For Customer to Agree:By providing ONSMART with my personal data, I agree that ONSMART may collect, use and disclose my personal data for purposes in accordance with its Privacy Policy and the Personal Data Protection Act 2012.

1. INTRODUCTION
2. PERSONAL DATA THAT COLLECT FROM YOU
3. USAGE AND DISCLOSURE OF PERSONAL DATA
4. UPDATING PERSONAL DATA
5. REQUEST TO WITHDRAW CONSENT
6. CHILDREN AND KIDS BELOW 18 YEARS OLD
7. THIRD PARTY COOKIES
8. GOVERNING LAW
9. ONSMART’S RIGHTS TO DISCLOSE PERSONAL DATA
10. LANGUAGE OF THIS POLICY

INTRODUCTION

ONSMART recognizes that privacy is a fundamental human right and further recognizes the important of privacy, security and data protection to our customers and partners. We totally committed to protecting the privacy of our customer. Hence, we will only collect, record, retain, store, disclose, transfer and use your personal information as outlined below.

1.1 ONSMART takes its responsibilities in relation to protecting your Personal Data and compliance with Applicable Laws very seriously. We are committed to properly managing, protecting and processing your Personal Data in accordance with this Policy, which shall apply to all Personal Data we collect from you through our Platforms.Please read and review this Policy, which will inform you how we collect, use, process and disclose your Personal Data. We may also collect and process your Personal Data under any exceptions to Applicable Laws, which are not set out in this Policy. We trust that it will assist you in making an informed decision whether to provide us with any of your Personal Data.For the purposes of understanding ONSMART’s Personal Data Protection Policy (“Policy”), capitalised terms used in this Policy shall have the following meanings:

1. “Applicable Laws” means Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations as amended from time to time;
2. "Apps"means our ONSMART’s mobile app on iOS and Android and any other app we may own or operate from time to time;
3. “Personal Data” means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any applicable Data Protection Laws.
4. “Platforms”means collectively OnSmart’s Apps, Social Media and Website, and any other websites or applications which we may own or operate from time to time;
5. “Social Media”means OnSmart’s pages and accounts on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+’
6. “Website” means the OnSmart website accessed at the following address www.onsmart.com; and
7. “OnSmart, we, us, or our” means ONSMART team or AddOn Systems Singapore Pte Ltd or its wholly owned subsidiary AddOn Systems Singapore Pte Ltd.

During our relationship with you, we may collect Personal Data from you. Examples of the types of Personal Data we may collect include your name, contact details, mailing and delivery addresses, email address, birthday, network and device data (including your IP address and device or advertising identifiers), your shopping or browsing behaviours, facial image, voice recording (for customer service calls) and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us. If you provide us with Personal Data relating to a third party by submitting such Personal Data 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. By (1) clicking “Yes” on our Policy pop-up or any web form referring to this Policy on any of our online platforms, (2) submitting your Personal Data to us when signing up for an account on the Website, (3) browsing our Website, or (4) ordering any of our products and services, you are agreeing to the terms of this Policy. We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.

PERSONAL DATA THAT COLLECT FROM YOU

We collect Personal Data from you when:

1. You register an account on the Website or the Apps;
2. You use any of our related services, such as subscribing to our newsletter, product notifications;
3. You browse our products and services or otherwise interact with our Website and Apps;
4. You accept our cookies on your device;
5. You interact with our customer experience team or other representatives, for example, via our webform, emails, telephone calls, letters, or face-to-face meetings;
6. You interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;
7. You participate in our promotions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
8. We receive references from business partners and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;
9. Your authorized representative submits your Personal Data to us for any purpose reasonably authorized by you, for example if such representative is purchasing our product or service to be delivered to you or as a gift;
10. Our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
11. When you voluntarily submit your Personal Data to us for any reason.

We usually do not collect your credit card details, whether to process your payment or for customer service purposes. Your credit card details are collected, processed and stored directly by our third-party payment processors pursuant to their terms of use and privacy policies. None of your credit card details are stored with us. However, we may collect your bank account details to process refunds.We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the products and services you have requested.

USAGE AND DISCLOSURE OF PERSONAL DATA

In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:

1. employees, consultants, temporary workers;
2. ONSMART’s distributor partners, who supply and deliver the products or services you ordered through the Website or Apps;
3. payment processors, who process your payment on the Website and the Apps;
4. logistics providers, such as courier services which will deliver your order to you;
5. business partners who separately maintain an account with you for loyalty or point redemption programs, such as AirAsia Big;
6. business partners or vendors in connection with the processing of any promotion, event or service organised by us;
7. professional advisers and consultants;
8. agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
9. any other party whom you authorize us to disclose your Personal Data to.

We may use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:

• register and maintain your user account and to verify your identity or age;
• process your order for our products or services, process or collect your payment for the order;
• deliver or perform the products or services you purchased, including our couriers calling or messaging you to obtain your delivery instructions;
• process your returns or refunds in accordance with our Terms of Service;
• provide you with supporting services and functions related to your user account, such as saved items in cart, wish list, brand or product notifications;
• communicate with you in relation to (i) your queries, requests and feedback, (ii) material changes to our Website or Apps Terms of Service, Policy or other terms and conditions, and (iii) matters relating to the operation of your account;
• personalise and improve your customer experience when you visit the Website and the Apps, for example by prioritizing products and services appearing in your search results or feed;
• monitor and enforce compliance with our Terms of Service, including dispute resolution;
• ensure our Website and Apps function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Website and Apps.

(collectively, the "Purposes")In addition, we may use and disclose your Personal Data for the following purposes, to:

• send you marketing communications in relation to our sales, products, services, promotions or the Platforms;
• send you marketing communications in relation to the sales, products, services or promotions of business partners, including promotional mail together with your order;
• deliver ads which are related to our products and services which may be of interest to you on the Platforms or other websites, apps or online platforms;
• enable businesses to deliver ads which are related to their products and services which may be of interest to you;
• provide you with our add-on or premium services such as Premium Care;
• invite you to our private customer events;
• process your participation in our promotions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
• process your participation in our business partners’ loyalty or point redemption programs;
• conduct market and customer research, analysis or tracking;
• promote our products and services on our Platforms;
• manage the administrative and business operations of ONSMART and complying with internal policies and procedures;
• improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
• any specific purpose in relation to a certain product or service, which we may separately notify you on the product or service page;

(collectively, the “Additional Purposes”) We may also disclose your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws. We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose. Note: If you withdraw your consent for us to use and process your Personal Data the Purposes or the Additional Purposes, we may no longer be able to provide you with the related products, services or benefits associated with our promotion.

UPDATING PERSONAL DATA

You may access or correct your name, birthday, shipping and billing addresses by logging in to your user account on the Website or Apps under “Account Information” and clicking the “Edit” button under each relevant field. For Personal Data that cannot be corrected by you by logging in to your user account on the Website or Apps, you may request to access and correct such Personal Data by submitting a written request to us via Contact US link. We may need to request additional information from you to confirm your identity before providing the access or making the correction. We reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request. We will do our best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws.

REQUEST TO WITHDRAW CONSENT

You may communicate the withdrawal of your consent to the continued use or disclosure of your personal data for any of the purposes and in the manner as stated above at any time or request the deletion or anonymisation of your personal data, by contacting our Data Protection Officer using the contact details provided above. Please note that if you communicate your withdrawal of your consent to our use or disclosure of your personal data for the purposes and in the manner as stated above, or request the deletion or anonymisation of your personal data, we may not be in a position to continue to provide our products or services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide our products or services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.

CHILDREN AND KIDS BELOW 18 YEARS OLD

ONSMART does not sell products for purchase by children under [18] years of age, nor does it intend to provide any of the Services or the use of the Platform to children under [18] years of age. We do not knowingly collect any personal data relating to children under [18] years of age. If you are under 18 years old, you may use our website only with the involvement of a parent or guardian.

THIRD PARTY COOKIES

Google Analytics ONSMART uses certain Google Analytics functions. Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking. ONSMART may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. ONSMART also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show ONSMART ads on sites across the Internet. ONSMART and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors’ past visits to ONSMART, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to ONSMART. When you log on to the ONSMART website, ONSMART with the help of Google Analytics may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this policy. For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Data Protection Officer via Contact Us link. Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.

Update on Data Protection Policy

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, ONSMART may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Website. Any amended Policy will be posted on our website and can be viewed at www.onsmart.sg/ (data protection link) By continuing to use our Platforms and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy. You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection. The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.

GOVERNING LAW

This Policy and your use of this Website shall be governed in all respects by the laws of Singapore for every purpose.

ONSMART’S RIGHTS TO DISCLOSE PERSONAL DATA

YOU ACKNOWLEDGE AND AGREE THAT ONSMART HAS THE RIGHT TO DISCLOSE YOUR PERSONAL DATA TO ANY LEGAL, REGULATORY, GOVERNMENTAL, TAX, LAW ENFORCEMENT OR OTHER AUTHORITIES OR THE RELEVANT RIGHT OWNERS, IF ONSMART HAS REASONABLE GROUNDS TO BELIEVE THAT DISCLOSURE OF YOUR PERSONAL INFOMARTION IS NECESSARY FOR THE PURPOSE OF MEETING ANY OBLIGATIONS, REQUIREMENTS OR ARRANGEMENTS, WHETHER VOLUNTARY OR MANDATORY, AS A RESULT OF COOPERATING WITH AN ORDER, AN INVESTIGATION AND/OR A REQUEST OF ANY NATURE BY SUCH PARTIES. TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, YOU AGREE NOT TO TAKE ANY ACTION AND/OR WAIVE YOUR RIGHTS TO TAKE ANY ACTION AGAINST ONSMART FOR THE DISCLOSURE OF YOUR PERSONAL DATA IN THESE CIRCUMSTANCES.

LANGUAGE OF THIS POLICY

In accordance with the requirements of Applicable Laws, this Policy is issued in English.