Sincere Watch Personal Data Protection Policy
Last Updated: March 2025
This Personal Data Protection Policy (“Policy”) sets out the basis which Cortina Holdings Limited and our subsidiaries, (collectively referred to herein as “Cortina Group”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data (“Personal Data”) of persons in accordance with the applicable Personal Data protection laws and regulations. As part of our efforts in implementing the latest policies, practices and processes, we will be reviewing these policies, practices and processes from time to time. We reserve the right to amend the terms of this Policy at our absolute discretion. This Policy, if amended, will be posted on our website. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to Personal Data protection. By continuing to have a relationship or dealings with Cortina Group, you shall be deemed to have accepted this Policy as amended and be bound by the prevailing terms as updated from time to time.
This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations which we have engaged to collect, use, disclose or otherwise process Personal Data for our purposes. At Cortina Group, safeguarding your Personal Data is our top priority and we take reasonable care and security to protect your personal data.
The purpose of this Policy is to inform you of how we manage Personal Data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”).
1. Your Personal Data
1.1. The PDPA defines Personal Data as data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which an organisation has or is likely to have access.
1.2. Cortina Group considers certain types of Personal Data as “sensitive information”. This includes, but is not limited to, personal details regarding a person’s racial or ethnic origin, political opinions or affiliations, religious or philosophical beliefs, membership in professional or trade associations or unions, sexual orientation or practices, criminal history, and health information (including genetic and biometric data). Cortina Group generally does not collect sensitive information about individuals. However, should you voluntarily provide us with sensitive information—for example, health-related data such as information about allergies or skin conditions—you are deemed to consent to our collection, use, and disclosure of that information solely for the purpose for which it was provided if it is reasonable that you would voluntarily provide the information, and in accordance with the provisions of the PDPA. We will handle any sensitive information we receive with reasonable care and in compliance with applicable legal requirements.
1.3. We may use your Personal Data for the following purposes: (a) the purpose for which it was collected (and related purposes which would be reasonably expected by you); (b) purposes to which you have consented; or (c) as otherwise authorized or required by law.
1.4. Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, education background, and information about your usage of and interaction with our website.
2. Collection of Personal Data
2.1. We may collect Personal Data from our customers, business partners, contractors, employees and other individuals such as job applicants. We would only collect data (a) for which you give, or is deemed to have given consent to the collection; or (b) the collection is required or authorised under the PDPA or any other written law.
2.2. We collect your Personal Data in several ways, including but not limited to:
2.2.1. when you complete forms related to our products or services (e.g., subscription forms);
2.2.2. when you register or use our website or services (e.g., creating an account, logging in);
2.2.3. when you post feedback or interact with our customer service officers, (e.g. via meetings, emails or telephone calls);
2.2.4. when you send items for servicing (e.g., watches, electronics);
2.2.5. when you participate in promotions or surveys (e.g., responding to feedback requests);
2.2.6. when you apply for a job with us (e.g., submitting a resume or application);
2.2.7. via CCTV recordings when you visit our premises or photo taking or video recording at events;
2.2.8. when you submit your Personal Data to us for any other reasons; and/or
2.2.9. when we collect your Personal Data by other lawful means.
2.3. If you provide us with Personal Data relating to a third party (e.g., spouse, children, parents, employees, or authorised representatives) for any purpose, you represent and warrant that you have obtained the necessary consent from the third party to Cortina Group collecting, using and/or disclosing such Personal Data for that particular purpose.
2.4. While browsing our website, you generally do so anonymously, though certain data such as cookies and IP addresses may still be collected (please refer to the section on cookies for more details).
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1. Cortina Group takes reasonable steps to protect your Personal Data from unauthorised disclosure. Subject to the provisions of applicable laws, your Personal Data will be collected, used, and disclosed only for legitimate purposes, including but not limited to:
3.1.1. performing obligations in the course of or in connection with our provision of the requested services and products by you;
3.1.2. managing your relationship with us;
3.1.3. responding to, processing, and handling your queries, requests, and complaints;
3.1.4. processing your job application, including pre-recruitment checks to assess a person’s suitability for available employment position;
3.1.5. verifying your identity;
3.1.6. complying with laws, regulations, codes of practice, and assisting law enforcement authorities in Singapore;
3.1.7. conducting data analytics (aggregated and anonymized) to improve products and client services; and
3.1.8. with informed consent, using data for any other related purposes in the course of business.
3.2. We may disclose or provide access to your Personal Data to third parties in connection with the purposes described in 3.1.1 of this Policy. We may disclose your Personal Data:
3.2.1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;
3.2.2. to comply with any applicable laws, regulations, codes of practice, guidelines or rules (e.g. in an emergency or when we receive a subpoena to disclose your Personal Data); or
3.2.3. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in paragraph 3.1.1 above for us. Any third parties engaged by us will be contractually bound to keep all Personal Data confidential.
4. Cross Border Transfers of Personal Data
4.1. As Cortina Group is an international business, you acknowledge and agree that some information (including Personal Data) may be transferred to regions/countries outside of Singapore in the ordinary cause of our business including to parties located in;
4.1.1. Malaysia
4.1.2. Thailand
4.1.3. Taiwan
4.1.4. Hong Kong (SAR) of China
4.1.5. Macau (SAR) of China
4.2. When Cortina Group discloses personal information outside of Singapore, we will comply with this Policy and the requirements of the Act pertaining to the transfer of Personal Data outside of Singapore, including any guidelines issued by the PDPC. If we do so, we will notify you of the transfer and provide confirmation that the transfer of Personal Data to the recipient is necessary for the purposes of fulfilling our obligations under applicable laws, and that we have taken reasonable steps to ensure that your Personal Data so transferred will not be used or disclosed by the recipient for purposes other than as permitted under the PDPA, and your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the applicable Personal Data protection laws and regulations of Singapore Additionally, where it is necessary to do so, Cortina Group shall enter into legally binding data sharing agreements with the recipients. In this regard, you confirm that by continuing to have a relationship with or deal with Cortina Group, you have consented or are deemed to have consented to the disclosure by Cortina Group of your Personal Data to the aforesaid recipient(s).
5. Disclosure without Consent; Deemed Consent
5.1. Subject to applicable data protection legislation, we may disclose your Personal Data without your prior consent in certain situations, including where required by law, or where it is necessary for law enforcement or legal processes.
5.2. Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your Personal Data to us for the stated purpose(s). By providing your Personal Data to us, you acknowledge and agree that you have fully read and understood this Policy, and are consenting to the collection, use, processing and disclosure of your Personal Data as described in this Policy. The exceptions upon which Personal Data may be collected without consent are pursuant to the Second Schedule of the PDPA, which is available at Singapore Statutes Online.
5.3. The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
6. Direct Marketing
6.1. Direct marketing involves communicating directly with you for the purpose of promoting the sales of goods and services. Direct marketing can be delivered by a range of methods including mail, telephone, email, WhatsApp, Line, REDnote or SMS. We may use and disclose your personal information for the purpose of sending you direct marketing materials where you have consented to us doing so; or it is otherwise permitted by law.
6.2. You can unsubscribe from receiving direct marketing materials from us at any time by contacting us (see section 14 of this policy) or by ticking the unsubscribe box and returning to sender any mail or by utilising the unsubscribe link in our digital communication. We will act upon this information within ten (10) business days of receiving it at our office, or shall otherwise inform you of the time frame by which the withdrawal consent will take place.
7. Security
7.1. Cortina Group shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession. Please notify us immediately if you become aware of any breach of security.
7.2. Cortina Group requires our contractors and third parties to keep Personal Data confidential and not to use or disclose it for any purpose other than performing services for us or on our behalf and to comply with this Policy and the requirements of the PDPA.
7.3. While Cortina Group implements security measures to protect your Personal Data, no system can be entirely free from risk. We will continuously review and enhance our security measures to mitigate potential threats and safeguard your data to the extent reasonably possible.
7.4. You should be aware that some information that you upload to our social media pages may be available to be viewed by public. You should use discretion in deciding what information to upload to such sites. Cortina Group is not responsible in any way for the security and/or management of Personal Data shared by individuals with third party websites accessible via links on Cortina Group’s website.
8. Withdrawal, Access, and Correction of Your Personal Data
8.1. Cortina Group provides procedures to manage your Personal Data in compliance with applicable regulations, including the Personal Data Protection Act (PDPA). Your consent for the collection, use, and disclosure of Personal Data remains valid until withdrawn in writing.
8.1.1. Withdrawal of Consent:
8.1.2. You may withdraw your consent for the collection, use, or disclosure of your Personal Data at any time by submitting your request in writing or via email to our Data Protection Officer by using Form A set out therein. Upon receiving your request, we will process it within ten (10) business days or otherwise inform you of the time frame by which the withdrawal consent will take place, and thereafter cease collecting, using, or disclosing your Personal Data as per your instructions but this does not affect Cortina Group’s right to continue to process Personal Data where such processing is permitted or required under applicable laws. Depending on the extent to which an individual withdraws consent to the use and/or disclosure of his or her Personal Data by Cortina Group, such withdrawal of consent may result in Cortina Group’s inability to provide services to the individual and may be considered as a termination by the Individual of the relevant agreement between Cortina Group and the Individual or a cessation of any services provided by Cortina Group to the Individual. Nevertheless, Cortina Group’s legal rights and remedies are expressly reserved in such event.
8.1.3. Access and Correction of Personal Data:
8.1.4. You may request to access or correct your Personal Data by submitting your request in writing or via email to our Data Protection Officer by using Form B or Form C set out herein. To respond to your request, we may ask you to provide us with a proof of your identity. We will aim to provide access to your Personal Data within thirty (30) business days If the request cannot be completed within this timeframe, we will notify you of the within 30 days after receiving the request;
8.1.5. For corrections, we will make the necessary changes as soon as practicable unless we are satisfied on reasonable grounds not to do so;
8.1.6. Depending on the scope and nature of your request, we may charge an administrative fee to cover processing costs. This will be assessed on a case-really-case basis, and you will be informed of any fee in advance. In some cases, a deposit may also be required; and
8.2. Please note that we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9. Accuracy of Personal Data
9.1. You must ensure that all Personal Data submitted to us is complete, accurate, true, and correct.
9.2. We will make every reasonable effort to ensure that Personal Data collected by us or on our behalf is accurate and complete.
9.3. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete, and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officers at the contact details provided in Section 15 below:
10. Data Retention
10.1. We will only retain your Personal Data for as long as necessary to fulfil the purpose(s) we collected it for and where retention is no longer necessary for legal or business purposes, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.2. To determine the retention period for your Personal Data, we (amongst other things) consider the nature of the Personal Data, the risk of unauthorised use or disclosure of your Personal Data, the purposes for which we process it and the applicable legal requirements.
10.3. Details of retention periods for different aspects of your Personal Data are available on request, by contacting us.
10.4. Should you require your Personal Data to be deleted from our records, please submit your request in writing via emails provided in section 15.
11. Links
11.1. Our websites may include links to other websites or other internet sources. Cortina Group cannot control these sites and external sources. Hence, Cortina Group cannot be held responsible for those sites or external sources, and declines any responsibility for the content, advertising, products, services and any other material available on or branching off those sites and external sources. In addition, Cortina Group cannot be held responsible for any damage or losses, true or alleged, deriving from the use or from having trusted the content, or goods and services available on those sites or external sources.
12. European Union (EU)
12.1. For individuals residing in the EU, we will obtain your explicit consent (written or electronic) for processing your Personal Data, unless the processing is otherwise permitted under the GDPR.
12.2. We will also obtain your explicit written or electronic consent prior to disclosing any of your personal information, unless such disclosure is permitted without consent under the GDPR.
12.3. Under the GDPR, you have several rights regarding your Personal Data, which can be exercised by submitting your request in writing or via email to our Data Protection Officers email addresses below or at 391B Orchard Road, #18-01 Ngee Ann City Tower B, Singapore 238874. These rights include access to your data, the ability to request corrections, deletion in certain circumstances, restriction of processing, data portability, and the right to object to processing, including for direct marketing or legitimate interests.
13. Use of Cookies
13.1. Cortina Group uses HTTP cookies (“Cookies”) on the Website to improve your online experience. A cookie is a small data file which is stored on your device when you use our website. You can block or deactivate cookies in your browser settings. You have to be aware that blocking or deactivating the cookies may, inter alia, affect the quality of your user experience on our website. By continuing to use our website, you are agreeing to the use of cookies on our website.
13.2. Cookies allow you to record data (information) from the use of the Website. The information is collected and stored on user’s own computer by the user’s web browser. The information collected can be used to personalise the online experience when using the Website, for example the Website will remember stateful information (item added to your wishlist) or record the browsing activity (logging in).
13.3. By using and accessing the Service provided by the Website, Cortina Group places a number of cookies file in your web browser. We use cookies for the following purposes:
13.3.1. to enable functions of the service;
13.3.2. to provide analytics;
13.3.3. to improve your online experience by remembering your preferences; and
13.3.4. to enable an improved advertisements delivery including behavioural advertising.
13.4. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our website if cookies are disabled.
13.5. In addition to our own cookies, we may also use third-party cookies to report usage of statistics of the Service, deliver advertisements on and through the Service or other purposes as previously-mentioned above.
14. Complaints
14.1. If you have any complaints or concerns regarding our handling of your Personal Data, please contact us by submitting your request in writing or via email to our Data Protection Officer by using Form D set out therein. We take such concerns seriously and will address them promptly.
14.2. When submitting a complaint, please provide sufficient details about your concern, including the nature of the complaint, the Personal Data involved, and any relevant information that may help us investigate your issue.
14.3. We aim to acknowledge your complaint within ten (10) business days and will keep you informed of the progress. We will investigate the matter thoroughly and strive to resolve it within a reasonable time frame.
15. Data Protection Officer
15.1. You may contact our Data Protection Officer if you have any enquiry, feedback or complaint regarding our Personal Data protection policies and procedures, if you wish to make any request, or if you believe that information, we hold about you is incorrect or out-dated.
15.2. You may contact our Data Protection Officer via email at dpo@sincerewatch.com.