Customer Privacy Notice

This privacy notice describes how Kobayashi Pharmaceutical (Singapore) Pte. Ltd. (“we”, “our” or “us”) collects, uses, discloses, or otherwise processes personal information about you in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”), how we protect this information, and your rights under the PDPA in relation to this information.

This privacy notice applies to all personal information we collect, use, disclose, and/or process about you. For the purposes of this privacy notice, “personal information” is defined as data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.

1. Personal information we collect

   We collect personal information from you directly (e.g. when you contact us about a product), and may generate information about you in the course of our relationship with you.

   The categories of information that we collect directly from you will include any personal information you include in correspondence to us. This may include personal details (e.g. name, date of birth); contact details (e.g. phone number, email address or postal address); details about purchases you have made (e.g. when you make purchases or respond to offers); and any other information you provide to us.

   If you are an employee of a seller of our products, we may also collect other information about your employment from you including your job title, place of work and delivery addresses.

   We will seek your consent before collecting any additional personal information that is not described above.

2. How we use your personal information and the basis on which we use it

   We may use your personal information for the following purposes:

   • Responding to communications: if you contact us, we will use your personal information to respond to any communications and resolve any complaints you have. This is to meet our legitimate interests in providing the best service we can to the users of our products.
   • Managing orders: if you order our products as a seller, we will use your personal information to process your order and to invoice. This is to meet our legitimate interests in fulfilling our orders, and to meet our customers' expectations of our service.
   • Improving our products and services: if you contact us about our products or our service, we may use your personal information to make suggestions about improvements to our products. It is in our legitimate interests to provide the best products possible to all our customers.
   • Managing our business: we may use your personal information to keep our records of our customers and our sales accurate and up to date, and to ensure that we meet any legal obligations to which we are subject. Where not necessary to comply with any such legal obligations, we do this to meet our legitimate interests in running our business most effectively.
   • Exercising our rights: we may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect breaches of the law or of our policies.
   • Complying with our obligations: we may process your personal information to comply with other legal or regulatory requirements, where this is explicitly required by law.

   We will seek your consent before using your information for purposes other than the ones set out above.

3. How and when we Share Your Personal Information

   We may share your personal information with third parties under the circumstances including but not limited to the following circumstances:

   • Service providers and business partners: We may share your personal information with our service providers and business partners that perform business operations for us for the purposes set forth above. For example, we may partner with companies to process payments, fulfil orders, and manage deliveries.
   • Group companies: Kobayashi Pharmaceutical (Singapore) Pte. Ltd. is owned by Kobayashi Pharmaceutical Co., Ltd. in Japan, and we work closely with our parent company and other companies in the Kobayashi Group. We may share your personal information with members of the Kobayashi Group (a full list is available here), including but not limited to, Corporate Headquarters International Business Division of Kobayashi Pharmaceutical Co., Ltd. in Japan which may process that personal information for the purposes set out above.
   • Where required by law: We may share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
   • In the context of a transaction: We may, in accordance with the PDPA, share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, your personal information will only be collected, used, or disclosed in a manner that is consistent with the PDPA, and subject always to the conditions set out therein.

4. Your rights over your personal information

   You have certain rights regarding the personal information we hold about you, subject to Singapore law. These may include the rights to access, correct, restrict or object to our use of your personal information.

   If you wish to make an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, you may submit your request in writing or via email to us at the contact information set forth below. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

   We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

   We also encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

   Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

   Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

   Please note that we may require additional information from you in order to honour your requests.

   If you would like to discuss or exercise any rights you may have under law, please contact us at the contact information set forth below.

5. Information Storage

   We retain your personal information for as long as is necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by applicable laws. When we determine how long to keep your personal information after our relationship with you has ended, we take into account our legal rights and obligations. In particular we may retain records to investigate, commence or defend potential legal claims. We will cease to retain your personal information or remove the means by which the data 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 data was collected, and is no longer necessary for legal or business reasons.

6. International Data Transfer

   Your personal information may be disclosed and transferred to, and collected, used, stored, and processed by members of the Kobayashi Group in other countries (a full list of the relevant countries is available here) in compliance with the PDPA. In this regard, we have put in place appropriate safeguards, including contractual commitments, with effective legal remedies to ensure your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. This includes, but is not limited to:

   • encrypting your personal information using ZIPcrypto when it is sent via email to members of the Kobayashi Group overseas;
   • ensuring that your personal information and the folder in which it is stored can only be accessed via certain specific devices and employees of the Kobayashi Group who have a need to know such information and only for the purposes which such information has been provided by you;
   • protecting your personal information in compliance with local data protection laws at the recipient country;
   • (in relation to Japan) protecting your personal information in compliance with the JIS Q 15001:2017 data protection standard;
   • appointing a personal information management representative(General Management Supervisor) at Kobayashi Pharmaceutical Co., Ltd. to manage all personal information (including yours) that is collected, used, disclosed and/or transferred amongst the Kobayashi Group and to ensure compliance with applicable data protection laws (including the PDPA); and
   • conducting annual internal audits of the Kobayashi Group’s compliance with applicable data protection laws, such audits carried out by the Internal Audit Department of Kobayashi Pharmaceutical Co., Ltd. and its findings reported to the Information Security Committee organized by the (General Management Supervisor) of Kobayashi Pharmaceutical Co., Ltd.

7. Contact Us

   If you have questions or concerns regarding the way in which your personal information has been or will be used, or if you would like to make any request in relation to your personal information, please contact us at:

   Contact Address: 2, Alexandra Road #04-01D Delta House, Singapore 159919

   Telephone No.: (65) 6270 8239

   E-mail Address: t.funaki@kobayashi.co.jp

   Responsible Person: FUNAKI TAKEO, Director

   We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy, and to fulfil any of your requests under the PDPA relating to your personal information.

8. Changes to the Policy

   We may modify or update this privacy notice from time to time without any prior notice to you. You may determine if any changes to this privacy notice have been made by referring to the date on which this privacy notice was last updated. Your continued use of our products and services constitutes your acknowledgement and acceptance of such changes.

   Effective Date: 1st June, 2023