PRIVACY POLICY

Last updated: November 2024

This Privacy Policy applies specifically to LOTTE Travel Retail Singapore Pte Ltd, operating under the brand name LOTTE Duty Free (“LDF”) in Singapore.

At LOTTE Duty Free (“LDF”), we take your privacy seriously and understand your concerns. This Privacy Policy outlines how we handle personal data at LDF, including information about our customers who interact with us through various channels: visiting our retail stores, websites, social media sites, mobile applications, as well as corresponding with us via physical letters, email, phone calls, and chat communications. Our policy covers the types of personal data we collect, how we use this information, and with whom we may share it. We strive to be transparent and responsible in our handling of personal data and are committed to protecting your privacy.

By using the abovementioned services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not further access or use the services.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your personal data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to collect, use or disclose your personal Data.

We will typically seek or have sought your consent to collect personal information about you when you visit any of our LDF stores. For all intents and purposes, subject to applicable law, you hereby agree, and acknowledge and consent that your personal data may be collected, used, and disclosed for any purpose contemplated in this Privacy Policy.

1. General Description of Ways in which We Collect Personal Data

We collect personal data in various ways through our online services, which include websites ("Sites"), social media platforms ("Social Media"), and web or mobile applications ("Mobile Apps"), subject to applicable laws and regulations. We also collect personal information at our retail stores to facilitate sales transactions. Unless such laws and regulations do not permit us, we may collect personal data when users create, share, and interact with other users on our Social Media or use our Sites or Mobile Apps.

We have security measures in place at our stores, including CCTV surveillance. Clear signage indicates when CCTV is in operation. The recorded footage is securely stored and accessed only on a need-to-know basis (e.g., for incident review). CCTV recordings are typically overwritten automatically after a short period unless retained for investigation due to an identified issue (e.g., theft).

Information Collected Through Automated Means

We may collect information from your computer system or mobile device through automated technologies when you visit our stores or use our Online Services or in-store technologies. These automated technologies may include cookies, local shared objects, and web beacons. The information we collect may include your Internet Protocol (IP) address; computer/mobile device operating system and browser type; type of mobile device; mobile device settings; the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device; device and component serial numbers; advertising identifier (e.g. Identifier for Advertisers (IDFAs or IFAs) or similar identifier; the referring website or application; the linked sites, third-party websites, applications or social media where you share Online Services content; and/or activity related to your use of our Online Services such as the pages you visit on our Sites or in our Mobile Apps.

At our retail stores, as part of our sales transaction process, we collect personal information from customers' passports and boarding passes. This data collection is seamlessly conducted through the use of specialized scanners that are integrated into our Point-of-Sale (POS) system. This information aids us in the efficient processing of sales, as it is used to verify customers' eligibility for purchases while also ensuring full compliance with airport security and customs regulations.

The providers of third-party apps, tools, widgets and plug-ins on our Online Services, such as Facebook “Like” buttons, also may use automated means to collect information regarding your interactions with these features. This information is subject to the applicable privacy policies or notices of these providers.

Location Information

LDF Online Services and in-store technologies may collect precise information about the location of your mobile device or computer using geolocation and location presence awareness technologies such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you are able to withdraw your permission for LDF to acquire this information on your location through the device or Web browser settings. If you have questions about how to disable collection of precise location information, we recommend you contact your mobile device service provider, the device manufacturer, or your Web browser provider (as the case may be). Please note that certain Online Services and in-store technologies may not function properly without precise location information. If you would like us to delete location information we have collected that is identifiable to you, please email us at hellosg@lotte.net or contact us via the postal address listed below. Please note that we may be required by law to retain certain information.

Combined Information

We may combine the information we receive from or about you, including information you provide to us and information we automatically collect through the Site or App, as well as information across other computers or devices that you use, with information we collect or receive about you from other online and offline sources, or from other third-party sources. This may also include using technologies to recognise multiple interactions and combine them into a single customer profile where appropriate.

Third-Party Analytics and Advertisements

We also may use third-party advertisements, analytics, and tracking tools to better understand who is using the Site or App, how people are using the Site or App, how to improve the effectiveness of the Services and related content, and to help us or those third parties serve more targeted advertising to you across our media channels. These third parties may use technology such as cookies, web beacons, pixel tags, log files, flash cookies, or other technologies to collect and store information. They may also combine information they collect from your interaction with the Site or App with information they collect from other sources, which combination may be subject to the third party’s control and privacy policy.

Social Networks

Our website and mobile or web-based applications may provide you with social plug-ins from various social networks (such as Facebook and Twitter). If you choose to interact with a social network, your activity on our website or via our mobile or web-based applications will also be made available to social networks such as Facebook and Twitter.

We cannot influence this data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings

2. The types of personal information we collect include:

• Transaction information, such as product purchased, price, method of payment and payment details.
• Personal details such as name, postal address, email address, phone number, and other contact information when you provide that information to us, such as if you register with our Online Services or enter a LDF contest, competition, prize draw, or sweepstakes.
• Unique information such as NRIC or passport numbers, photographs, and date of birth;
• Account information, such as username, password, and other identifiers or credentials used to access our Online Services to acquire LDF products and services.
• Lifestyle information such as your interest and hobbies including sensitive personal information like health status, or religious beliefs.
• Images of you; and information about you for your attendance at our events such as your dietary specifications.
• Other personal information you choose to provide when you interact with LDF.

3. Reasons for the Collection, Use and Disclosure of your personal data :

• Fulfilment and delivery (where applicable) of products and services you have purchased. We may share your personal information with our delivery partners, and third-party service providers;
• Processing your transactions and payments for LDF products and services;
• Registering for or use any of our Online Services operated by us or when you register as a member of websites and/or any membership programmes owned and/or operated by us;
• Providing customer support, such as responding to your inquiries, requests, and feedback;
• Providing customers with bespoke retail experience such as a customized site or app content, with targeted offers or through other third-party sites or apps, or via email, text messages or app push notifications that are offered by LDF or other marketing partners;
• Mailing you marketing or promotional materials, and literature about our products and services or those of our partners or affiliates;
• Communicate with you about and administer your participation in contests, competitions, prize draws, sweepstakes, offers, promotions or special events;
• Internal administrative and training purposes;
• Perform data analytics including consumer research, trend analysis and financial analysis;
• Conduct research and analysis to improve our products, services, and customer experience;
• Prevent and detect fraud and abuse in order to protect the security of our customers, LDF, and others;
• Comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities
• As otherwise described to you at the point of data collection.
• Any purpose which is related to or reasonably necessary for the aforesaid.

4. Why we may have to Share your Personal Information

LDF shares personal information and your communications with us with others to be able to improve our service and offerings to you and to enable the extension of the LDF brand and experience beyond our stores, sites, or Services.

A. When you use the Services, LDF may collect, process, use and/or store your personal data for the following purposes:

• We use third-party "service providers" (also called "vendors") to perform certain services on our behalf but only the necessary information would be disclosed for them to perform their duties. These third-party service providers are prohibited from using personal information for any other purpose and are contractually required to comply with all applicable laws and requirements;
• We may need to share your personal information with third-party service providers, both inside and outside of Singapore, who provide administrative, data processing, computer, or other services to LDF;
• We may need to disclose personal data to those involved in the negotiations or transfer of LDF in the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of LDF business assets;
• We may share your personal data to facilitate a research or analysis on trends;
• We may share your personal data in circumstances that are not listed herein. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless we are permitted under applicable laws to process your personal data without your consent.
• We may share collected personal data within the LOTTE Group of companies but such information shall receive the same standards of protections as prescribed in Singapore or South Korea or any other jurisdiction.
• We may need to fulfil any law, regulation or legal requirement to protect the integrity of our Online Services and in-store technologies to institute or defend against legal claims so as to protect the rights, interests, safety and security of LDF, its employees or franchisees, members of the public, or in relation to the investigation of fraud, illegal activities or violation of our policies.

B. Co-Marketing Partners: Certain areas of the services may be provided to you in association with third parties, such as companies that provide products and services, rewards programs, conduct joint sales programs sweepstakes, promotional campaigns, and other jointly sponsored events. Such services will identify the third party. If you elect to register for any products and/or services provided during the use of the services, you will either be providing your information to both LOTTE and such third party, or LOTTE might share your information directly with such third party for that third party to fulfil their services directly with you.

LOTTE may also share your information with select partners, affiliates, and other third parties that we believe may have offers or be of interest to you in support of your customer experience with us or others or to extend the LOTTE brand experience beyond our sites, stores, and Services.

5. Transferring Your Personal Data Outside Of Singapore

When we transfer your personal data outside of Singapore, we will do so according to the requirements under applicable law and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the data protection laws and regulations of Singapore by having appropriate safeguards such as a contract with the transferee entity receiving your personal data.

6. Retention

We will retain your personal data for a reasonable period for the purposes as cited herein or as required by law.

7. Security

We have taken certain physical, administrative, operational, and technical steps to safeguard the information we collect from and about our customers and Online Services visitors. While we make every effort to help ensure the confidentially, integrity and availability of our network and systems, we cannot guarantee our security measures. When you enter such information (e.g., credit card details) on our forms, we encrypt the transmission of that data to help prevent unauthorized access. Additionally, for your protection, your password and other sensitive information will be encrypted and securely stored in our system.

8. Disclaimer

To the maximum extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your personal data.

9. What Choices You Have.

A. You have a right to accuracy and correction of personal data. Therefore, you should ensure that all personal data submitted to us is true, accurate and complete. Failure on your part to do so may result in our inability to provide you with the goods and services you have requested.

To the extent required by the Act, LOTTE will use reasonable efforts to ensure that the personal data it uses is sufficiently accurate and complete to minimize the possibility that incorrect personal data may be used to make a decision that impacts the person to whom the personal data relates, or if such Personal Data is likely to be disclosed to a third party. However, you acknowledge that there may be circumstances where LOTTE is entitled to assume such accuracy and completeness, in accordance with law.

You may correct any erroneous personal data held by LOTTE by writing to us at hellosg@lotte.net. Any unresolved differences as to accuracy or completeness of personal data shall be noted in your records. Save as otherwise required under the Act, you may only correct any personal data which you have provided to LOTTE. LOTTE reserves the right to not correct personal data to the extent permitted under the Act.

B. You are deemed to have acknowledged and agreed to any amended version of this Privacy Policy if you continue to use our services after the changes have taken place. As such, you are encouraged to visit this page from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

If you do not accept the amended Privacy policy, and wish to withdraw your consent to any or all aspects of the consent you have given us at any time, or if you wish to update or have access to your personal data, you are welcome to contact us.

If you wish to opt out of receiving marketing communications, please contact us at hellosg@lotte.net or via the postal address listed below.

If at any time you would like to access, edit, or delete personal information we have collected from you, please contact us at dpoSG@lotte.net or via the postal address listed below.

If you wish to make a complaint regarding our handling of personal data, you may send your complaint in writing to the address below or email us at dpoSG@lotte.net.

LOTTE Travel Retail Singapore Pte. Ltd.

9 Tampines Grande
Asia Green
#03-12

Attention: Data Protection Officer

We will endeavour to respond to all requests without delay, and in any event within one month of receiving your request. There may be circumstances when we need to extend the time limit for responding to a request. Before responding to a request, we may be required to ask for further information and/or proof of identity.

Please note that if you opt out of receiving marketing communications from us, we may still send communications to you concerning your transactions, accounts with LDF and any contests, competitions, prize draws, or sweepstakes in which you have enrolled.

10. Governing Law

This Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.

Note: Certain services or platforms mentioned in this Privacy Policy (e.g., our website, mobile app, or online services) are not currently available, but these references are retained as they are intended for future-proofing. Where such services do not exist, the related sections may be disregarded as they do not apply at this time. Notwithstanding this, all other provisions of the Privacy Policy remain valid, enforceable, and fully applicable to the extent relevant.