Bulbs Privacy Policy (Last Updated 7 Sep 2020)

  1. 1. Welcome to the Bulbs online website or mobile application (the “Platform“) run by Bulbs Pte. Ltd. (UEN: Ltd (UEN: 202017841Z) (“Bulbs“, “we“, “us” or “our”) .We take our responsibilities under applicable data privacy laws and regulations (“Data Privacy Laws“) seriously and are  committed to respecting the data privacy rights of all users of the Platform (the “Platform“) (collectively “you”, “Users” or “Parties”). We recognise the importance of the Personal Data you have entrusted to us and understand that it is our responsibility to properly manage, protect and process your Personal Data. This Privacy Policy (this “Privacy Policy”) is designed to help you understand how we collect, use, disclose and process the Personal Data you have provided to us or which we possess, whether now or in the future, as well as to help you to make an informed decision before providing us with any of your Personal Data. 
  1. 2. “Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of Personal Data include an individual’s name, identification number and contact information.
  1. 3. By using the Services, registering for an account with or on the Platform, visiting the Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and policies set out in this Privacy Policy, and you consent to us collecting, using, disclosing and processing your Personal Data in accordance with this Privacy Policy.

If you do not consent to the processing of your Personal Data in accordance with this Privacy Policy, please do not use any of the Services or access the Platform. If we change this Privacy Policy, we will post those changes or the amended Privacy Policy on our platform, and the amended Privacy Policy takes effect with immediate effect on such posting. We reserve the right to amend this Privacy Policy at any time.

  1. 1. We may collect Personal Data about you:
  • (a) when you register or use our Services or the Platform, or open an account with or on the Platform (“Account“);
  • (b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products or any of the Services, whether online or by way of a physical form;
  • (c) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products or any of the Services;
  • (d) when you interact with us, such as via telephone calls (which may be recorded), video communications (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
  • (e) when you use any of the Services, or interact with us via the Platform or access the Platform. This includes through cookies which we may deploy when you interact with our software application or website;
  • (f) when you carry out transactions through or in connection with the Services;
  • (g) when you provide us with feedback or complaints;
  • (h) when you register for a contest conducted through the Platform or the Services; or
  • (i) when you submit your Personal Data to us for any reason.

The above is not an exhaustive listing of when we may collect Personal Data about you, and merely sets out some of the more common examples of when Personal Data about you may be collected.

  1. 1. The Personal Data that Bulbs may collect includes but is not limited to your:
  • (a) name;
  • (b) email address;
  • (c) date of birth;
  • (d) billing address;
  • (e) shipping address;
  • (f) bank account and payment information (including credit card details);
  • (g) telephone number;
  • (h) gender;
  • (i) information sent by or associated with the device or devices used to access the Services or the Platform;
  • (j) any other information about the User when the User signs up to use the Services or the Platform, and when the User uses the Services or Platform, as well as information related to how the User uses the Services or the Platform; and
  • (k) aggregated data on content made available on the Platform or through the Services that the User engages with.
  1. 2. You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.
  1. 3. If you sign up to be a user of the Platform or the Services using your social media account (“Social Media Account”), link your Account to your Social Media Account or use any social media features of the Platform or the Services, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider’s terms and policies, and we will manage and use any such Personal Data in accordance with this Privacy Policy at all times.
  1. 4. If you do not want us to collect the abovementioned information or Personal Data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled “How can you withdraw consent, remove, request access to or modify information you have provided to us?” Please note, however, that opting out or withdrawing your consent for us to collect, use or process your Personal Data may adversely affect your use (including your experience and ability to use) of the Services and the Platform.  For example, opting out of the collection of location information will cause its location-based features to be disabled.
  1. 1. As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse the Platform. This typically includes your device’s Internet Protocol (IP) address, computer or mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a “cookie” (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use the Platform.
  1. 2. Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and process this information for one or more purposes including location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device’s location services, please contact your mobile device service provider or the device manufacturer.
  1. 1. We may from time to time implement “cookies” or other features to allow us or third parties to collect or share information that will help us improve the Platform and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognise your computer or device and tell us how and when the Services or Platform are used or visited, by how many people and to track activity within the Platform. We may link cookie information to Personal Data. Cookies also link to information regarding what items you have selected for purchase and pages you have viewed. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor usage of the Services.
  1. 2. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of the Platform or the Services.

As when you view pages on our website or mobile application, when you watch content and advertising and access other software on the Platform or through the Services, most of the same information is sent to us (including IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time.

  1. 1. We may collect, use, disclose and process your Personal Data for one or more of the following purposes:
  • (a) to consider or process your application or transaction with us or your transactions or communications with third parties via the Services or the Platform;
  • (b) to manage, operate, provide and/or administer your use of or access to our Services and the Platform (including remembering your preferences), as well as your relationship and Account with us;
  • (c) to respond to, process, deal with or complete a transaction or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
  • (d) to enforce our Terms of Use or any applicable end user licence agreements or other agreements with you or policies referred to in any of them;
  • (e) to protect personal safety and the rights, property or safety of others;
  • (f) for identification or verification;
  • (g) to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
  • (h) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
  • (i) to contact you or communicate with you via voice call, video call, text message, fax message, email and postal mail or otherwise for the purposes of administering and  managing your relationship with us or your use of our Services or the Platform, such as communicating administrative information to you relating to our Services or the Platform. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes or mail packages;
  • (j) to allow other Users to interact or connect with you on the Platform, including to inform you when another User has sent you a private message or posted a comment for you on the Platform;
  • (k) to conduct research, analysis and development activities (including data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
  • (l) to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with the Services;
  • (m) for marketing and in this regard, to send you by various modes of communication marketing and promotional information and materials relating to products and services (including products and services of third parties whom Bulbs may collaborate or tie up with) that Bulbs (and its related corporations, as it is defined under the Singapore Companies Act (Cap 50.)) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related corporations;
  • (n) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on Bulbs or on its related corporations;
  • (o) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
  • (p) to carry out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
  • (q) to audit our Services or Bulbs’ business;
  • (r) to prevent or investigate any actual or suspected violations of our Terms of Use, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
  • (s) to store, host, back up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of your jurisdiction;
  • (t) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Bulbs as a participant or involves only a related corporation or affiliate of Bulbs as a participant or involves Bulbs and/or any one or more of Bulbs’ related corporations as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and
  • (u) any other purposes which we notify you of at the time of obtaining your consent,

(collectively, the “Purposes”).

  1. 2. You acknowledge, consent and agree that Bulbs may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Bulbs or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Bulbs; (c) enforce the Bulbs Terms of Use or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Bulbs or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Bulbs, its users and/or the public.
  1. 3. As the purposes for which we may collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purposes may not appear within the list set out in Section G.1. However, we will notify you of such other purposes at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Data Privacy Laws.
  1. 1. We implement a variety of security measures and strive to ensure the security of your Personal Data on our systems. Users’ Personal Data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can be no guarantee of absolute security.
  1. 2. We will retain Personal Data in accordance with the Data Privacy Laws and other applicable laws. That is, we will destroy or anonymise your Personal Data when we have reasonably determined that:
  • (a) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data;
  • (b) retention is no longer necessary for any legal or business purposes; and
  • (c) no other legitimate interests warrant further retention of such Personal Data.

If you cease using the Platform and the Services, or your permission to use the Platform and the Services is terminated or withdrawn, we may continue storing, using and disclosing your Personal Data in accordance with this Privacy Policy and our obligations under the Data Privacy Laws. Subject to the Data Privacy Laws, we may securely dispose of your Personal Data without prior notice to you.

  1. 1. In conducting our business, we may need to disclose your Personal Data to third party service providers, agents, our affiliates or related corporations, and other third parties, whether sited in Singapore or outside of Singapore, for one or more of the Purposes. Such third party service providers, agents, affiliates or related corporations of ours, and other third parties would be processing your Personal Data either on our behalf or otherwise, for one or more of the Purposes. Such third parties include:
  • (a) our related corporations and affiliates;
  • (b) other Users of the Platform for one or more of the Purposes;
  • (c) contractors, agents, service providers and other third parties we use to support our business. These include those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centre providers;
  • (d) a buyer or other successor in the event of a merger, divestiture, amalgamation, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Bulbs’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by Bulbs about Users is among the assets transferred; or to a counterparty in a business asset transaction that Bulbs or any of its related corporations or affiliates is involved in; and
  • (e) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.
  1. 2. This may require, among other things, share statistical and demographic information about our Users and their use of the Services with suppliers of advertisements and programming.
  1. 3. For the avoidance of doubt, if Data Privacy Laws or other applicable laws permit us to collect, use or disclose your Personal Data without your consent, such permission granted by the laws shall continue to apply.
  1. 4. Third parties may unlawfully intercept or access Personal Data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your Personal Data as required by the Data Privacy Laws. However, there can inevitably be no guarantee of absolute security such as when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
  1. 5. If Bulbs allows you to share videos from YouTube in the Platform or through the Services (“YouTube Content“), which Bulbs uses YouTube API Services made available by YouTube to facilitate, you agree that in sharing such Youtube Content, you are bound by the Google Privacy Policy (http://www.google.com/policies/privacy).

The Services and the Platform are not intended for children under the age of 13. We do not knowingly collect or maintain any Personal Data or non-personally-identifiable information from anyone under the age of 13 nor is any part of the Platform or other Services directed to children under the age of 13. As a parent or legal guardian, please do not allow any children under your care who are under the age of 13 to submit Personal Data to Bulbs. If Personal Data of a child under the age of 13 in your care is disclosed to Bulbs, you hereby consent to the processing of the child’s Personal Data and accept and agree to be bound by this Privacy Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and delete any Personal Data we believe was submitted without parental consent by any child under the age of 13.

  1. 1. The Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States or other countries. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
  1. 2. We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by Bulbs. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
  1. 1. We do not guarantee the security of personal data or other information that you provide to or through third party sites. We do implement a variety of security measures to maintain the safety of your Personal Data that is in our possession or under our control. Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the Personal Data confidential. When you place orders or access your Personal Data, we offer the use of a secure server. All Personal Data you supply is encrypted into our databases to be only accessed as stated above.
  1. 2. In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through the Platform) may not be received by us.
  1. 3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of the Platform and the Services and the links placed upon each of them and therefore welcome any feedback about these linked sites (including if a specific link does not work).

Your Personal Data and information may be transferred to, stored or processed outside of your country. In most cases, your Personal Data will be processed in Singapore, where our servers are located and our central database is operated. Bulbs will only transfer your information overseas in accordance with Data Privacy Laws.

  1. 1. Withdrawing Consent
  • (a) You may withdraw your consent for the collection, use and disclosure of your Personal Data in our possession or under our control by sending an email to our Personal Data Protection Officer at account@bulbs.sg, and we will process such requests in accordance with this Privacy Policy and our obligations under the Data Privacy Laws. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate the contract between you and us, your Account and your access to and ability to use the Platform and the Services in accordance with the Terms of Use. 
  • (b) Where you share YouTube Content, in addition to withdrawing your consent by emailing us pursuant to Section 14.1.1, you may also revoke Bulbs’ access to your Personal Data via the Google security settings page at:


  1. 2. Requesting Access to or Correction of Personal Data
  • (a) If you have an account with us, you may personally access and correct your Personal Data currently in our possession or control through the Account Settings page on the Platform. If you do not have an account with us, you may request to access or correct your Personal Data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at account@bulbs.sg.
  • (b) We may charge you a reasonable fee for the handling and processing of your requests to access your Personal Data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
  • (c) We reserve the right to refuse to correct your Personal Data in accordance with the Data Privacy Laws, where they require or entitle an organisation to refuse to correct Personal Data in such circumstances as are stated in the relevant Data Privacy Laws.

If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at account@bulbs.sg.

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