Bronx Holdings Private Limited Privacy Notice
Effective Date: 31 August 2024
1. Scope
This Privacy Notice and its Addendum(s) ("Privacy Notice") describe how Bronx Holdings Private Limited, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively "Bronx", "Bronx Aerogel", "we", "us" or "our") collect, use, process and disclose your Personal Data through the use of Bronx's mobile applications and websites (respectively "Apps" and "Websites"), as well as products, features and other services globally, operated by Bronx (collectively, "Services").
"Personal Data" is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.
We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) ("PDPA") and other applicable data protection laws, including the European Union ("EU") General Data Protection Regulation ("GDPR"), where applicable. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in section 6 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between Bronx and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement or may be necessary to perform any contract you have agreed with us or perform services that you have requested.
In addition, if your Personal Data has been collected, used or disclosed by us in a particular jurisdiction which has specific requirements or exceptions to the definition of Personal Data, including sensitive Personal Data, we will comply with those requirements under the applicable data protection regulations in that jurisdiction.
2. The Types of Personal Information We Collect
Bronx collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Notice. When you do not provide personal information to Bronx, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:
| Personal Information | |
| Category | Description/Examples |
| Commercial Information | Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services. |
| Business Contact Data | Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities. |
| Marketing and Communications Data | Information with respect to your marketing preferences and your subscriptions to our publications and alerts. |
| Internet and Electronic Network Data | Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and information derived from any device that connects to our WiFi services. |
| Your Feedback | Information you provide about our Services, which may include data gathered from any Bronx Aerogel surveys or reviews submitted by you |
| Visitor Information | Information an individual provides when visiting any physical location or premises of Bronx (e.g., visitor logs and registries, vehicle and parking information). |
| Video and Images | In some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing. |
| Geolocation Data | Information about the general city, state, or region in which a user of the Site is located. |
| Professional or Employment Data | If you apply for a job with Bronx, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references. |
| Inferences | Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behaviour. |
3. How We Use your Information / Purpose of Collection
We collect the information as described above for the following reasons:
communicate with you and respond to your inquiries or requests (e.g., requested materials, a requested newsletter), including as part of the "Contact Us" feature on our website;
send administrative information to you (e.g., information regarding the changes to our terms and conditions);
provide you with customer service and customer support related to troubleshooting in connection with our products, solutions and Services;
manage the planning of events and webinars, and other management-related purposes, such as registration, attendance, connecting you with other event attendees, and contacting you about relevant events, products, solutions and Services;
carry out our obligations and enforce our rights arising from contracts entered into between you and Bronx, including for billing and payment collection;
send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you;
present products, solutions and offers tailored to you;
tailor your experiences with our Services to meet your special interests and needs;
engage in one of the following activities: data analysis, audits, fraud monitoring and prevention, developing new products and solutions, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities;
send you satisfaction surveys to better understand your uses and experiences with our products, solutions and Services;
help diagnose problems with our servers, to manage our Services and to enhance our Services based on the usage pattern data we receive;
keep business records (such as tax and accounting);
protect our operations or those of any of our affiliates;
protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;
comply with legal process;
pursue available remedies or limit the damages that we may sustain and;
respond to requests from public and government authorities;
4. Disclosure Of Information
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.
Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions (including rebates and returns), tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.
Distributors and Business Partners.We may share your personal information with third parties that distribute our goods, products, and marketing materials.
Business Restructuring.Circumstances may arise where, for strategic or other business reasons, Bronx decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of Bronx's assets.
Legal; Compliance; Legitimate Interests.We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, Bronx may disclose your personal information to any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.
Consent.In addition to the reasons for disclosure set forth herein, we may also disclose your personal information upon your consent. In the event that you facilitate a transaction with Bronx, or request information from or otherwise engage with us, and such activities require Bronx to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Bronx to intentionally disclose your personal information to the service provider or third party.
5. Retention Of Personal Data
We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.
6. Protection of Personal Data
We will take reasonable legal, organizational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorized way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorized manner and are required to treat your information with confidentiality.
Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.
7. International Transfers Of Personal Data
Your Personal Data may be transferred from the country, state and city ("Home Country") in which you are present while using our Services to another country, state and city ("Alternate Country").
When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.
Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.
8. Cookies, Related Technologies And Advertising On Third Party Platforms
Bronx, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), which have similar functions to cookies and which may be installed in the Bronx Aerogel App to allow partners to collect certain information about your interaction with the Bronx Aerogel App) (collectively, "Cookies") in connection with your use of the Websites and Apps, which may be persistent or stored only during an individual session on your browsers or devices.
Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may be used for various purposes such as to:
provide the essential, basic functions of the use of our Websites, Services or Apps;
authenticate you, or remember your user preferences and settings;
delivering and measuring the effectiveness of advertising campaigns, such as by measuring number of views or clickthroughs;
analyse site traffic and trends;
serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers);
enhance user interface and experience by generally understanding the online behaviors and interests of users who interact with our Website, Services or Apps.
Bronx may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Bronx does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.
Disabling the collection of cookies on our websites
You have the right to choose to disable, block or deactivate cookies. Please note that however refusal or removal of some cookies could affect the availability, functionality or use of our Website, Services or Apps. You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the "History", "Preferences", "Settings" or "Privacy" section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information. You may also adjust your cookie settings here:
Disabling the display of Targeted Ads on other platforms
We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of.
You may be able to limit our use of your Personal Data to display targeted advertisements on behalf of our advertisers, by adjusting your preference through our Bronx Aerogel App. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple's IDFA or Google's GAID) and the ability to track you across apps and websites owned by other companies by adjusting the settings available on your mobile devices. Through adjusting the settings on your device, you can typically reset, delete, limit and/or otherwise restrict the use of such mobile identifiers.
Although we will not use your Personal Data to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers / platforms to display ads to users of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms
9. Your Rights With Respect To Your Personal Data
In accordance with applicable laws and regulations, you may be entitled to:
inquire about the processing of your Personal Data and be provided with a copy of it;
in some cases, request the correction and/or deletion of your Personal Data;
in some cases, request the restriction of or object to the processing of your Personal Data;
withdraw your consent to the processing of your Personal Data within our possession or control (and where we are processing your Personal Data based on your consent);
request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.
Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section III (How We Use your Information / Purpose of Collection) or that you are unable to make use of App or the Services.
After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.
We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.
10. Amendments And Updates
Bronx may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on the website www.bronxaerogel.com. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase products from Bronx or continuing to communicate or engage with Bronx following the modifications, updates or amendments to this Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
11. Governing Law
This Policy and your use of this website shall be governed in all respects by the laws of Singapore. For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.
12. Contact Us
If you have questions regarding this Privacy Notice or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Champion at: (email) privacy@bronxaerogel.com; or please use our interactive web form.