Privacy Policy

This privacy notice and its addendum(s) (collectively, “Privacy Policy”) describes how SicPama Pte. Ltd. a company incorporated under the laws of Singapore bearing company registration number: 202309509W, its respective subsidiaries, affiliates, associated companies and jointly controlled entities, including SicPama Co., Ltd. (collectively, “Sicpama”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Sicpama’s website (“Website”), as well as service, features and other services globally, operated by Sicpama (collectively, “Services”).

This Privacy Policy applies to our users (such as diners) (each a “user”, “you”, or “your”).

By using the Services, or providing any personal information to Sicpama through the Services, you consent to the terms set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please discontinue your use of the Services and do not provide any personal information to us through the Services.

“Personal Data” or “personal information” is any information which can be used to directly or indirectly identify you (e.g. your name or photo) or from which you are directly or indirectly identifiable (e.g. on the basis of a user ID linked with the personal information in your profile). This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, e-mail address, your image, government-issued identification number, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information, as the case may be, and to the extent provided to us in the course of your use of the Services.

This Privacy Policy describes the types of Personal Data we collect from visitors to, and users of, our Services. The Privacy Policy also sets forth how we use such Personal Data, provides other details about our practices in relation to such Personal Data, and explains how to contact us if you have any questions or concerns. By visiting, and/or using, our Services, you agree and where required you consent to the collection, use and transfer of your Personal Data in the manner set out in this Privacy Policy.

We would like to inform you that we are a proud member of the Sicpama Group, and as a cohesive family, we make decisions together. SicPama Co., Ltd. in the Republic of Korea, being the head office of Sicpama Group, plays a key role in determining the methods and purposes for processing your Personal Data. Your personal information collected by in Singapore by SicPama Pte. Ltd. may also be accessible by SicPama Co., Ltd and other members of Sicpama. This collective responsibility within the Sicpama group of companies ensures that you can conveniently access our services across different countries.

Collection of personal data

Your Personal Data will enable us to provide you with access to the relevant parts of the Services and to supply the Services you have requested. It will also enable us to contact you where necessary concerning our Services. We will also use and analyse the information we collect so that we can administer, support, improve and develop our business, for any other purpose in relation to our provision of the Services, whether statistical or analytical and/or to help us prevent fraud.

An overview of the personal data we process

In this section you can find general information about the categories of Personal Data we process about you.

You will find more detailed information on our processing activities below, in the next section. But our data processing activities on the platform can be summarized by reference the main categories of Personal Data:

1. Required personal data for each feature

Membership registration: profile/nickname, phone number, email, name, date of birth, and gender.
Simple registration: profile/nickname, phone number, email, name, date of birth, and gender.
Sign up via phone number: phone number.
Mobile phone authentication: date of birth, gender, phone number, name.
Order: Order history, profile/nickname, and credit card information.
Service use: date of birth, and gender.
Customer inquiries: phone number, and e-mail address.

2. Purpose of collection and use of personal information

Profile/nickname, name, phone number, email: Identification for the purpose of facilitating use of membership service, delivery of announcements, confirmation of personal intention, transmission of other service information and advertisement information provided by Sicpama and its partners via the Services, authentication of identity required for service use, and response to customer inquiries and processing (as applicable).
Date of birth, gender: Provision of personalized services.
Order history, profile/nickname, credit card information: Verification of identity as required in relation to use of the Services.

a. Profile data (master data)

Master data includes your nickname, email address, profile picture, telephone number, gender, name and date of birth.
Master data is crucial for the provision of the Services. You will be unable to create a profile without providing your name, e-mail address and telephone number. Further, your age is required to be provided, to ensure that you are not a minor under applicable laws.

b. Order history data

This category includes the following information: name, order history, and e-mail address.
We collect this data upon receipt of receipts and sales slips, further to your use of the Services. Such data will be retained until the relevant service provision is completed, and the payment and settlement process is finalized.

c. Payment data

This includes card information (such as card number, expiry date, cvc and name of card company etc.).
We require this data in order to process your payment, initiate a refund, or cancel your order via the Services.

d. Complaints and customer consultation data

This category includes the following information: name, telephone number, e-mail address, content of the issue, visit history, and consultation transcript.
We collect this data to address and resolve complaints and provide customer consultation. The data will be retained until the complaint handling and customer consultation process and complaint resolution have been completed.

e. Cookies

Cookies are small data files that are transferred to your device, allowing it to recognize and identify your device. They enable your device to store and remember information from the Services for future use. Cookies are used to track the visiting and usage patterns of each service and website visited by users, including popular search terms and security access status, in order to provide users with optimized information. This information helps us enhance and improve your overall user experience. It is important to note that cookies do not contain any personally identifiable information, and we do not use cookies to obtain such information. Your Personal Data can only be obtained by our partner service providers if you voluntarily provide it to us. If you prefer, you can refuse cookie storage by adjusting the options in your web browser or device (as the case may be) (e.g. “Tools > Internet Options > Privacy menu”). However, please note that refusing cookie storage may cause difficulties in accessing personalized Services.

Sicpama utilizes Google Analytics, a web analysis service provided by Google, Inc. ("Google"), to analyze and evaluate how users utilize the Services, understand user demand, and improve and personalize the Services and products in order to provide efficient Services. For the avoidance of doubt:

Sicpama may use Google Analytics, services provided by PostHog, Inc. (“Posthog Service”) and/or other service providers for statistical analysis and academic research purposes.
The processing of information collected through Google Analytics, Posthog Service and/or other service providers is subject to the respective privacy policy and terms of service of each service provider (as amended from time to time). For your ease of reference only:

Google Analytics Terms of Service: https://www.google.com/analytics/terms/en.html
Google Analytics Privacy Policy: https://policies.google.com/privacy?hl=en
PostHog Service Terms of Service: https://posthog.com/terms
PostHog Service Privacy Policy: https://posthog.com/privacy

IP addresses are anonymized by removing the last two octets and stored without being merged or linked with other Google data.
Customized Advertising: To provide personalized advertisements to customers, Sicpama collects and uses "cookies" in web browsers and advertising identifiers (ADIDs) in mobile apps. Sicpama automatically collects customer service usage history through cookies and advertising identifiers to conduct customized advertising. The cookies and advertising identifiers collected by Sicpama are not linked to other personal information and do not identify individuals. Users can refuse to receive such customized advertisements at any time.
In instances where users seek our assistance for issue resolution, we might utilize recordings of the service usage to identify and rectify problems effectively. It is imperative to emphasize that these recordings are strictly for operational troubleshooting and must not display or compromise any Personal Data of our users, conforming to our stringent privacy standards.

Disclosure of your information

1. Provision of personal information to third parties

1.1 In principle, we do not provide personal information to a third party beyond the scope of the purpose(s) of collection and use or without the user's consent. However, Sicpama may make your personal information available to its affiliates, service providers, partners and restaurants directly involved in the operation, performance, support and/or maintenance of the Services or fulfilling your request. These companies are permitted to use the personal information only to provide Sicpama with specific services, and not for any other purposes, to facilitate our provision of the Services to you. We do not authorize these third parties to use the Personal Data or to disclose it for any purpose other than to perform services on our behalf, in compliance with the terms set out in this Privacy Policy and applicable data privacy laws. Sicpama may also disclose personal information as required by applicable laws, to comply with requests of law enforcement or other government authorities or where Sicpama believes it is necessary or appropriate to protect the safety, rights or property of Sicpama, its employees or others.

As the purposes for which we may/will collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose may not appear in the instances listed in this Privacy Policy. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless we are permitted by the Personal Data Protection Act 2012 of Singapore (“PDPA”) or any other applicable laws to process your Personal Data without your consent.

SicPama Pte. Ltd. may share Personal Data within the Sicpama Group. The “Sicpama Group” includes SicPama Pte. Ltd., SicPama Co., Ltd., and their subsidiaries, affiliates, associated companies and jointly controlled entities. Members of the Sicpama Group that receive this information from SicPama Pte. Ltd. are not authorized to use or disclose the information except as provided in this Privacy Policy.

1.2 Personal information that Sicpama provides to the following third parties:

Recipients:
- Partner vendors (e.g. Vibes Cafe).
- Other users who have placed orders together with the user.
- Other members of the SicPama Group (of which SicPama Pte. Ltd. is a member), including SicPama Co., Ltd, and any its subsidiaries, affiliates, associated companies and jointly controlled entities, located in or outside of Singapore.
- Any agent, contractor or third party service provider, located in or outside of Singapore.
Purpose of provision:
- Order verification and service provision (recipient verification, order management, exchange/return/cancellation processing, inquiries and consultations).
- Issuance of coupons (with user consent).
- Sharing order details with others.
- Provide administrative, data processing, computer and or other services to Sicpama, to enable Sicpama to carry out the purposes permitted under this Privacy Policy.
- Internal analysis purposes (including research on trends or analytics)*.
- Process information, deliver email notices, manage or store user data, and/or provide customer service.

*Any Personal Data transferred to third parties (i.e. parties not within the Sicpama Group, including but not limited to partner companies) for external traffic/sales analytics and data purposes will be anonymized and aggregated before such data is transferred. For the avoidance of doubt, such anonymized and aggregated data does not constitute Personal Data, as such data cannot be used to directly or indirectly identify you and does not comprise data from which you are directly or indirectly identifiable.

Personal information items provided:
- Age group, gender, order history, and payment history.
- Nickname, order history, and statistical information.
- Nickname, profile image, and order history.
Retention and use period of personal information:
- Until the service provision related to the user's order is completed.
- Immediately deleted upon withdrawal of user consent, unless otherwise required to be retained by applicable laws.

We shall take reasonable steps to ensure that the third parties comply with the PDPA and other applicable data protection laws when handling Personal Data, and require such parties to implement appropriate safeguards to protect the confidentiality, integrity, and availability of Personal Data. As part of our agreement with the relevant third parties, they are required to adhere to the PDPA, other applicable data privacy laws, and any policies that we provide, and to take reasonable measures to ensure your Personal Data is secure.

For the avoidance of doubt, you agree to comply with the terms of this Privacy Policy, and applicable data privacy laws, in relation to Personal Data of other users who have placed orders together with you.

We respect the confidentiality of the Personal Data that you provide to us. We do not sell Personal Data to any third party.

International data transfers

SicPama Pte. Ltd. is a subsidiary in the SicPama Group, with its headquarters in the Republic of Korea. As such, we may share information about you within the SicPama Group and transfer it to countries in the world where the SicPama Group carries on business in connection with the uses identified above and in accordance with this Privacy Policy.
If we transfer your Personal Data outside of Singapore, we will take reasonable steps to ensure that the overseas recipient provides a standard of protection to the Personal Data that is comparable to the protection under the PDPA. This includes obtaining your explicit consent (to the extent specific consent has not already been obtained for such transfer by way of consent provided in relation to this Privacy Policy), entering into legally binding agreements with the overseas recipient that require them to provide a standard of protection that is comparable to the protection under the PDPA, or implementing other measures to ensure that your Personal Data remains secure and protected.

User obligations

Users have an obligation to comply with the applicable laws and regulations regarding the protection of personal information in order to securely protect their own personal information.
Users have an obligation to protect their personal information securely, and Sicpama is not responsible for any incidents caused by the user's negligence. Therefore, users are obligated to make their best efforts to protect their personal information, such as carefully managing their ID and password and regularly updating them.
Users have an obligation to provide and maintain their personal information accurately and up to date. Users are solely responsible for any problems that may arise from inaccurate information provided by them.
Users may face penalties under the laws and regulations related to personal information if they use another person's personal information for membership registration or service usage, resulting in loss of membership status.
Users also have an obligation not to infringe upon or disclose others' personal information. If users mention or disclose personal information of other users that they have become aware of during the service usage, they may be subject to penalties under the relevant laws and regulations regarding personal information.

Security and data retention

Security Measures and Disclaimer
1. We will request that our service providers use all reasonable endeavors to maintain the security of your Personal Data and protect it from misuse, interference, loss, unauthorized access, modification, or disclosure. We will destroy any Personal Data we hold about you that is no longer required under the terms of this Privacy Policy, or by applicable laws.
2. Sicpama takes the following measures to ensure the safety of personal information:

Administrative measures: Establishment and implementation of internal management plans, regular employee training, etc.
Technical measures: Management of access rights in the personal information processing system, installation of access control systems, encryption of unique identification information, installation of security programs.
Physical measures: Access control for computer rooms, data storage rooms, etc.

Due to the nature of the internet, we do not (and our service providers do not) provide any guarantee or warranty regarding the security of your Personal Data during transmission to us or storage by us. You acknowledge that you disclose your Personal Data to us at your own risk. Please contact us immediately if you become aware or have reason to believe that there has been any unauthorized use of your Personal Data in connection with the Services.

Destruction of personal information
1. Sicpama destroys personal information without delay when the personal information becomes unnecessary, such as the expiration of the personal information retention period and the achievement of the purpose of processing.
2. If personal information must be kept in accordance with other applicable laws and regulations despite the expiration of the personal information retention period agreed to by the information subject or the achievement of the purpose of processing, the personal information is moved to a separate database or stored in a different storage location.
3. The procedure and method of destroying personal information are as follows:
  1. Destruction procedure: Sicpama selects the personal information for which the reason for destruction occurred and destroys the personal information with the approval of the person in charge of personal information protection of Sicpama.
  2. Destruction method: Sicpama destroys personal information recorded and stored in electronic file form so that the record cannot be reproduced, and personal information recorded and stored in paper documents is destroyed by shredding or incinerating.
Personal Information Retention and Use Period:

Until the service provision related to the user's order is completed.
Immediately deleted upon withdrawal of user consent.
Personal information may be retained for a certain period of time in accordance with relevant laws and regulations.
To prevent fraudulent use, related personal information can be kept for six (6) months after membership withdrawal.
If there is no record of service use by a member for one (1) year, the member is notified in advance and stored separately for three (3) years.
Members who engage in expedient or illegal acts by repeatedly re-registering or voluntarily canceling membership after withdrawing from membership to obtain economic benefits with discount coupons and event benefits provided by Sicpama, or using their names without permission in the process, their information is stored for 90 days after membership withdrawal in order to block it.
Personal information may be retained for a certain period of time in accordance with the provisions of related laws.

Personal Information Processing:

To ensure smooth and improved services, Sicpama may entrust the processing of personal information to external professional companies.
The personal information is retained until member withdrawal, termination of outsourcing contract, or service termination.

Rights, Obligations, and Exercise Methods of Data Subjects and Legal Representatives:

Data subjects have the right to access, correct, delete, and request the suspension of processing of their personal information from Sicpama at any time.
Requests regarding the mentioned rights can be made to Sicpama in writing, by email, fax, or other means.
Requests can also be made through a legal representative or an authorized delegate.
The right to access, correction, deletion, and suspension of processing of personal information may be limited under certain circumstances.
Requests for correction and deletion of personal information cannot be made for personal information that is expressly specified as a collection target under other laws.
Sicpama verifies the requestor's identity before processing requests related to personal information.

Security Measures for Personal Information:

Sicpama implements administrative, technical, and physical measures to ensure the security of personal information.
Administrative measures include the establishment and implementation of internal management plans and regular employee training.
Technical measures include access control management, installation of access control systems, encryption, and security programs.

Accessing and updating

Please contact us if you would like to access your Personal Data held by us or our service providers. We will use reasonable endeavours to provide a complete list of your personal information within a reasonable period of receipt of your request. Please email us if you would like to receive a copy of this information – support@sicpama.com. We, and our service providers (as applicable) reserve the right to charge reasonable fees for the processing of such request in accordance with local legislation – we will provide you with a written estimate of the fee beforehand. The purpose of the fee is to allow us to recover the incremental costs of responding to the access request (e.g. the time and costs incurred to search for the Personal Data requested, and/or the cost of producing a physical copy of the Personal Data for the individual requesting it). If our fees are higher than the original written estimate, we will inform you of the increased fee, in writing. We retain the discretion to refuse to process or provide access to your Personal Data until you agree to pay the relevant fee. If the requested personal data resides in a form that cannot practicably be provided to the individual in documentary form, whether as physical or electronic copies (e.g. the data cannot be extracted from a special machine owned by the organisation), then the organisation may provide the individual a reasonable opportunity to examine the requested data in person.
You may contact us at any time at support@sicpama.com to correct any of your Personal Data that is inaccurate, incomplete or out-of-date, or to request that all or any part of your Personal Data be deleted. We will use reasonable endeavours to correct or delete your Personal Data as requested within a reasonable period of receipt of your request.
However please note that requests for correction and deletion of personal information are subject always the applicable laws, and may be required to be retained to comply with directions from relevant governmental authorities.
Deletion of your account, whether with us or with our service providers will not automatically delete your Personal Data. If you would like our service providers to delete all Personal Data together with the deletion of your account, please email us at support@sicpama.com.
Please note that the deletion of your Personal Data from our database will result in us not being able to provide you with any services that require such Personal Data. If applicable, any legal requirement on us to maintain certain records of your Personal Data shall prevail over any of your requests. We may require you to prove your identity before providing you with copies of your Personal Data, including the provision of relevant supporting documents as reasonably required by us, at our sole discretion.
Sicpama checks whether the person who made the request, such as a request for viewing, a request for correction or deletion, or a request for suspension of processing according to the rights of the information subject, is the person or a legitimate agent.

Changes to our privacy policy

We may revise this Privacy Policy periodically. Any modifications to this Privacy Policy will be published via the Services to ensure that you stay informed about how we collect and use your Personal Data. We encourage you to review this Privacy Policy whenever you access the Services or engage with us to stay updated on our information practices and ways to protect your privacy. The updated versions of this Privacy Policy will indicate the date of the revision at the end, allowing you to verify the most recent amendment date. Any changes to this Privacy Policy will become effective upon posting the revised version on the Website or via our Services. We will notify you of the reasons for the change and the content of the change on the service screen at least seven (7) days prior to implementation. However, if there are significant changes regarding members' rights in the collection and use of personal information, etc., we will notify you at least 30 days in advance. By continuing to use the Services after such changes, you acknowledge and accept the revised Privacy Policy. However, if the changes have a substantial impact on your rights or obligations regarding the handling of your Personal Data, they will only apply to Personal Data collected after the changes are implemented.

Other websites

Our Services may include links to external websites, apps, content, services, or resources that are operated by third parties. It's important to note that these third-party entities have their own privacy policies. Therefore, when you access these external links and utilize their services, please be aware that we do not assume any responsibility or liability for their privacy practices or the collection of Personal Data through these platforms. We strongly recommend reviewing the privacy policies of these websites or apps before providing any personal information to them.

Contact

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to our data protection officer at support@sicpama.com.