TRANZGO PTE LTD owns the operation of ipharmerci.com. This Privacy Notice (this “Notice”) applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from goods and/or services offered by TRANZGO PTE. LTD (UEN No. 202006489E) (collectively referred to as “TRANZGO”).
1. This Notice provides information on the obligations and policies of TRANZGO in respect of an individual’s Personal Data. TRANZGO undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
2. TRANZGO’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, TRANZGO. TRANZGO shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by TRANZGO shall be done in an appropriate manner and in accordance with the Act and this Notice.
3. By interacting with TRANZGO and its related platforms (including but not limited to the Site), submitting information to TRANZGO, or signing up for any products or services offered by TRANZGO, the User agrees and consents to TRANZGO as well as to its respective representatives and/or agents ("Representatives") (collectively referred to herein as "TRANZGO", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves the User's Personal Data, and disclosing such Personal Data to TRANZGO’s authorised service providers and relevant third parties in the manner set forth in this Notice.
4. This Notice supplements but does not supersede nor replace any other consents the User may have previously provided to TRANZGO in respect of the User's Personal Data, and the User consents herein are additional to any rights which TRANZGO may have at law to collect, use or disclose the User's Personal Data.
5. For the purposes of this Notice, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of TRANZGO or that which shall be collected by TRANZGO in future.
6. The website and mobile apps uses Google Firebase for data protection and support for GDPR and CCPA. Firebase technology by Google is generally a data processor under GDPR and processes personal data on their behalf. Similarly, when customers use Firebase, Google generally operates as a service provider under the CCPA handling personal information on their behalf. Firebase terms include Data Processing and Security Terms detailing these responsibilities.
Contacting the Data Protection Officer
1. Where the User legitimately requests access to and/or correction of Personal Data relating to the User, such Personal Data which is in the possession and control of TRANZGO, TRANZGO shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter
2. In accordance with the Act, TRANZGO has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that TRANZGO receives complaints and enquiries, the User should send the same via email to the Data Protection Officer (the “DPO”) of TRANZGO at the following email address: [EMAIL]
3. Please note that if the User's personal data has been provided to TRANZGO by a third party (e.g. a member via a referral process), the User should contact that individual to make such queries, complaints, and access and correction requests to TRANZGO on the User's behalf.
4. Should the User not wish TRANZGO to use the User's Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from TRANZGO, the User may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. The User's request shall be processed within 30 days. Please note however that this may affect TRANZGO’s ability to attend to the User's needs in the event where there is an existing business relationship between TRANZGO and the User.
Statement of Practices
Types of Personal Data Collected:
1. As part of its day-to-day activity, TRANZGO may collect from the User, through various means, including via TRANZGO’s websites (including the Site), smart phone applications, marketing events such as road shows and any forms used by TRANZGO from time to time, some or all of the following Personal Data:
• Name (first and surname)
• Postal Address
• Office number
• Fax number
• Email address
• Bank account/credit card details
• Personal Data of your emergency contacts
• IP addresses
• Information on the User's trades and
• Photographs and images
TRANZGO uses third party service provider(s), to assist TRANZGO in better understanding the use of the Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.
Purpose of Collection of Personal Data2. The above Personal Data mentioned in Clause 3.1 is collected for the purposes of:
• allowing you to open and operate an Account on the Platform
• enabling you to complete Transactions on the Platform
• to ascertain if you are eligible for any discounts, privileges, or benefits or other related purposes
• to conduct market research and analysis eg. surveying our Users' needs and opinions on issues, such as our performance
• to notify you of any changes to our policies or services which may affect you
• to respond to queries and feedback
• maintaining and updating your Account details
• as required for regulatory purposes
• to provide you with information about products and promotions that may be of interest to you, from ourselves and third parties, although only if you have specifically
• for direct marketing through voice calls; text messages; email; direct mail and facsimile messages
• for payment and/or credit control purposes and
• informing you of new developments, services, promotions of TRANZGO and other third parties which we are associated with.
Disclosure of Personal Data3. In order to carry out the functions described above, TRANZGO may, from time to time, disclose your Personal Data between TRANZGO’s companies and the Representatives.
4. Without derogating from any of the above, TRANZGO may also disclose your Personal Data to the following third parties:
• Regulators and law enforcement officials
• Third party service providers and consultants
• Credit, debit and charge card companies, banks and other entities processing payment
• Financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organisation
• Potential buyers or investors of TRANZGO or any of TRANZGO’s companies and
• Any agent or subcontractor acting on TRANZGO’s behalf for the provision of TRANZGO’s services
5. TRANZGO may disclose the User's Personal Data to the abovementioned parties also in the occurrence of any of the following events:
• To the extent that TRANZGO is required to do so by the law
• In connection with any legal proceedings or prospective legal proceedings
• To establish, exercise or defend TRANZGO’s legal rights
• To the purchaser (or prospective purchaser) of any business or asset which TRANZGO is (or is contemplating) selling
• To any person and/or entity for the purpose of processing such information on TRANZGO’s behalf
• To third parties who provide services to TRANZGO or on its behalf
• To any third party that purchases TRANZGO or TRANZGO’s business or any part of TRANZGO or TRANZGO’s business
• With your consent and
• For the purposes of disaster recovery
Any third party which receives or has access to Personal Data shall be required by us to protect such Personal Data and to use it only to carry out the services they are performing for you or for TRANZGO, unless otherwise required or permitted by law.
We will ensure that any such third party is aware of our obligations under this Notice and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Data disclosed to them than the obligations we undertake to you under this Notice or which are imposed on us under applicable data protection laws.
Optional Provision of Personal Data6. In some instances, you may also be requested to provide certain Personal Data that may be used to further improve TRANZGO’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent TRANZGO from providing the service to you.
7. Under certain circumstances, telephone calls made to any of TRANZGO’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Notice, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.
Transfer of Personal Data Overseas
To the extent that we may need to transfer personal data outside of Singapore, whether to our group companies or business partners or third-party service providers or simply to data storage facilities, we shall do so in accordance with the Personal Data Protection Act, 2012 (“PDPA”) to ensure that we provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA
Accuracy of Personal Data
Where possible, TRANZGO will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, TRANZGO is able to validate the data provided against pre-existing data held by TRANZGO. In some cases, TRANZGO is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of TRANZGO, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
Protection of Personal Data
TRANZGO uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside TRANZGO, other than to you or as described in this Notice. However, TRANZGO cannot ensure or warrant the security of any information you transmit to TRANZGO and you do so entirely at your own risk. In particular, TRANZGO does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of TRANZGO’s physical, technical, or managerial safeguards.
Access and Correction of Personal Data
1. In accordance with Clause 2.1 of this Notice, you have the right to:
1. check whether TRANZGO holds any Personal Data relating to you and, if so, obtain copies of such data; and
2. require TRANZGO to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
2. TRANZGO reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.
3. If you wish to verify the details you have submitted to TRANZGO or if you wish to check on the manner in which TRANZGO uses and processes your personal data, TRANZGO’s security procedures mean that TRANZGO may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, Account number and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which TRANZGO takes in response to a request from someone using your Account details. We would strongly recommend when you login to your online account in our websites that you do not use the browser's password memory function as that would permit other people using your terminal to access your personal information.
Storage and Retention of Personal Data
TRANZGO will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of TRANZGO and where the Personal Data is deleted from TRANZGO’s electronic, manual, and other filing systems in accordance with TRANZGO’s internal procedures and/or other agreements. In accordance with our record keeping obligations we will retain Accounts and Personal Data for, at least a period of five years after they are closed by Users.
We have implemented security measures to ensure the confidentiality of your Personal Data and to protect your Personal Data from loss, misuse, alteration or destruction. Only authorized personnel of TRANZGO have access to your Personal Data, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.
Withdrawal of Consent
You have the right to ask us not to process your Personal Data for marketing purposes. You can exercise the right at any time by contacting us at firstname.lastname@example.org
This Notice is governed by and shall be construed in accordance with the laws of Singapore. The User hereby submit to the non-exclusive jurisdiction of the Singapore courts.
1. This Notice only applies to the collection and use of Personal Data by TRANZGO. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. TRANZGO does not share the User's Personal Data with third party websites. TRANZGO is not responsible for the privacy and conduct practices of these third-party websites. The User should read the privacy policies of these third-party websites before disclosure of any Personal Data to these websites.
2. TRANZGO will not sell the User's personal information to any third party without the User's permission, but TRANZGO cannot be responsible or held liable for the actions of third-party sites which the User may have linked or been directed to TRANZGO’s website.
3. TRANZGO’s websites (including the Site) do not target and are not intended to attract minors under the age of twenty-one (21) years old. TRANZGO does not knowingly solicit personal information from minors under the age of twenty-one (21) years old or send them requests for personal data.
4. There may be links from TRANZGO’s websites (including the Site) to other websites and resources provided by third parties. This Notice applies only to TRANZGO’s websites (including the Site). Accessing those third-party sites or sources requires the User to leave TRANZGO’s websites. We do not control those third-party sites or any of the content contained therein and the User agree that we are in no way responsible or liable for any of those third-party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. The User agrees to review all policies, rules, terms and regulations, including the privacy notices, of each third-party site that the User visits.
5. Please be notified that TRANZGO is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media and who may promise to help solve the User's issues for money.
Remember - customer support is provided only via the TRANZGO website and is always provided free of charge.
If the User encounters anything the User believes may be a fraud, phishing, or scam which impersonates TRANZGO, the User should email TRANZGO immediately at email@example.com