While information is the foundation for providing you with superior service, protecting the privacy of your personal information is of the highest importance to us. We believe that responsible stewardship of the information entrusted to us is crucial in developing and maintaining the public trust which in turn is essential for our continued success. We are sensitive to your privacy concerns, and are committed to letting you know what kind of personal information is being collected and how the information is being used. It also describes how cookies and other technologies may be used in our software products.
Boncru Fine Wines
Boncru Fine Wines Pte. Ltd. is a private company registered in Singapore. We import and sell wines and beverages within the Republic of Singapore. For the purpose of this policy, Boncru Fine Wines Pte. Ltd. is referred to as "Boncru Fine Wines”.
What kind of personal information do we collect?
The kind of information we collect depends on the purpose for which it is collected. In relation to our employees we may collect name and home contact details, including addresses, phone numbers and email addresses. We may also collect details of their next of kin for emergency contact purposes. We also collect name, telephone and email contact details of people we deal with in the course of our business, such as our clients' and suppliers' representatives.
A significant part of our business is in the collection and analysis of data and as part of that we may obtain data which includes personal information such as names, addresses and other contact details.
How do we collect personal information?
Wherever reasonably possible, we collect personal information from the person to whom it relates. For example, you may provide your name and contact information to us to communicate with you. That is not always possible or appropriate and we do collect and use personal information from publicly available sources and from third parties. However, we only do so if the individual has consented to such collection or would reasonably expect us to collect their personal information in this way, or if it is necessary for specific purpose such as the investigation of a privacy complaint.
Where we collect personal information from third parties we are careful to seek confirmation from those providing us with the information that it was acquired in accordance with the requirements of the Singapore Personal Data Protection Act 2012, that they are entitled to provide it to us and that they are able to authorise us to use it for the purposes for which they are supplying it.
Why do we collect personal information and how do we use it?
We are in the business of providing our customers with product information, news analysis, event details and other services relating to the supply of wine and other beverages. To do so we gather, analyse and process volumes of information, some of which is personal information.
Boncru Fine Wines uses and discloses your personal information to enable the development and provision of our products and services. Generally personal information which we collect is only used and disclosed under the following circumstances:
•Your consent has been obtained in relation to the use or disclosure of the information
•It is used for the purpose for which the information was collected or for a related secondary purpose
•We are required or authorised under an Singaporean law or other legal order
Who do we disclose personal information to?
We supply a number of products and services which allow access to and use of personal information that we have collected to the extent you have consented to the use of your information to the person who collected it. Where you have provided the relevant consent allowing us to include your personal information in such products or services we provide and we may disclose your personal information to our clients who purchase those products or subscribe to the relevant services. Where we have obtained your personal information for other purposes, such as for use in our internal analysis, or for use in providing analytical services to clients, we may retain and use that personal information, but will not disclose it except as contemplated below.
We may disclose personal information we hold, including information obtained for internal analytical purposes to other members of the Boncru Fine Wines group and to reputable companies and suppliers (3rd parties) we engage to process data on our behalf. We require that all our suppliers protect such information from unauthorized access, use and disclosure and prohibit them from using the information we disclose for any purpose other than providing services to us.
Disclosures to other members of the Boncru Fine Wines group may include Boncru Fine Wines companies located in Thailand, Malaysia, Hong Kong, Indonesia, India and China. We do this so that we can take advantage of the specialist skills of other members of the Boncru Fine Wines group in developing our products, processing data and services. The companies we disclose to in these jurisdictions are related companies are members of and bound by safe harbour schemes concerning the use and management of personal information. In circumstances where we disclose personal information we hold to them, we generally retain control of that information for the purposes of those schemes, unless we have obtained your express consent to provide your information to international recipients. We can therefore ensure that the information we disclose is used only in accordance with this policy and in accordance with the requirement of the Singapore Personal Data Protection Act 2012.
Under certain circumstances Boncru Fine Wines may disclose your personal information if it is required by or under an Singaporean law or other legal order or we reasonably believe that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of an enforcement body.
How secure is your personal information?
Boncru Fine Wines recognises and acknowledges the importance of keeping the personal information and data that it holds, secure and protected from unauthorised access. To do this, at a minimum Boncru Fine Wines utilises industry standard security and encryption processes and technology and ensures that access to your personal information is only provided to those employees who need to have access in order to perform their role. Access is also provided to users and subscribers of the products and services we offer and any law enforcement agency with whom we are required by law to provide your personal information. These standards operate globally across the Boncru Fine Wines group so, if we disclose your personal information to any of our overseas affiliates, the same level of security will apply. To the extent that we disclose any personal information to our clients, we require that they implement appropriate safeguards with regard to the security of that information.
We may be obliged to disclose personal information we hold to law enforcement agencies. In such circumstances the use and security of that information is determined by the rules governing the relevant agency.
To ensure that we maintain the standards we have set for security and that we comply with our obligations in relation to the storage and handling of your personal information Boncru Fine Wines requires all of its employees to complete regular training in relation to the handling of personal information and the application of our security policies. We will also regularly review this policy and assess our performance against it to ensure we are meeting and continue to meet our obligations under the Singapore Personal Data Protection Act 2012.
How do we maintain the quality of your personal information?
It is extremely important to us that the personal information we hold about you is up to date and accurate. The information we receive from the users of our products and services and the data we collect from publicly available sources and 3rd parties are subject to various processes to ensure the information is accurate. Where updated information is available we will incorporate it into our products as soon as practicable. The time it takes to apply updates to products depends on the product itself, while some can be updated almost immediately; others have release cycles as long as three months, so the time taken for a change to become effective may vary considerably.
How can you access or correct the personal information we hold?
Should you wish to gain access to or correction of your personal information, you may contact us at Boncru Fine Wines.
Generally we are happy to provide details of the information we hold free of charge. However to the extent permissible under law, we reserve the right to charge a nominal fee commensurate with our costs of extraction and collation of information where significant work is involved. We will require you to adequately identify yourself when requesting a copy of your personal information.
If you would like us to update your information or you believe that any of the information we hold is incorrect, please let us know. Where we have obtained information directly from you, we may occasionally ask you to update your information. Data will not be kept for longer than is necessary and will be removed from our database at your request. If you wish Boncru Fine Wines to delete your profile, you may contact us at Boncru Fine Wines.
There are certain limited circumstances permitted under the Singapore Personal Data Protection Act 2012 in which we may decline to permit access to the information we hold, or we may decline to apply a correction to that information which you have requested. In such circumstances you may require that we note that a request for access or correction has been refused by us.
How can you complain about our use of personal information?
Where you feel the information we have provided to you may not be accurate or you have a dispute regarding the information we hold, you may contact us at Boncru Fine Wines in order for us to investigate the matter further. In general we aim to respond to all complaints promptly and in any event in less than 30 days. We aim to act promptly and reasonably in resolving any complaints.
There are some circumstances, for example, where the matter is complex, or the resolution relates to a product with a long update cycle, where we may require additional time to resolve an issue or to implement a correction.
Upon conclusion of our investigation and if you are still dissatisfied with our outcome, you have the right to refer the matter to the Commissioner for handling at:
Personal Data Protection Commission
460 Alexandra Road
#10-02 PSA Building
Phone: +65 6508 7333
Fax: +65 6273 7370
Collection and use of information through this website
This section only covers Boncru Fine Wines's web site at www.boncrufinewines.com . Other web sites by Boncru Fine Wines and other members of the Boncru Fine Wines group are governed by their respective privacy statements.
We collect information from visitors (your visits) to this website through the use of enquiry forms and every time you e-mail us your queries or details. Where that information is personal information, it is collected and handled in accordance with the general Privacy Statement set out above. In addition we log your IP address (this is the technical standard which ensures messages get from one host to another and that the messages are understood) which is automatically recognised by the web server.
Use of personal information
We process personal information collected via this web site for the purposes of:
•Identifying potential customers or subscribers.
•Providing you with the services that you have subscribed to or registered for.
•Dealing with your requests and enquiries.
•Providing you with information about products and services offered by Boncru Fine Wines.
We DO NOT sell personal information collected through this site or use your personal information for any other purposes than those stated above.
Cookies may be used by us to provide you with customised information from our web site. A cookie is an element of data that a website can send to your browser, which may then store it on your system. Cookies allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our web site. Cookies may also allow us to make our website more user friendly by, for example, allowing us to save your password so that you do not have to re-enter it every time to visit our web site.
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by browsing this website and communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.
Where you have provided us with information through this website, you may access and update your data at any time by accessing this system.