Last Updated: August 13, 2025
This Privacy Policy describes how Tobewarmglobal.com (“we,” “us,” or “our”) collects, uses, and discloses your Personal Data when you visit or make a purchase from the Site. We are committed to protecting your privacy and handling your data in an open and transparent manner, in compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore.
1. Introduction and Your Consent
By accessing or using our Site, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with this policy, please do not use our Site. This policy may be updated from time to time, and your continued use of the Site after any changes signifies your acceptance of the revised policy.
2. Personal Data We Collect
We collect various types of personal data to provide and improve our services to you. The types of personal data we collect depend on the nature of your interaction with us. This may include:
- Identity and Contact Data: Name, billing address, shipping address, email address, phone number, and other similar contact data.
- Transaction Data: Details about products and services you have purchased from us, payment information (though sensitive payment details are handled by our payment gateway, as detailed below), and order history.
- Technical Data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data: Information about how you use our website, products, and services, including browsing patterns, pages viewed, products searched for, and time spent on certain pages.
- Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
3. How We Collect Your Personal Data
We use different methods to collect data from and about you, including through:
- Direct Interactions: You may give us your Identity, Contact, and Transaction Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
– Apply for our products or services;
– Create an account on our website;
– Subscribe to our service or publications;
– Request marketing to be sent to you;
– Enter a competition, promotion, or survey; or
– Give us feedback or contact us.
- Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources, such as:
– Technical Data from analytics providers (e.g., Google Analytics);
– Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services (e.g., HitPay).
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To process and fulfill your orders, including managing payments, fees, and charges.
- To manage our relationship with you, which will include:
– Notifying you about changes to our terms or privacy policy;
– Asking you to leave a review or take a survey.
- To enable you to participate in a prize draw, competition, or complete a survey.
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.
- To make suggestions and recommendations to you about goods or services that may be of interest to you.
- To comply with legal and regulatory obligations.
5. Disclosure of Your Personal Data
We may share your personal data with the following parties for the purposes set out in Section 4:
- Internal Third Parties: Other companies within our group acting as joint controllers or processors and who are based in Singapore and provide IT and system administration services and undertake leadership reporting.
- External Third Parties:
– Service providers acting as processors who provide IT and system administration services.
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in Singapore who provide consultancy, banking, legal, insurance, and accounting services.
– Regulators and other authorities acting as processors or joint controllers based in Singapore who require reporting of processing activities in certain circumstances.
– Payment Gateway Providers (e.g., HitPay): For processing secure payments. Please refer to Section 6 for more details.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Payment Processing with HitPay
We use HitPay Payment Gateway to process payments for purchases made on our Site. When you make a purchase, your payment information (such as credit card details) is securely collected and processed directly by HitPay. We do not store your sensitive payment information on our servers. HitPay is responsible for the security and integrity of your payment data during the transaction process. For more information on how HitPay handles your personal data, please refer to their Privacy Policy at https://hitpayapp.com/privacy-policy.
7. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. Your Rights
Under the PDPA, you have rights in relation to your personal data. These include the right to:
- Access your Personal Data: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request Correction: Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Withdraw Consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the details in Section 10.
10. Contact Information
If you have any questions about this Privacy Policy or our data practices, please contact us at:
Email: care.tobewarmglobal@gmail.com
WhatsApp: +65 8436 2649
