Effective date: Dec 3rd, 2023
Last updated: March 2nd, 2026
This Privacy Policy describes how 99 Peaks Pte. Ltd., its affiliates, and subsidiaries (collectively, “99 Peaks,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.
We collect information about you in a variety of ways depending on how you interact with us and our websites, mobile applications, and services, including:
The following table summarizes the type of information we collect in various contexts and how we use that information.
| Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
| Account Registration | Your name and contact information when you create an account; information relating to actions you perform while logged in. | Legitimate interest in providing account-related functionalities (e.g., easy checkout, saving preferences and transaction history). |
| Client Information | Name and contact information of our clients and their employees with whom we interact. | Legitimate interest in contacting clients and communicating concerning normal business administration (projects, services, billing). |
| Cookies and First-Party Tracking | Cookies and clear GIFs. “Cookies” are small pieces of information a website sends to a computer’s hard drive while a website is viewed. See our Cookie Preference Center for more information. | Legitimate interest in making our website operate efficiently. |
| Cookies and Third-Party Tracking | Tracking technology that collects analytics, records how you interact with our website, or allows behavior-based advertising (e.g., third-party cookies). Third parties may collect information over time and across websites. See our Cookie Preference Center for more information. | Where required by law, we base the use of third-party cookies upon consent. |
| Demographic Information | Personal information such as your age or location. | Legitimate interest in understanding our users and providing tailored services. |
| Distance Information | Your location from GPS, Wi-Fi, and/or cellular technology in your device when you use our Apps. | Legitimate interest in understanding our users and providing tailored services. In some contexts, use is also based on your consent to provide geo location information. |
| Email Interconnectivity | Data related to when you open our messages, click links or banners, and make purchases. | Legitimate interest in understanding how you interact with our communications. |
| Employment | Information necessary to process your application or retain you as an employee (e.g., Social Security Number). Required for employment. | Perform obligations to employees; in some contexts required by law to collect. Legitimate interest in efficient staffing and workforce operations. |
| Feedback/Support | Your name, email address, and any other content you send when you provide feedback or contact us for support. | Legitimate interest in receiving and acting upon your feedback or issues. |
| Health and Wellness Data | Information you directly input or allow us to receive by consent relating to your health: vital sign data, lab test results, medical conditions, treatments, prescriptions, disabilities, physical and physiological data, and other information you make available. | Perform our contract to provide you with products or services. Legitimate interest in sharing information about our products or services based on the information you provide. |
| Mailing List | Your email address or postal address when you sign up for a mailing list. | Share information about our products and services with individuals who consent. Legitimate interest in sharing information about our products or services. |
| Mobile Devices | Unique identifying information broadcast from your device when visiting our website or stores. | Legitimate interest in identifying unique visitors and understanding how users interact with us on mobile devices. |
| Order Placement | Name, billing address, shipping address, email address, phone number, and credit card number when you place an order. | Perform our contract to provide you with products or services. |
| Partner Promotion | Information you provide as part of a co-branded promotion with another company. | Legitimate interest in fulfilling our promotions. |
| Surveys | Information you provide through the survey. If provided by a third party, that party’s privacy policy applies. | Legitimate interest in understanding your opinions and collecting information relevant to our organization. |
| User Content | Contest picks, scores, and entries; forum/blog content, comments, reviews, questions, and metadata associated with your content. | Understand our users, improve our Services, and foster a safe environment on our websites. |
| Whistleblower hotline | Personal information that individuals who use the hotline provide (e.g., contact information or information relating to other individuals or employees). Contact information may not remain confidential in all instances. | Legitimate interest in allowing employees to communicate regarding issues that might violate our policies or procedures. In certain situations we may disclose (e.g., consent, legal obligation, legitimate business interest, or to protect individuals at risk). |
| Website interactions | Technology to monitor how you interact with our website (e.g., links clicked, information typed into forms, device or browser information). | Legitimate interest in understanding how you interact with our website, improving it, understanding your preferences and interests, and detecting and preventing fraud. |
| Web logs | Browser type, operating system, IP address, domain name, click-activity, referring website, and/or date/time stamp for visitors. | Legitimate interest in monitoring our networks and visitors; understanding which of our services is most popular. |
In addition to the purposes and uses described above, we use information in the following ways:
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you engage our services, we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your transactions. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:
Some jurisdictions give you a right to make the following choices regarding your personal information:
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
You may exercise the rights described above by contacting us as indicated in the “Contact Information” section below. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last time you transacted with us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a signed and notarized form indicating that you are able to act on another person’s behalf.
We store user data securely on encrypted servers hosted by Amazon Web Services (AWS), using SSL encryption protocols to protect data during transmission and at rest. Note, however, that no method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements. For example, we typically retain your user-inputted data for twelve (12) months after account deletion unless legally required to retain it longer.
As a multi-national company, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States and/or Singapore. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices, websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.
We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. If we make a material change to our privacy notice, we will attempt to notify you through email, in-app notification, and/or through a website pop-up.
Our websites and online services are not intended for children under the age of 18 and we do not knowingly collect personal information from children under age 18. Children under the age of 18 should not provide their personal information to us.
If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.
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