Data Protection Policy

1. 1.Pokémon Singapore, Pte. Ltd.（“Pokémon SG”） is a wholly owned subsidiary of the Pokémon Company (Japan).

2. 2.Pokémon SG may, in the course of providing goods and services to you, collect, use, store, disclose or otherwise process your personal data. The term “personal data” refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organization has or is likely to have access. The terms used in this Policy shall bear the meanings assigned to them under the Personal Data Protection Act 2012 (“the PDPA”) to the extent that the context allows.

3. 3.Pokémon SG is committed to ensuring that any collection, use, storage, disclosure or otherwise processing of your personal data is done in compliance with the PDPA and the laws of Singapore. This Policy sets out the general principles that Pokémon SG will adhere to when collecting, using, storing, disclosing or otherwise processing of your personal data. Please read this Policy carefully. If you have any further questions regarding this Policy, you may contact Pokémon SG’s Data Protection Officer (see [20] below for contact details).

1. 4.Pokémon SG will generally collect your personal data only where (a) you have been informed of the purpose (see [5] below) of the collection, use, or disclosure and you have consented to the collection, use, or disclosure of your personal data; or (b) collection of your data is otherwise permitted under the PDPA, including situations where you may be deemed to have consented to the collection, use, storage, disclosure or otherwise of your personal data (e.g. where you have voluntarily provided your personal data for any particular purpose listed at [5] below). You may arrange for your consent to be given via a third party whom you have authorized to give such consent.

2. 5.Pokémon SG will collect, use, store, disclose or otherwise process your personal data for any or all of the following purposes:

   1. A)Performing obligations in the course of or in connection with our provision of goods and services to you;

   2. B)Verifying your identity;

   3. C)Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

   4. D)Sending you marketing information, newsletters, and other such media informing about our goods and services, including notifications on events, competitions, contests, projects, or campaigns at our stores;

   5. E)To manage your participation/membership in community groups and communities (e.g. fan clubs), which may be organized or hosted by us on the Internet, via newsletters, and other medium, and to use any comments received from you as material for such community groups and communities;

   6. F)Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

   7. G)For market research and analysis;

   8. H)For research and development of products and services;

   9. I)For other specific purposes that may be communicated to you from time to time;

   10. J)For disclosure to third parties (including third party service providers and agents) for the purposes set out above;

   11. K)To carry out any incidental business purposes related to or in connection with the above.

3. 6.If you are (i) below 13 years of age; or (ii) above 13 years of age but below 21 years of age and are unable to fully understand the purposes set out above and the consequences of disclosing your personal data, please speak to your parent/guardian, who have to provide consent on your behalf.

4. 7.The purposes listed at [5] may continue to apply for a reasonable period after your relationship with us (e.g. for example pursuant to a contract) has ended (including, where applicable, a period to allow us to enforce our rights under any contract with you).

1. 8.If you have given us consent to collect, use, or disclose your personal data, that consent shall remain valid until it is withdrawn by you. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above. This can be done by submitting your request for withdrawal in writing or via email to our Data Protection Officer (see [20] below for contact details).

2. 9.If you submit a written request to withdraw your consent, we may require a reasonable time to process your request (depending on how complex your request might be). We will also notify you of how the withdrawal of consent will affect your legal rights and liabilities to us. Please note that in certain situations, the withdrawal of consent might result in us no longer being able to provide the same goods and services to you.

3. 10.Please note that even where you may have withdrawn your consent, this does not affect our right to collect, use, and disclose personal data where such collection, use and disclosure without consent is permitted or required under the applicable laws.

1. 11.You may, by submitting a request in writing or via email to our Data Protection Officer, request to access the personal data which we hold about you or information about the ways in which we use or disclose your personal data. You may also, submit a request in writing, to correct or update any of the personal data which we hold about you. These submissions may be made to our Data Protection Officer (see [20] below for contact details).

2. 12.Please note that we may change you a reasonable fee for such access.

3. 13.We will respond to your request as soon as reasonably possible. If we are unable to do so within 30 days from your request, we will inform you in writing of the time when we will be able to respond. Please note that there are certain situations as provided for under the PDPA where we will not be able to, or are not required to, provide access or correction of personal data.

1. 14.We will adopt such reasonable administrative, physical and technical measures (including up-to-date antivirus protection and encryption) to secure all storage and transmission of personal data. The transmission/disclosure of personal data will only be done on a need-to-know basis.

2. 15.Please note that while we shall take all reasonable steps to protect and secure your personal data, no protection methods are full-proof, and security cannot be guaranteed.

1. 16.We will generally rely on the Personal Data provided by you and will generally assume that such data is accurate. In order to ensure that your personal data is accurate, please check the data you are submitting carefully. Please also inform the Data Protection Officer (see [20] below) if there are any changes in your personal data.

1. 17.We will generally retain your personal data to the extent necessary to fulfill the purposes for which it was collected, or as may be required or permitted under the applicable laws.

2. 18.We will cease to retain, or will remove the means by which the data can be associated with you (e.g. by keeping the data only in an anonymized form), as soon as it is reasonable to assume that retention is no longer necessary for the purposes for which the personal data was collected, and it is no longer necessary for legal or business purposes.

1. 19.We will generally not transfer your personal data out of Singapore. If such a transfer becomes necessary, we shall seek your specific consent for your Personal Data to be transferred in this manner, and will seek to ensure that your personal data will remain protected to a same standard as it would have in Singapore.

1. 20.You may contact our Data Protection Officer at: cs@pokemon.com.sg

1. 21.This Notice should be read alongside and as being complimentary to any other contractual clauses, consent clauses, notices, and such other documents which we may issue in relation to your personal data.

2. 22.We continually seek to improve our processes, and as such this Policy, may from time to time be changed without prior notice. Your continued use of our services and/or the continued purchase of goods shall be deemed to constitute your acceptance of the changed terms.

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