct-to-Consumer website.

  1. LB Ucess

Address: 661, Gyeongin-ro, Guro-gu, Seoul, Republic of Korea

Purpose: LB Ucess is a customer service provider and may use the User Related information for managing consumer inquiries, addressing claims, and handling customer service tasks.

  1. Google

Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Purpose: Google may use the User Related information for utilizing digital marketing tools. 

  1. Cafe 24

Address: 15, Boramae-ro 5-gil, Dongjak-gu, Seoul, Republic of Korea

Purpose: Cafe 24 may use the User Related information for developing and building a Direct-to-Consumer platform.

  1. VIVA REPUBLICA INC.

Address: 142, Teheran-ro, Gangnam-gu, Seoul, Republic of Korea

Purpose: VIVA REPUBLICA INC. is a payment service provider and may use the User Related information for processing payments securely.

 

ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN INDONESIA 

 

“PDP Law” means the Law No. 27 of 2022 regarding Personal Data Protection, dated October 17, 2022, and all amendments and superseding regulations thereto, along with its implementing legislations and all amendments and superseding regulations thereto.

Rights as a Data Subject

If you are a citizen or resident of the Republic of Indonesia, you shall have the rights set out below as a data subject, together with and any other rights as may be provided by the laws of Indonesia from time to time:

  1. Right to Access, Delete and Correct. You are entitled to access, correct, and delete tour Personal Data under our possession and/or control, exercisable by serving written notification delivered in hand, phone call or by email to our representative to access, correct, or delete your Personal Data.

 

  1. Right to Erase, Destroy, and Revoke Consent to the Processing. You are entitled to erase, destroy, and revoke your consent for the processing of your Personal Data in accordance with the applicable personal data protection regulations, exercisable by serving written notification delivered in hand or by email to our representative. 

 

Transfer Outside of Indonesia.

If we transfer Personal Data to a country or territory outside Indonesia, we shall ensure that it is protected to a standard of protection that is at least comparable to the protection under the PDP Law in the manner prescribed in the relevant regulations under the PDP Law. 

Data Breach.

We shall protect Personal Data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks and the loss of any storage medium or device on which Personal Data is stored.

In the event of a failure of Personal Data protection, we shall notify you by no later than 3 x 24 (three times twenty-four) hours (and in accordance with and subject to the PDP Law) in the event of a data breach affecting your Personal Data which may cause significant harm.