Privacy Policy

Welcome to Kefi Meraki! We are pleased that you are visiting our website at www.kefi-meraki.com. Data protection and data security when using our website are very important to us. We would therefore like to inform you which of your personal data we collect when you visit our website and for what purposes it is used.

Background

This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain to you the following concepts.

a) What is Personal Data?
Personal Data is any includes information relating to an individual who can be identified or who is identifiable, directly from the information in question; or who can be indirectly identified from that information in combination with other information.

b) What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

c) What is Processing?
“Processing” means and covers virtually any handling of data.

What law applies

We will only use your Personal Data in accordance with the applicable data protection laws, in particular Singapore’s Personal Data Protection Act 2012 (“PDPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

Who is responsible

The person responsible in the sense of the PDPA and the GDPR is Kefi Meraki Consultant, 997B Buangkok Crescent, #09-863, Singapore 532997 (“Kefi Meraki”, “we”, “us”, or “our”). Please direct any questions you may have to connect@kefi-meraki.com.

Data collection

All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:

  • you have given your consent;
  • the data is necessary for the fulfilment of a contract / pre-contractual measures;
  • the data is necessary for the fulfilment of a legal obligation; or
  • the data is necessary to protect the legitimate interests of our company and business.
Data retention

We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with Singapore’s Commercial Law and Fiscal Code and others for up to 8 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

Data we collect automatically

a)  Provision and use of the website
When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.

b)  Hosting
The hosting services used by us for the purpose of operating our website is Hostinger International, Ltd. In doing so Hostinger processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.

c)  Content Management System
We use the Content Management System (CMS) of WordPress by Automattic Inc to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to our website are transferred to WordPress. The legal basis for this processing is our legitimate interest.

d)  Fonts
We use Google Fonts by Google LLC and Font Awesome of Fonticons Inc on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google/Fonticons server is established when our website is accessed. The connection to Google/Fonticons established when you call up our website enables Google/Fonticons to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.

e)  Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in Singapore’s Personal Data Protection Act 2012 (“PDPA”) and Spam Control Act 2007 (“SCA”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

f)  Cookie consent
Our website uses a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our The basis for processing is our legitimate interest and your consent.

g) Economic analyses and market research
For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.

Data we collect directly

a)  Contacting Us
We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.

b)  Using our services
We process the Personal Data involved in your use of our wellness consultancy services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e- mail addresses and telephone numbers) as well as contractual data (e.g., services used, contents of the contract, contractual communication, names of contact persons), certain Special Category Data.

As a matter of principle, we do not process Special Category Data, unless they are part of a commissioned or contractual processing. Accordingly, the data is processed on the basis of fulfilling our contractual obligations, our legal obligations, your consent and your specific consent in relation to Special Category Data.

c)  Administration
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

d)  Data management and customer support
For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data will be stored on our website and or our customer relationship management system provided by Hubspot. This data processing is based on our legitimate interest in providing our service.

e)  Testimonials
Within the Testimonial section, we may display certain Personal Data, share certain details, knowledge and insights. When you approve and submit your Testimonial to us your consent is obtained, and you have choices about the information in your Testimonial. The basis for processing is your consent.

f)  Surveys
We use the service of SurveyMonkey. Participation in a survey is via a link. Even if you participate in an anonymous survey, SurveyMonkey will collect information about the device the person uses to take the survey. This includes the IP address, the version of the operating system version, device type, device ID/MAC address, system and performance information, and browser type. and browser type. If a mobile device is used to participate in the survey, the UUID of that device is also the UUID of that device is also collected by SurveyMonkey. The legal basis for the use of SurveyMonkey is our legitimate interest in providing our service.

g)  Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.

h)  Newsletter
We use the services of Mailchimp by Intuit Inc to send our Newsletter and if you subscribe we will use your email address to send you information about products, promotions, news and customer satisfaction surveys. You can find an unsubscribe link at the end of each newsletter. The legal basis is your consent.

Data sharing

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

a)  Internal

If necessary, we transfer your Personal Data within Kefi Meraki. Of course, we comply with the PDPA and GDPR and ensure that your data is processed properly. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.

b)  External bodies

Personal Data is transferred to our service providers in the following instances:

  • in the context of fulfilling our contract with you,
  • to use marketing services and to advertise our services online,
  • to communicate with you,
  • to provide our website, and
  • to state authorities and institutions as far as this is required or

c)  International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

Data security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Social Media

a)  General
We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.


b)  Market research and advertising
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. You can find more information about our advertising on social media in our Cookie Policy. The legal basis is our legitimate interest.


c)  When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

Marketing

Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

Advertising

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following Personal Data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

Your rights and privileges

a)  Privacy rights

Under the PDPA and the GDPR, you can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;

b)  Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.

c)  Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

d)  Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Singapore is: The Personal Data Protection Commission (www.pdpc.gov.sg). However, we would appreciate the opportunity to address your concerns before you contact the Personal Data Protection Commission or any other supervisory authority.

e)  What we do not do

  • We do not request Personal Data from minors and children;
  • We do not process special category data without obtaining prior specific consent;
  • We do not use Automated decision-making including profiling; and
  • We do not sell your Personal
Validity and questions

This Privacy Policy was last updated on Saturday, 6th of April 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary.

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.