Privacy Notice

Last updated on 25 July 2022

The protection of your personal data is of utmost importance to us. We are committed to protecting your personal data in compliance with the data protection laws applicable to you.

This privacy notice (the “Privacy Notice”) sets out the manner in which Flash Coffee collects, uses, processes and discloses your personal data. It may be supplemented by additional privacy statements, terms or notices provided to you from time to time. The Flash Coffee company that operates the relevant Service, as defined below, is the primary controller of the personal data that is provided to or collected by or for, the said Service.

This Privacy Notice applies to all the mobile applications, websites, products, features and other services globally (including our physical stores), owned or operated by Flash Coffee (each, a “Service” and collectively, the “Services”). By submitting any personal data to us and by using our Services, you consent to us collecting, using, processing and disclosing your personal data in accordance with the terms of this Privacy Notice.

1. What is “Personal Data”?
   “Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes your name, your mobile number, email address, location, delivery address, your Flash account profile photo, payment information and Service usage information insofar as you may be identified from such information.
2. When do we collect your Personal Data?
   We collect Personal Data about you in the manner set out below:
   1. When you provide your Personal Data to us, including:
      • when you create an account with us – your name, mobile number, location, account profile photo, email address, payment method, saved delivery addresses; and
      • when you take a survey or interact with us in various ways including our social media pages, contests and events organised by us – demographic information such as your age, gender, interests, your social media account handle or ID, profile photo or any other publicly accessible data, images, audio or videos that you may submit, which may include images of yourself and/or others.
   2. When you use Flash Coffee’s Services, Personal Data may be collected in the ordinary course of such use or operation, including:
      • when you buy goods or services via our mobile app, physical stores, web orders, through our programs or otherwise – your order information including what you purchased, the store that you purchased from, your purchase frequency, preferences, loyalty rewards earned or redeemed and other transaction information (such as payment method);
      • your location information (depending on your permissions);
      • device information – hardware model, IP addresses, app names and versions, IMEI number, device-specific settings and characteristics;
      • information about how you interacted with our Services including features used and content viewed;
      • when you interact with our customer support team – the personal data that you enter in such messages, your voice or image or both, and its related metadata; and
      • where our physical stores are equipped and monitored by closed circuit television cameras – images and videos of persons in and around our physical stores
   3. From other sources, including
      • the organization you are employed or affiliated with – we may obtain information such as your name, job title and organizational email address in order to activate and manage your corporate discounts or benefits package with us;
      • our business partners and service providers;
      • your authorised representatives; and
      • publicly available sources and data suppliers.
3. Accuracy of Information
4. By submitting your Personal Data to us, you warrant that all Personal Data submitted to us is complete, accurate, true and correct. Failure to ensure that such data provided to us is complete, accurate, true and correct may result in inability on our part to provide you with the requested products or services.
5. Personal Data of Other Individuals
6. If you provide the Personal Data of other individuals to us, you represent and warrant that you have the requisite rights, permissions or consent from the other individual(s) for their Personal Data to be collected, used, processed and disclosed as described in this Privacy Notice.
7. How do we use your Personal Data?
   We may use your Personal Data for the purposes described in this Privacy Notice or as disclosed to you with or as part of our Services. These include (but are not limited to the following):
   1. to provide you with the Services including to conduct and complete transactions, process and manage purchases, payments, delivery and use of Flash Coffee products and services;
   2. to create, administer and update your account;
   3. to process, manage or verify your eligibility for or application of Services, promotions, rewards and subscriptions with us;
   4. for the administration, billing, audit and management of programs and partnerships;
   5. to monitor our service levels and address any abnormalities or service issues;
   6. to tailor and personalise your experience across our Services including through product and service recommendations and recognising your preferences;
   7. to investigate and address service inquiries, feedback, comments or statements, or take other actions in response your inquiries or other website or app activities;
   8. to conduct marketing and promotional activities, and to create personalised promotions by combining personal information with non-personal information, such as the amounts and types of purchases or any benefits you receive through Flash Coffee’s programs;
   9. to communicate with you by post, telephone, email, SMS, instant messaging, web messaging, social media and other engagement platforms, and/or Flash Coffee’s mobile app (including but not limited to any in-app messaging services) about Flash Coffee brands, products, events or other promotional purposes, including co-branded offers and affiliate and partner offers;
   10. for internal operations, including troubleshooting, data analysis, testing, research, service improvement and product development;
   11. to maintain or defend the security of your account and the Services;
   12. exercising a right or obligation conferred or imposed by law, including responding to requests and legal demands; and/or
   13. purposes relating thereto.
8. Who do we share your Personal Data with?
   In the course of providing you with our products and services and depending on the circumstances of our interaction, your Personal Data may be disclosed to the following third parties for the purposes listed above:
   1. agents, contractors or third party service providers who have been engaged by us to provide services such as data processing, customer support, analytics, customer engagement, customer segmentation, performance marketing or market research, in accordance with our instructions;
   2. our parent company, affiliates and/or subsidiaries within and/or outside Singapore;
   3. business partners;
   4. delivery partners;
   5. the organization you are employed or affiliated with, as part of our corporate program;
   6. cloud hosting and IT service providers;
   7. payment service providers, banks, credit card companies and their respective service providers;
   8. professional advisors such as lawyers and auditors;
   9. relevant government authorities or law enforcement agencies;
   10. in the event of a merger, acquisition, financing or sale of assets or any other situation involving the transfer of some or all of our business assets, we may disclose Personal Data to those involved in the negotiation or transfer (subject to your consent, where required under applicable law); and
   11. any party to whom you authorise us to disclose your Personal Data.
   We require all third parties to respect the confidentiality and security of your personal data and to treat it in accordance with the law.
   Your Personal Data may be transferred, stored and/or processed in a country or territory outside the country in which you gave the Personal Data to us. When we transfer your Personal Data as such, we will comply with our legal and regulatory obligations in relation to your Personal Data including putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient is obligated to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.
9. Use of Cookies and Web Services
   Flash Coffee and third parties with whom we partner, may use cookies, web beacons, scripts, tags, local shared objects, advertising identifiers and similar technologies (collectively, “Cookies”) in connection with your use of our websites and apps. Among other things, Cookies allow Flash Coffee to provide the essential basic functions of our websites and apps and also help to improve services and user experience. Flash Coffee uses Cookies to see which areas and features are popular, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon. These Cookies may be persistent or stored only during an individual session on your browsers or devices.
   You have the right to choose to disable, block or deactivate Cookies. You may adjust your internet browser or mobile phone settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. Please note however, that refusal or removal of some Cookies could affect the availability, functionality or use of our websites or apps.
10. How do we manage, protect and store your Personal Data?
    1. Protection
       We take privacy very seriously and will take all reasonable legal, organisational and technical measures including the deployment of appropriate security measures to ensure that your Personal Data is securely stored and protected against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. We limit access to your Personal Data to our employees, partners and service providers on a strict need-to-know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.
       You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. In the event of a data breach affecting your Personal Data, we shall notify you as required by and in accordance with the data protection laws applicable to you.
    2. Retention
       We will only retain Personal Data for as long as the retention is required for (i) the purposes for which such Personal Data was collected, or (ii) as required for legal and business purposes.
       We will cease to retain your Personal Data, 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, you have requested to do so or withdrawn your consent, or the Personal Data is no longer necessary for legal or business purposes.
    3. Links to Other Sites
       Our Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Notice of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
11. What are your rights?
    You may have the right under applicable privacy and data protection laws to request:
    1. access to your Personal Data;
    2. correction or erasure of your Personal Data;
    3. withdraw your consent to the processing of your Personal Data;
    4. restriction of our processing of your Personal Data, or to object to our processing; and
    5. portability of your Personal Data.
    If you wish to exercise these rights, please submit your request in writing via email to our Data Protection Officer at the contact details provided below or in the case of account deletion requests, you can make use of the self-help feature found within the “Profile” feature in the Flash Coffee app.
    We will respond to your request in accordance with the requirements of applicable laws. Depending on the nature of your request, we may reach out to you to verify your identity and/or obtain further information as needed to allow us to act upon or respond to, your request.
    Where you are given the option to share your Personal Data to with us, you are free to choose not to do so.
    The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing.
    Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
    Please note that withdrawing consent does not affect our right to continue to collect, use. process and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
    In certain instances, please note that a reasonable fee may be charged for processing your privacy request. If so, we will inform you of the fee before processing your request.
12. Privacy Notice Updates
    We may update, amend or modify this Privacy Notice from time to time. If we make revisions that change the way we collect, use or disclose your Personal Data, these changes will be posted in this Privacy Notice and the effective date will be noted at the beginning of this Privacy Notice. Therefore, you should review this Privacy Notice periodically so that you are up to date on our most current policies and practices. We will also prominently post such material changes prior to implementing the change, and seek your consent if required by applicable law.
13. Who should you approach?
    If you have any feedback or enquiries relating to this privacy notice, please contact our Data Protection Officer via email at [email protected].
    For your convenience, this Privacy Notice exists in a number of language versions, but is originally drawn up in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.