Privacy Policy

Data Protection Notice

This Data Protection Notice ("Notice") outlines how THEOS KYRIOS ("we," "us," or "our") may collect, use, disclose, or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA"). This Notice applies to personal data in our possession or under our control, including data held by organizations we have engaged to handle personal data on our behalf.

Personal Data

1. In this Notice:

- "Customer" refers to an individual who:

(a) has contacted us through any means to learn more about the goods or services we and our associate partners provide, or

(b) is in the process of, or has entered into, a contract with us/partners for the supply of goods or services provided by us/partners or for recommendations of our associate partners' products/goods/services.

- "Personal data" means any data, whether true or not, about a customer that can be identified:

(a) from that data alone; or

(b) in combination with other information we have or are likely to acquire.

2. Depending on how you interact with us, examples of personal data we may collect include:

- Your name and identification information, such as your NRIC number.

- Contact details, such as your address, email address, or telephone number.

- Demographic information, including nationality, gender, date of birth, and marital status.

- Photographs and other audio-visual materials.

- Employment and financial information, including credit card numbers, debit card numbers, or bank account details for investigation purposes.

3. The terms used in this Notice shall have the meanings ascribed to them in the PDPA where applicable.

4. We utilize SSL encryption. An SSL certificate is a digital certificate that authenticates a website's identity and enables an encrypted connection. SSL stands for Secure Sockets Layer, a security protocol that creates a secure link between a web server and a web browser. Companies and organizations implement SSL certificates on their websites to secure transactions and safeguard customer information. In short, SSL protects internet connections and prevents unauthorized access to information exchanged between two systems. A padlock icon next to the URL in the address bar indicates that SSL protects the website you are visiting.

Collection, Use of Personal Data, and Associate Partners Disclosure

5. We generally do not collect your personal data unless:

(a) It is provided voluntarily by you or through a duly authorized third party (your "authorized representative") after:

(i) you (or your authorized representative) have been informed of the purposes for which the data is collected, and

(ii) you (or your authorized representative) have given written consent for the collection and use of your personal data for those purposes.

(b) The collection and use of personal data without consent is permitted or required by the PDPA or other laws.

We will seek your consent before collecting any additional personal data or using your personal data for purposes not previously disclosed (except where permitted by law).

6. We and our associate partners may collect and use your personal data for the following purposes:

(a) Fulfilling obligations related to the goods and/or services you have requested.

(b) Verifying your identity.

(d) Managing your relationship with us.

(e) Safely processing payments via Bank Transfer, Paylah/PayNow. We will not request, require, or retain access to your credit card details.

(f) Sending marketing information about our goods or services, including notifications about marketing events, initiatives, promotions, lucky draws, membership and rewards schemes, and promotions/recommendations from our associate partners.

(g) Complying with applicable laws, regulations, and guidelines, or assisting in investigations conducted by governmental and/or regulatory authorities.

(h) Any other purposes for which you have provided the information.

(i) Transmitting data to unaffiliated third parties, including our third-party service providers and agents, as well as relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the purposes mentioned above.

(j) Engaging in any other incidental business activities related to or in connection with the above unless explicitly provided or submitted by you.

7. This website may accept cash advertising, sponsorship, or other forms of compensation from our associate partners. It may also utilize associate referral links, redirect traffic, and employ cookies. Occasionally, this website may offer free gifts, products, vouchers, promotions, or special offers to enhance user experience.

8. We may disclose your personal data in the following situations: (a) when such disclosure is necessary to fulfill our obligations related to the goods or services you have requested; or (b) to third-party service providers, agents, and other organizations that we have engaged to perform functions on our behalf, as described above.

9. The purposes listed in the previous clauses may continue to apply even if your relationship with us (such as in a contract) has been terminated or modified. This will be valid for a reasonable period thereafter, which may include a timeframe necessary for us to enforce our rights under any contract with you.

We and our associated partners use cookies to enhance your experience on our site and to deliver relevant advertising. This helps us learn about your interests, provide essential features, and serve various purposes, including:

(a) Recognizing you when you log into our site. This enables us to offer product recommendations, display personalized content, recognize you as a subscriber, facilitate one-click purchasing, and provide other customized features and services.

(b) Keeping track of your specified preferences.

(d) Conducting research and diagnostics to improve the products and services of our associate partners.

(e) Delivering content, including ads, tailored to your interests, needs, and convenience, on our associate sites and third-party websites.

(f) Reporting and data analysis, which allows us to measure, analyze, and improve the performance of our services and recommendations for our associate partners' products.

Associate Partners Disclaimer

Customers are encouraged to exercise due diligence by reviewing the terms and conditions on our partners' sites and promotions. All purchases made on our redirected associate partners' websites are subject to their respective terms and conditions. Any personal information or particulars submitted by you are provided voluntarily and with your consent.

Withdrawing Your Consent

10. The consent you provide for the collection, use, and disclosure of your personal data will remain valid until the cookie's expiration date (30 days) or until you withdraw it in writing. You may withdraw your consent and request us to cease using or disclosing your personal data for any or all purposes listed above by submitting your request in writing or via email to our Data Protection Officer using the contact details provided below.

11. Upon receiving your written request to withdraw your consent, we may require a reasonable amount of time to process your request, depending on its complexity and impact on our relationship with you. Generally, we aim to process your request within 14 business days.

12. While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may be unable to continue providing goods or services to you. In such cases, we will inform you before completing the processing of your request. If you decide to cancel your withdrawal of consent, please notify us in writing as described in clause.

13. It is important to note that withdrawing consent does not impact our right to continue collecting, using, and disclosing personal data where such actions are permitted or required under applicable law.

14. If you would like to make a request for access to a copy of the personal data we hold about you, or to learn how we use or disclose your personal data, you can submit your request in writing or via email to our Data Protection Officer using the contact details provided below.

15. Please note that a reasonable fee may be charged for an access request. If applicable, we will inform you of this fee before processing your request.

16. We will respond to your request as quickly as possible. If we cannot respond within thirty (30) days of receiving your request, we will notify you in writing within that same thirty (30) days, indicating when we expect to be able to respond. If we are unable to provide any personal data or make the corrections you requested, we will generally explain the reasons for this, except where we are not required to do so under the PDPA.

PROTECTION OF PERSONAL DATA

17. To protect your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented appropriate administrative, physical, and technical measures. These include up-to-date antivirus protection, encryption, and the use of privacy filters to secure all storage and transmission of personal data, both internally and when disclosing personal data to our authorized third-party service providers and agents on a need-to-know basis.

18. However, please be aware that no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your information and continuously enhance our security measures, complete security cannot be guaranteed.

ACCURACY OF PERSONAL DATA

19. We generally rely on the personal data you provide (or that your authorized representative provides). To ensure that your personal data is current, complete, and accurate, please inform us of any changes by contacting our Data Protection Officer in writing or via email using the contact details below.

RETENTION OF PERSONAL DATA

20. We may retain your personal data for as long as necessary to fulfill the purpose for which it was collected or as required or permitted by applicable laws.

21. We will cease to retain your personal data or remove any means of associating the data with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the data was collected and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

22. We typically do not transfer your personal data to jurisdictions outside of Singapore. However, should such a transfer become necessary, we shall obtain your express consent and implement measures to ensure that your personal data continues to receive a level of protection that is at least comparable to that provided under the Personal Data Protection Act (PDPA).

DATA PROTECTION OFFICER

23. Should you have any inquiries or feedback regarding our personal data protection policies and procedures, or if you wish to submit any requests, please reach out to us via the [CONTACT US] page.

COMMITMENT TO RESPECTFUL INTERACTIONS

24. Our dedicated staff members are committed to fulfilling your orders, ensuring your orders are met with efficiency, and that you receive the best possible attention at all times.

It is imperative that all personnel treat our patrons with dignity and respect. We expect reciprocal respect between our staff and patrons. To foster constructive relationships, we kindly request that patrons remain mindful of the following unacceptable behaviors:

(a) Rude, persistent, or unrealistic demands that create undue stress for our staff.

(b) The use of inappropriate language, including profanity, shouting, or swearing, directed at staff.

(c) Any form of verbal abuse, including insults or comments that are racist or sexist, and may cause emotional or psychological harm.

(d) Physical aggression, such as pushing or shoving, which may result in injury, harm, damage, or fatality.

(e) This policy encompasses all forms of interaction with staff, whether conducted in person, by telephone, through written correspondence, via email, or through our website and associated social media platforms.

(f) Our Zero Tolerance Policy permits THEOS KYRIOS management to decline service, impose bans, prohibit individuals’ access, discontinue services, initiate legal action, or file police reports against anyone exhibiting disrespectful behavior.

ZERO TOLERANCE POLICY

25. THEOS KYRIOS management regards all incidents of aggressive, violent, or abusive conduct directed towards our staff with the utmost seriousness. We maintain a Dignity at Work and Zero Tolerance Policy, affirming that our employees possess the inherent right to a safe and respectful work environment. In our interactions with you, we endeavor to ensure that you are treated with courtesy and respect.

NOTICE EFFECTIVENESS AND AMENDMENTS

26. This Notice operates in conjunction with any other notices, contractual clauses, and consent provisions pertinent to the management of our site and the collection, use, and disclosure of your personal data by us.

27. We reserve the right to revise this Notice periodically without prior notification. You may verify updates by referring to the date when this Notice was last amended. Your continued use of our services indicates your acknowledgment and acceptance of any modifications made. THEOS KYRIOS reserves the authority to manage our site and amend any of the aforementioned policies without prior notification.

For additional questions and inquiries, please contact us through the [CONTACT US] page.

Effective Date: [01/01/2020]

Last Updated: [26/11/2025]