PI-XCELS PRIVACY POLICY
Effective Date: 20 May 2025
1. ABOUT THIS PRIVACY POLICY
1.1. This is the Privacy Policy for Pi-xcels Pte. Ltd. and its affiliates and related companies (collectively referred to herein as “Pi-xcels”, “us”, “we” or “our”). In this Privacy Policy, “you” and “your” refers to any person and/or entity using and/or accessing our Services and/or Websites.
1.2. This Privacy Policy describes how we may collect, use, disclose and process your personal data when you:
1.2.1. access or use our websites and applications (collectively, “Websites”);
1.2.2. access or use our electronic receipt issuance and storage services, and/or any other services or supplementary services which we provide from time to time (collectively, “Services”); and/or
1.2.3. provide us with your personal data.
1.3. You may find out more about our Services in our Terms of Service.
1.4. By providing us with personal data, you acknowledge that our collection, use, disclosure and processing of personal data will be in accordance with this Privacy Policy, including the cross-jurisdictional transfer of your personal data.
1.5. This Privacy Policy supplements but does not supersede or replace any consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.
1.6. If you have any feedback, issues, requests, inquiries, or complaints in relation to your personal data, or about this Privacy Policy, you may contact our Data Protection Officer at:
Email : dataprotection@pi-xcels.com
When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.
2. AMENDMENTS TO THIS PRIVACY POLICY
2.1. We may amend this Privacy Policy from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. The updated policy will supersede earlier versions and will apply to personal data provided to us previously. The updated Privacy Policy will take effect when made available (i) on our website or; (ii) through any other appropriate means designated by us from time to time.
2.2. If we amend the purposes of collection, use, disclosure and processing of your personal data, such amendment shall be effective in relation to you from the time when we obtain your consent for such amended purpose.
3. PERSONAL DATA WE COLLECT
3.1. The personal data we may collect from you include contact information, payment information, account information, usage data, marketing data, and device & technical data. Examples include your name, profile picture, date of birth, gender, telephone number, email address, username, masked credit card number and related financial information (e.g. expiration data and billing address), purchase history, historical information on loyalty and points programs, marketing preferences, location, Internet Protocol (IP) address, and any other information which we collect and you consent to provide from time to time.
3.2. We do not collect information such as racial or ethnic background, political opinion, trade or labour union membership, medical and health data, sexual preference and orientation, biometric data, and religious or philosophical beliefs.
3.3. We will only collect sensitive personal data where we have obtained explicit consent from you, or if it is otherwise permitted under applicable laws.
3.4. In certain circumstances, you may also provide us with personal data of persons other than yourself (such as your family members and next-of-kin). If you do so, you represent and warrant that you have brought this Privacy Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.
3.5. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data.
4. HOW WE COLLECT PERSONAL DATA
4.1. We collect, use, disclose and process your personal data where:
4.1.1. you have given us consent;
4.1.2. it is necessary to comply with legal or regulatory obligations (e.g. responding to valid requests from public authorities);
4.1.3. it is necessary to support our legitimate business interests, provided that this does not override your interests or rights;
4.1.4. it is necessary to perform a transaction you have entered into with us; and/or
4.1.5. it is necessary to provide a service that you have requested or require from us.
4.2. We may collect your personal data directly from you or through various channels, such as when:
4.2.1. you access or use any of our Websites and/or Services;
4.2.2. you register an account with us;
4.2.3. you use our single sign on (SSO) services;
4.2.4. you use and/or subscribe to the loyalty and points program operated by us or by a retailer that is on our platform;
4.2.5. we seek information about you and receive your personal data in connection with your relationship with us; and/or
4.2.6. when you submit your personal data to us for any other reason.
4.3. We may also collect your personal data from third party sources, for example, from:
4.3.1. any third parties whom you have authorised us to obtain your personal data from, including Google, Meta, or any other identify providers; and/or
4.3.2. our business partners, such as third parties providing services to us.
5. HOW WE USE PERSONAL DATA
5.1. We collect, use, disclose and process your personal data for the following purposes:
5.1.1. providing our Services to you;
5.1.2. identification, verification, and authentication of your account or facility with us;
5.1.3. maintenance and management of your account or facility with us;
5.1.4. operating and providing you access to our Websites;
5.1.5. communicating with you, including responding to any feedback, issues, requests, inquiries, or complaints you may have related to our Services or Websites;
5.1.6. fulfil retailer services, including the administration of rewards and subscribing to loyalty and points programs operated by each retailer, which you have consented to;
5.1.7. administrative purposes, quality assurance and staff training, and compliance with internal policies and procedures, including audit, accounting, risk management and record keeping;
5.1.8. administer rewards and provide you access to our loyalty and points program operated by us;
5.1.9. such purposes that may be informed to you when your personal data is collected; and/or
5.1.10. any other reasonable purposes related to the aforesaid.
5.2. In addition, we may collect, use, disclose and process your personal data for the following purposes to support our legitimate business interests, provided that this does not override your interests or rights, which include:
5.2.1. carrying out research and statistical analysis, including evaluation, improvement, and development of our Services and Websites;
5.2.2. conducting system maintenance and recovery of our Websites;
5.2.3. administering and protecting our business, Services and Websites, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data; and/or
5.2.4. investigation and prevention of unauthorized access to, or other unauthorized use of, the Services and Websites.
5.3. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law. Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
5.4. With your express consent (where required by applicable law), we may collect, use, disclose and process your personal data for the following purposes:
5.4.1. to send you information about our Services, offers, promotions or special rewards or programs that we believe may interest you;
5.4.2. to send you information about the products and services of our business partners and retailers; and
5.4.3. to provide your personal data to third parties for marketing and advertisement purposes, including to provide cross-contextual behavioural advertising on our Websites.
5.5. No marketing, using your personal data in non-aggregated and/or identifiable form, would be carried out unless you have provided us with your consent to use your personal data for such marketing purposes. If you no longer want to receive any marketing communication or information from us, or otherwise no longer want us to use your personal data for the purposes of marketing, you can withdraw your consent at any time by contacting us in accordance with paragraph 1.6 above.
6. DISCLOSURE OF PERSONAL DATA
6.1. We may disclose or share your personal data with our affiliates and related companies in order to provide our Services to you and to utilise shared group IT functions.
6.2. We may also disclose or share your personal data to third parties in connection with purposes described in paragraph 5, including without limitation the following circumstances:
6.2.1. disclosing your personal data to third parties who provide services to us, such as those that provide business, professional or technical support functions. These may include, but are not limited to, service providers that host our Services, data processing or other information technology service providers, and research and analytics vendors;
6.2.2. disclosing your personal data to retailers in order to fulfil retailer services, including administration of rewards and subscribing to the loyalty and points program operated by each retailer;
6.2.3. disclosing your personal data to third parties that we conduct marketing and cross promotions with; and/or
6.2.4. disclosing your personal data to authorities, governments, law enforcement agencies, public agencies, or any other third party as required under law.
6.3. We may jointly use and process your personal data together with the third parties identified in paragraphs 6.1 and 6.2.
6.4. When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.
6.5. Where your personal data has been disclosed to third parties in accordance with paragraph 6.2, the processing of your personal data by such third parties will also be subject to their respective privacy policies.
7. TRANSFER OF PERSONAL DATA
7.1. We may disclose and transfer your personal data to our affiliates, related entities and/or service providers that may be located outside of your jurisdiction, for the purposes described in paragraph 5. Where we transfer your personal data across jurisdictions, we will ensure that your personal data is protected in accordance with this Privacy Policy and applicable laws regardless of the jurisdiction that they are transferred to, but in any event to a level that is no less stringent than the applicable data protection laws in the jurisdiction from which the personal data is transferred.
7.2. To the extent that your personal data is transferred outside of your jurisdiction, we implement appropriate safeguards in accordance with applicable laws to ensure that your personal data is afforded the requisite level of protection. Specifically, where we transfer your personal data out of the European Union/United Kingdom, we will ensure that a similar degree of protection is afforded to the personal data by ensuring at least one of the following safeguards is implemented:
7.2.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
7.2.2. We will take measures to comply with applicable data protection laws related to such transfers and use appropriate transfer solutions for any transfers of personal data outside the European Union, such as the adoption of EU Standard Contractual Clauses, binding corporate rules or other applicable instruments (if any) to comply with the legal requirements. You may obtain details of these safeguards by contacting us in accordance with paragraph 1.6 above.
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8. SECURITY AND RETENTION OF PERSONAL DATA
8.1. The Company has taken the following measures and precautions to safeguard your personal data in our possession or under our control:
8.1.1. Organizational and management measures: development and enforcement of personal data handling regulations and internal privacy policies, commissioning of personnel to oversee personal data processing activities, regular employee education & training, and internal periodic audits.
8.1.2. Technical Measures: instalment of security programs, control of access authority to personal data processing systems, instalment of an access control system, cybersecurity assessments of service providers who may handle your personal data, and encryption of identifiable personal data (where applicable).
8.1.3. Physical Measures: restriction of personnel access to data processing room & data storage rooms.
8.2. While we take reasonable precautions to safeguard your personal data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes. We do not make any warranty, guarantee, or representation that your use of our Services or Websites is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such personal data is entirely at your own risk.
8.3. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for as stated in this Privacy Policy, to satisfy our business and/or legal purposes, including data analytics, audit, accounting or reporting purposes, and to comply with legal requirements. We will destroy your personal data when we no longer require your personal data to fulfil any of the aforementioned purposes. How long we keep your personal data may depend on the nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we use the personal data, and the applicable legal requirements.
8.4. Where it is necessary to destroy your personal data, and where required by applicable regulations, we will do so only after obtaining the approval from our Data Protection Officer. Personal data recorded and stored as physical documents will be destroyed using appropriate means.
8.5. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such anonymised personal data without restriction.
9. USE OF AUTOMATED DATA COLLECTION TECHNOLOGIES
9.1. In order to improve our products or services, we may collect data by way of “cookies”. Cookies are small data files that are placed on your computer or mobile device when you visit a website or access an application. For more information on the cookies we use, please visit https://www.pi-xcels.com/cookie-policy. There are two different types of cookies:
9.1.1. Session cookies: Session cookies contain information that is used within your current browser session. These cookies are automatically deleted when you close your browser. Nothing is stored on your device after you leave the website.
9.1.2. Persistent cookies: Persistent cookies are used to retain information between visits. When you return to a website, this data allows it to recognize you and act accordingly. Persistent cookies have a lifespan defined by the website and can vary from a few minutes to several months.
9.2. In addition, cookies can be first party or third party cookies. First party cookies are those that are generated by the website or application that you are visiting. Third party cookies are those that are generated by a domain, a website or an application other than the one you are visiting.
9.3. We use cookies for the following purposes:
9.3.1. Strictly necessary: these cookies are essential for you to browse our Websites and use its features. The information collected relates to the operation of the Websites.
9.3.2. Analytics: these cookies are used to determine how you use and interact with our Websites. We collect this information for analytical purposes, to better understand how you use our Websites, and to allows us to improve our Websites as well as our Services. These cookies are sometimes placed by third party providers of web traffic and analysis services. We use Google Analytics, Microsoft Clarity, Sentry, and Facebook. For more information on these third parties, please visit our Cookie Policy.
9.3.3. Preference: these cookies are designed to improve and personalize the non-essential functionalities of our Websites, give you access to specific but non-essential features depending on your browsing on our Websites, and improve your browsing experience.
9.4. We may also automatically collect and store certain information about your interaction with our Websites including IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps and related data.
9.5. To manage your cookie preferences, please visit our Cookie Policy. Your browser may also give you the ability to control cookies. You may refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox and Safari). Please note you may not be able to take advantage of all the features of our Websites and Services, including certain personalised features, if you delete or refuse cookies.
10. YOUR RIGHTS
10.1. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain rights under applicable law in relation to our collection, use, disclosure and processing of your personal data. Such rights may include:
10.1.1. Access: you have the right to obtain information about the processing of your personal data, as well as copies of such personal data.
10.1.2. Correction: you have the right to correct your personal data or supplement incomplete data, if your personal data is inaccurate.
10.1.3. Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.
10.1.4. Right to withdraw consent: where we collect, use, disclose or process your personal data based on consent, you have the right to withdraw such consent at any time. If you do so, you may not be able to access or use our Website and Services, and it may not be possible for us to fulfil the purposes for which we require your personal data.
10.1.5. Restriction: under certain conditions, you may request for the restriction of processing of your personal data (for example, where the personal data has been unlawfully processed), or ask us to suspend the processing of certain personal data about you (for example, if you want us to establish its accuracy).
10.1.6. Objection: you have the right to object to our processing of your personal data, under certain conditions.
10.1.7. Portability: you have the right to request for a copy of your personal data that you have provided to us, and to request the transmission of such data to another organisation.
10.1.8. Right to make a complaint: where you are located within the European Union or the United Kingdom, you have the right to make a complaint at any time to the data protection supervisory authority in the Member State of the European Union or the United Kingdom in which you are resident.
10.2. If you wish to exercise any of your rights, you may contact us in accordance with paragraph 1.6.
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