PRIVACY POLICY
(For Singapore)

1.About this Policy
1.1 This Privacy Policy explains how ANTWAY SINGAPORE PTE. LTD. (collectively, “Antway”, “we”, “us”, or “our”) collect, use, disclose, transfer, and safeguard personal data in Singapore.
1.2 We comply with the Singapore Personal Data Protection Act 2012 and its regulations, including mandatory data breach notification and the PDPC’s Advisory Guidelines.
1.3 This Policy applies to: (a) our landing pages (LP) used to confirm prospective users’ intent to use our services; and (b) our e‑commerce websites, mobile apps, official accounts (including messaging platforms), and any related online/offline services (collectively, the “Services”).


2.Definition of Personal Data
“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 we have or are likely to have access. This includes, for example: name, date of birth, address, postal code, phone number, email address, payment information (e.g., credit card token or masked card data via our payment provider), government-issued identifiers where permitted and necessary (e.g., for identity verification), account identifiers (e.g., messaging app IDs), and online identifiers (e.g., cookies, device IDs, IP addresses).


3.What We Collect

Depending on how you interact with us (LP or e‑commerce), we may collect:
3.1 Identity and contact data: name, email address, phone number, postal address;
3.2 Account and profile data: account credentials, preferences, dietary preferences or restrictions you choose to provide, order history;
3.3 Transaction and payment data: payment method, masked card details or tokens (processed by our payment processors), billing and delivery information;
3.4 Communications and support data: content of inquiries, feedback, survey responses, customer support records (including logs of issues and resolutions);
3.5 Marketing and analytics data: cookie identifiers, device and usage information, browsing history on our Services, referral sources, interaction with emails and ads;
3.6 Demographic and lifestyle data (if you choose to provide it, e.g., family composition, occupation, income range in surveys); and
3.7 Data from partners: transaction or interaction records received from our advertising, analytics, logistics, or payment partners where permitted by law and subject to your consents.


4.How We Collect Data
4.1 Directly from you: when you submit forms on our LP, register an account, place orders, contact support, participate in surveys or campaigns, or opt‑in to marketing.
4.2 Automatically: via cookies, SDKs, pixels, and similar technologies when you use our Services.
4.3 From third parties: payment processors, analytics and advertising networks, logistics partners, and other service providers or partners, in accordance with applicable law and your consents.


5.Purposes of Collection, Use, and Disclosure

We collect, use, and/or disclose personal data for the following purposes (and will not use personal data in a way that is likely to encourage or induce illegal or unfair acts):

5.1 Service Provision and Operations
5.1.1 To create and manage accounts; provide, operate, and improve the Services; process and deliver orders; provide notifications about delivery, service changes, or security updates;
5.1.2 To provide customer support, handle inquiries and complaints, perform identity verification where needed;
5.1.3 To process payments and prevent fraud, chargebacks, and misuse; and
5.1.4 To send service-related messages (e.g., order confirmations, shipping updates, maintenance notices).
5.2 Marketing, Personalisation, and Analytics
5.2.1 To send you information on new features, updates, promotions, and campaigns (where permitted by law and subject to your consent, where required);
5.2.2 To conduct surveys, interviews, and market research; to send rewards or gifts related to campaigns;
5.2.3 To personalize content, recommendations, and offers based on your preferences and usage; and
5.2.4 To measure and analyze usage, service performance, marketing effectiveness, and audience insights.
5.3 Product Development and Improvement
5.3.1 To improve our Services’ functionality, quality, and user experience; and
5.3.2 To plan, research, and develop new products or services.
5.4 Legal, Compliance, and Business Purposes
5.4.1 To enforce our terms and policies; prevent, detect, and investigate fraud, abuse, or security incidents;
5.4.2 To comply with laws, regulations, court orders, and lawful requests by public authorities; and
5.4.3 For corporate transactions (e.g., mergers, acquisitions, business transfers) and associated due diligence, subject to confidentiality and legal requirements.

We will notify you of any additional purposes at or before collection and obtain consent where required. If we intend to use data for a different purpose reasonably related to the original purpose, we will provide further notification and obtain consent when required by the PDPA.


6.Legal Basis and Consent
6.1 We collect, use, and disclose personal data with your consent, and/or where permitted or required by the PDPA without consent (e.g., to respond to an emergency, for investigations or legal proceedings, or where business improvement exceptions apply under Singapore law).
6.2 By providing your personal data to us, using our Services, or indicating your consent (e.g., ticking a box), you consent to our collection, use, and disclosure of your personal data for the stated purposes.
6.3 You may withdraw your consent at any time (see Section 14). If you withdraw consent for essential purposes, we may be unable to provide or continue providing certain Services.


7.Cookies and Similar Technologies
7.1 We use cookies, pixels, SDKs, and similar technologies to: enable core site functionality; remember preferences; analyze site traffic and performance; customize content; and deliver/measure advertising.
7.2 You can manage cookies via your browser or device settings. If you block certain cookies, some features may not function properly.
Disclosure to Third Parties

8.We may disclose personal data to:
8.1 Service providers and data intermediaries: payment processors, cloud hosting, analytics providers, advertising networks, email/SMS providers, customer support tools, logistics partners, and other vendors engaged to perform services on our behalf under appropriate contractual safeguards.
8.2 Business partners: where you have consented or where permitted by law, for co‑marketing, promotions, or integrated services.
8.3 Professional advisors: auditors, lawyers, and consultants for compliance and risk management.
8.4 Corporate transactions: in connection with mergers, acquisitions, business transfers, or reorganisation, subject to confidentiality obligations and applicable law.
8.5 Authorities and legal requests: to comply with applicable laws, regulations, legal processes, or governmental requests. We do not sell personal data.


9.Cross‑Border Data Transfers
9.1 We may transfer and store personal data outside Singapore (e.g., in Japan or other jurisdictions where our or our vendors’ servers are located). We will ensure such transfers comply with the PDPA’s Transfer Limitation Obligation by implementing legally required protections, such as ensuring recipients are bound by legally enforceable obligations to provide a standard of protection comparable to the PDPA (e.g., contractual clauses).
9.2 By using our Services, you acknowledge such cross‑border transfers.


10.Accuracy
10.1 We make reasonable efforts to ensure that personal data we collect is accurate and complete if it is likely to be used to make a decision that affects you, or is to be disclosed to another organisation.
10.2 You should update your account information and notify us of changes to keep your data accurate.


11.Protection and Security
11.1 We implement reasonable security arrangements to protect personal data in our possession or under our control from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. Measures include access controls, encryption in transit and at rest where appropriate, and secure development and operational practices.
11.2 No method of transmission or storage is completely secure; we cannot guarantee absolute security.


12.Retention
12.1 We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by law. We will securely delete, anonymise, or otherwise cease to retain personal data when retention is no longer necessary.
12.2 Illustratively, order and transaction data may be retained for the duration of the contractual relationship and thereafter for a period necessary for tax, accounting, legal, and compliance obligations.


13.Access and Correction Requests
13.1 You may request access to your personal data in our possession or control, and information about how it has been used or disclosed in the past 12 months, and you may request correction if you believe it is inaccurate or incomplete.
13.2 We may charge a reasonable administrative fee for access requests, and will inform you of the fee before processing, as permitted by the PDPA.
13.3 We will respond to access/correction requests as soon as reasonably possible in accordance with the PDPA. We may refuse access to certain records where permitted by law (e.g., where it would unreasonably reveal personal data about another individual).


14.Withdrawal of Consent
14.1 You may withdraw your consent for our collection, use, and/or disclosure of your personal data at any time by contacting our Data Protection Officer (DPO). We will process your request within a reasonable time and inform you of the likely consequences of your withdrawal.
14.2 For marketing emails/SMS, you may use the “unsubscribe” or opt‑out mechanism in the message. We will honor such requests in accordance with the PDPA and the Singapore Spam Control Act.


15,Data Breach Notification
Where we assess that a data breach has occurred and it is notifiable under the PDPA (i.e., likely to result in significant harm to affected individuals or affects the prescribed minimum number of individuals), we will notify the Personal Data Protection Commission (PDPC) and affected individuals in accordance with legal requirements.


16.Children’s Data
Our Services are not directed to children under 13. We do not knowingly collect personal data from children under 13 without verifiable parental consent. If you are a parent/guardian and believe your child has provided personal data to us without consent, please contact our DPO to arrange deletion.


17.Third‑Party Sites and Services
Our Services may contain links to or integrations with third‑party websites, apps, or services. We are not responsible for the privacy practices of such third parties. Please review their privacy policies.
Specific Notices for the LP

18.For the LP used to confirm prospective customer interest:
18.1 Data collected: at minimum, name, email address, phone number; optionally, area of residence and product/service interest, preferred contact channel, and any other information you choose to submit.
18.2 Purposes: to contact you about product availability and launches, confirm your interest, invite you to trials or surveys, send pre‑launch updates and marketing (with your consent), and analyze interest for service planning.
18.3 Retention: we will retain LP data for as long as needed for pre‑launch engagement and, if you later register for the e‑commerce Services, we may transfer the data into your account profile. If you do not proceed to register and request deletion, we will delete or anonymise your data, subject to legal requirements.
Specific Notices for the E‑Commerce Site

19.For the full e‑commerce Services:
19.1 Additional data: delivery addresses, order and transaction history, payment tokens, delivery notes, and dietary preferences you choose to provide.
19.2 Purposes: order processing and delivery, customer support, fraud prevention, service maintenance, account management, analytics, personalization, marketing (with your consent), and legal compliance.
19.3 Delivery and logistics: we share necessary delivery details with logistics partners to fulfill your orders.
19.4 Allergens: While we take care in handling food products, we cannot guarantee a product is free from all allergens. If you have allergies, consult a medical professional before using our products and review product information carefully.


20.Advertising and Analytics
20.1 We may work with advertising partners to deliver or measure ads and with analytics providers to understand usage. This may involve the use of cookies, SDKs, and identifiers to measure performance, prevent fraud, and provide interest‑based advertising, where permitted by law and subject to your consent where required.
20.2 You can opt out of marketing cookies or interest‑based advertising via your browser/device settings or using provided consent tools where available.


21.Data Intermediaries and Contracts
Where we engage data intermediaries (processors), we enter into contracts requiring them to protect personal data in a manner comparable to the PDPA, process it only for our documented purposes, and implement appropriate security measures.


22.Updates to this Policy
We may update this Policy from time to time. We will post the updated Policy with the effective date on our website/app and, where material changes are made, we will notify you by reasonable means. Where required by law, we will obtain your consent to material changes.


23.Contact: Data Protection Officer (DPO)
If you have questions, requests (access, correction, withdrawal), or complaints regarding your personal data, please contact our DPO:
Data Protection Officer, ANTWAY SINGAPORE PTE. LTD.
Email:contact.sg@antway.co.jp
Postal Address: 10, Anson Road, #14-06, International Plaza, Singapore 079903

We will investigate and respond within a reasonable period. If you are not satisfied with our response, you may contact the Personal Data Protection Commission (PDPC) in Singapore.

24.Governing Law
This Policy is governed by Singapore law. Nothing in this Policy limits your rights under the PDPA.
Effective Date: 2025/12/15