Livspace Pte Ltd and its affiliates, sister companies, and subsidiaries (collectively, “Livspace”, “we”, “our” or “us”) are engaged inter alia in the business of interior design and décor services, more fully described in our Terms and Conditions, available at www.livspace.com/my/service/service-payment-policy-my and any other policies we may make available on the Platform from time to time (collectively, “Terms”). This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have chosen to share with us when you access, use, or otherwise interact with our website available at www.livspace.com or mobile application Livspace Hub (collectively, “Platform”), avail products or services that Livspace offers you on or though the Platform, or partner with us to provide customers with these services (collectively, the “Services”).
At Livspace, we are committed to respecting your privacy and protecting your personal data. In order to provide you with access to the Services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you.
By interacting with us, submitting information to us, and using the Services, you confirm that you have read this Policy and consent to the collection, use, disclosure, and retention of your personal information in accordance with the processing activities described under this Policy In certain circumstances you may provide us with the personal data of other individuals such as your spouse, relatives, or friends. You represent and warrant that you have obtained such individuals’ informed consent for their personal data to be collected, used, or disclosed in accordance with this Policy. If you are a parent or legal guardian, please do not permit the minor(s) under your care to submit personal data to us, and in the event you provide us with a minor’s personal data, you consent to the collection, use, or disclosure of the minor’s personal data in accordance with this Policy. Your information may be used in other ways for which specific notice will be provided at the time of collection.
This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/or retention of your personal data.
Please refer to Section 1 to understand how the terms of this Policy apply to you.
(a) About Us:
The Services are made available to you by Livspace. If you have any questions about this Policy, how we process or handle your personal data, or otherwise, you may reach out to us with your queries, grievances, feedback, and comments at firstname.lastname@example.org or contact our personal data protection officer whose details are provided below.
Name: Michelle Lee
Designation: HR and Office Administrator/ Data Protection Officer
Contact Number: +603 8685 5521
(b) How this Policy applies:
This Policy applies to natural and legal persons and individuals who are competent to contract and who access or use our website, mobile applications, or products or services made available by us or prospective customers of our products and services (hereafter, “Users”) and service providers who use the Platform to provide their services to Users (“Service Providers”). For the avoidance of doubt, references to “you” across this Policy are to Users and Service Providers.
By using the Services, you consent to the collection, storage, usage, and disclosure of your personal data, as described in and collected by us in accordance with this Policy.
(c) Third-Party Links:
Personal data means any information in respect of commercial transactions which (A) is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose; (B) is recorded with the intention that it should be wholly or partly processed by means of such equipment; or (C) is recorded as a part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to an individual who is identified or identifiable from that information and from that or other information in our possession.
(a) When you use the Services as a User, we collect different types of personal data about you. This includes but is not limited to:
(i) Contact Data, such as your mailing or home address, zip code, location, email addresses, and mobile numbers.
(ii) Identity and Profile Data, such as your name, government issued identifiers, passport or other identification number, telephone numbers, username or similar identifiers, photographs, details about your family members, their age and profession, credit information, gender, language, interests, and hobbies.
(iii) Property and Home Data, such as the name of your property, type of property, size of property, preferred furniture and colour schemes for your home, details about the rooms in your home, the number of homes you own, and whether your home is owned or rented by you.
(iv) Marketing and Communications Data, such as your address, email address, information posted in service requests, offers, wants, feedback, comments, quizzes, pictures and discussions in our blog and chat boxes, responses to user surveys and polls, your preferences in receiving marketing communications from us and our third parties, preferred service or products and your communication preferences. We also collect your chat and call records when you communicate with Service Providers through the Platform.
(v) Technical Data, which includes your IP address, browser type, internet service provider, details of operating system, registered domain or home server, access time, page views, device ID, device type, frequency of visiting our website and use of the Platform, website and mobile application activity, clicks, date and time stamps, location data, search terms, search results, access times and referring website’s address(es), and other technology on the devices that you use to access the Platform.
(vi) Transaction Data, such as details of the Services you have availed, your credit or debit card details for tracking transactions that are provided to us by payment processors, banking details, and UPI IDs for processing payments.
(vii) Usage Data, which includes information about how you use the Services, your activity on the Platform, booking history, user taps and clicks, user interests, time spent on the Platform, details about user journey on the mobile application, and page views.
(b) When you use the Services as Service Provider, we collect different types of personal data about you. This includes but is not limited to:
(i) Contact Data, such as email addresses, phone numbers, and permanent address.
(ii) Identity and Profile-related Data, such as your name, mobile number, gender, date of birth, age, address, zip code, description of services provided, content and information about your business including photographs and videos, work experience, credit or debit card details, government-issued identifiers, verification reports, credit information, cancelled cheque, GST details, tax residency certificate, information from testimonials, polls, surveys, and feedbacks.
(iii) Technical Data, which includes your IP address, internet service provider, device ID, device type, domain name, details of operating system, browser type, date and time stamp of accessing the Platform, device metadata, location data, and mobile applications used by you.
(iv) Marketing and Communications Data, such as feedback, comments, quizzes, pictures and discussions in our blog and chat boxes, responses to user surveys and polls, your preferences in receiving marketing communications from us and our third parties, and your communication preferences. We also collect your chat and call records when you communicate with Users through the Platform.
(v) Usage Data, which includes call logs, mobile application usage and activity data, call and chat records with customers and end-users, and email usage.
(c) We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
(d) What happens if I refuse to provide my personal data?
Where we need to collect personal data by law, or under the terms of a contract (such as the Terms), and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with the Services). In this case, we may have to cancel or limit your access to the Services, but we will, where reasonably practical, notify you if this is the case at the time.
(e) Personal Data from Minors and Children:
We understand the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 18. It is our policy never to knowingly collect or maintain information about anyone under the age of 18, except as otherwise required by law.
To the extent that you have provided (or will provide) personal data about your family, spouse and/or other dependents, you confirm that you have explained to them that their personal data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Policy and, in respect of minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, you confirm that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their personal data in accordance with this Policy.
Children under the age of 18 years should not submit their personal data via the Platform. If you believe that your child has submitted personal information and you would like to request that their information be removed from our systems, please submit a request to the Personal Data Protection Officer in the manner described in Section 1(a) to this Policy and reasonable efforts will be made to comply with your request within 30 (Thirty) days of the request.
We use different methods to collect personal data from and about you including through:
(a) Direct Interactions. You provide us your personal data when you interact with us. This includes personal data you provide when you, for example:
(i) create an account or profile with us at the time of registration on our Platform, kiosks, physical showrooms, or through our channels on third party social media platforms (including but not limited to Facebook, Instagram, and YouTube);
(ii) submit an enquiry or a quote request with us;
(iii) use the Platform or the Services;
(iv) interact with us during physical or digital promotion, competitions, contests, lucky draws, special events, user poll, or surveys or other types of research, or by using devices within our showrooms;
(v) request that we contact you and/or interact with our customer servicing team via our communication channels such as a phone call;
(vi) facilitate payments through the Platform;
(vii) complete purchase orders, requests, or applications for our products or services (by phone, in person, snail mail, or electronically);
(viii) subscribe to any of our membership programmes, i.e. opting for email notifications and/or newsletters or request marketing communications to be sent to you;
(ix) sign up or redeem a promotional offer or initiatives;
(x) communicate with us directly via our customer service centre, or directly via our co-workers within our stores in relation to our products and services (in person, by email, telephone, direct mail or any other means);
(xi) interact with our promotional advertisements or social media posts, whether inadvertently or otherwise through any third party platforms;
(xii) subscribe to our membership programmes;
(xiii) report a problem with the Platform and/or our Services, give us feedback, contact us, or provide testimonials;
(xiv) perform an online transaction;
(xv) respond to our request for additional personal data;
(xvi) submit your personal data to us for any other reason.
(xvii) provide us with camera permissions that allows you to upload any picture straight from the camera; or
(xviii) provide us with access to your photo gallery that allows you to upload any picture from your photo gallery.
(b) Automated technologies or interactions. We automatically collect Technical Data about your operating system, equipment, browsing actions, and patterns each time you use the Platform. We collect this personal data by using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites that employ our cookies. We may also collect information about your usage and browsing habits using various web-based technologies.
(c) Third parties or publicly available sources. We will receive personal data about you from various third parties, including, without limitation:
(i) Technical Data from analytics providers such as Facebook, Pinterest, Google Analytics, Google and advertising networks;
(ii) Our business partners through which you create or access the Platform, such as payment providers, social media services, or applications or websites who use our APIs or whose API we use;
(iii) Background verifiers;
(iv) Credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of our products and/or services, performance of conditions of agreements and/or to comply with our legal and regulatory obligations;
(v) From referrals by any user who thinks you may be interested in Livspace or the Services. It is the referrer’s obligation to seek authorisation to share your personal information as a referral. When an individual shares your personal information with us, it is deemed that you have consented to such sharing;
(vi) Identity and profile-related data from publicly available sources; and
(vii) Marketing service providers.
(a) We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data where we need to provide the Services, or where we need to comply with a legal obligation. We use your personal data for the following purposes:
(i) to communicate with you;
(ii) to maintain and improve customer relationship;
(iii) to administer and process any payments related to products, services and/or facilities requested by you;
(iv) to establish your identity and background;
(v) to verify your identity, and create your user account with us on the Platform at the time of registration and to manage your account, including access to your purchase history;
(vi) to provide the Services to you including processing your order and providing you with end-to-end interior design and execution services, and to administer or otherwise carry out obligations to you;
(vii) if you are a Service Provider, to assess the performance of your services rendered to Users;
(viii) to monitor your activities on the Platform;
(ix) to monitor trends and personalise your experience;
(x) to improve the functionality of our Services based on the information and feedback we receive from you;
(xi) to conduct internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
(xii) for product development and testing;
(xiii) to improve customer service to effectively respond to Users’ Service requests, grievances, and support needs;
(xiv) to develop new product features, analyse our products, and also facilitate financial solutions and insurance that our connected to our Services;
(xv) to track transactions and process payments;
(xvi) to send periodic notifications to manage our relationship with you including to notify you of changes to our Services, to inform you of changes and developments to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the products and services offered to you, and to send other occasional company news and updates related to us or the Services;
(xvii) to assist with the management of the Services offered to you, including to send you information and updates about the Services you have availed, communicate with you about and administer your participation in special events, including contests, sweepstakes, programs, surveys, promotions, campaigns, product launches, and other offers, and operate and communicate with you about our social network pages or mobile applications;
(xviii) to tailor ads displayed to you on the Platform and on third- party websites to your interests and history;
(xix) to conduct credit reference checks and establish your creditworthiness, where necessary, in providing you with the products, services and/or facilities;
(xx) to administer and protect our business and the Platform, including for troubleshooting, data analysis, system testing, and performing accounting, auditing and other internal operations;
(xxi) to improve our business and delivery models;
(xxii) to perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
(xxiii) to enforce our Terms;
(xxiv) to market our Services to you, via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels to members of our loyalty programmes e.g. referrals, website membership, consented social media affiliations in accordance with their consent;
(xxv) to transfer information about you if acquired by or merged with another company or otherwise required to be transferred to another entity for the purposes of providing you with the Services;
(xxvi) to comply with our legal obligations;
(xxvii) to maintain and update internal record keeping;
(xxviii) for internal administrative purposes;
(xxix) to send you seasonal greetings messages from time to time;
(xxx) to share any of your personal data with the auditor for our internal audit and reporting purposes;
(xxxi) to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
(xxxii) to share any of your personal data with our joint venture/business partners to jointly develop products and/or services or launch marketing campaigns;
(xxxiii) to share any of your personal data with insurance companies necessary for the purpose of applying and obtaining insurance policy(ies), if necessary;
(xxxiv) to share any of your personal data with financial institutions necessary for the purpose of applying and obtaining credit facility(ies), if necessary;
(xxxv) for audit, risk management and security purposes;
(xxxvi) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(xxxvii) to transfer or assign our rights, interests and obligations under any agreements entered into with us;
(xxxviii) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
(xxxix) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
(xl) to respond to subpoenas, court orders, establish or exercise our legal rights, or defend ourselves against legal claims (for example the police, fraud investigation organisations, insurers, solicitors, auditors and financial advisors); and
(xli) to investigate, prevent, or take action regarding illegal activities, suspected fraud, violation of the Terms, or as otherwise required by law;
(xlii) to ensure Platform security;
(xliii) storing, hosting, backing up (whether for disaster recovery or otherwise) whether within or outside Malaysia; and
(xliv) to verify compliance with the terms and conditions governing the use of our website including monitoring private messages sent through our website private messaging service.
(b) You agree and acknowledge that by using our Services or accessing the Platform, you authorise us, our associate partners, affiliates, and end-users, customers, and partners to contact you via email, phone, or otherwise. This is to enable us to provide the Services, provide you with marketing material, and ensure that you are aware of all the features of the Services.
(c) You agree and acknowledge that any and all information pertaining to you, whether or not you directly provide it to us (via the Services or otherwise), including but not limited to personal correspondence such as emails, instructions from you, etc., may be collected, compiled, and shared by us in order to render the Services to you. This may include but not be limited to vendors, social media companies, third-party service providers, storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with other entities in the Livspace group within Malaysia and across borders worldwide in connection with the above-mentioned purposes. Those countries may not have the same data protection laws as your country of residence and your personal data may be subject to applicable foreign laws.
(d) You agree and acknowledge that we may share data without your consent, when it is required by law or by any court or government agency or authority to disclose such information, or if disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.
(e) You agree and acknowledge that for certain purposes such as detecting or preventing illegal activities, preventing the misuse of the Services, carrying out corporate due diligence, improving, enhancing, or developing new goods and services, learning or understanding consumer behaviour or preferences, we may collect, use, or process your personal data without consent, on the grounds of our legitimate interests, or business improvement, as applicable.
(f) We may use your personal data to market Livspace’s Services, events, offers, and promotions to you, including through telephone calls and messages, push notifications, or emails. In the event you wish to unsubscribe to the processing of your personal data for such marketing and promotion, you may click on the unsubscribe facility provided in such marketing or promotional messages.
(a) We may share your personal data with third parties set out below for the purposes set out in Section 4:
(i) Internal third parties, which are other companies within the Livspace group of companies.
(ii) External third parties such as:
(b) We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
You possess certain rights in relation to your personal data in our possession or control. We exercise reasonable due diligence and adopt measures to verify your identity prior to processing your request to exercise your rights, and you may be required to provide supporting documentation or information to corroborate your request, within the timelines prescribed by applicable laws.
(a) Accessing and Updating your Personal Data: You hereby warrant that all personal data that you provide us with is accurate, up-to-date, and true. When you use our Services, we provide you with the ability to access (including obtaining a copy thereof) and correct inaccurate or deficient data, subject to any legal requirements, for instance we may refuse to give effect to your access request if (i) we are not supplied with the information we reasonably require to satisfy ourselves as to your identity; (ii) we are not supplied with such information as we may reasonably require to locate the personal data to which your access request relates; (iii) the burden or expense of providing access is disproportionate to the risks to your privacy in relation to the personal data in question; (iv) we cannot comply with your data access request without disclosing personal data relating to another individual, unless the other individual has consented to such disclosure or it is reasonable to comply with your request without the consent of the other individual; (v) another entity controls the processing of your personal data in a manner that prohibits us from complying with your access request; (vi) providing access would constitute a violation of a court order; (vii) providing access would constitute confidential commercial information; or (viii) such access to personal data is regulated by laws other than Malaysian data protection laws of general application. Additionally, we may refuse to give effect to your correction request if (i) we are not supplied with the information we reasonably require to satisfy ourselves as to your identity; (ii) we are not supplied with such information as we may reasonably require to ascertain in what way the personal data to which your data correction request relates is inaccurate, incomplete, misleading, or not up-to-date; (iii) we are not satisfied that the correction which is the subject of the data correction request is accurate, complete, not misleading, or up-to-date; (iv) some other entity controls the processing of your personal data to which the data correction request relates in such a way so as to prohibit us from complying with your data correction request, or (v) any other instance as permitted under applicable laws. If we are unable to provide you with any personal data or to update it as requested by you, we shall generally inform you of the reasons why we are unable to do so (to the extent permissible under applicable laws).
(b) Withdrawing Consent to the Processing of your Personal Data: We provide you with the ability to withdraw your consent to the further processing of your personal data, where the ground on which we process such personal data is consent. If you choose to exercise this right we will be unable to provide you with the access or use of all or any part of the Services.
(c) Preventing Processing likely to cause Damage or Distress: If you believe that our processing of your personal data is causing or is likely to cause substantial damage or distress to you or any other person, and that such damage or distress is unwarranted, you may request us to cease or not begin such processing.
(d) Preventing Processing for Purposes of Direct Marketing: You may require us to cease or not to begin processing of your personal data for purposes of direct marketing. When we send you marketing and promotional content through email, we provide you with the ability to opt-out of such communications by using the opt-out instructions provided in such emails.
(a) We comply with applicable laws in respect of storage and transfers of personal data. As a part of your use of the Services, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in, in accordance with the procedure prescribed under applicable laws. This may happen if any of our servers are from time to time located in a country other than the one you are based, or one of our service providers is located in a country other than one you are based in.
(b) By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.
We implement appropriate security measures to protect your personal data from unauthorised access, and follow standards prescribed by applicable law. We implement privacy protective features such as encryption, password protection and role based access control. However, no security system is perfect, and it cannot be promised that information about you will remain secure in all circumstances, including the security of your data during transmission or the security of data on your device. There is always a risk that a third party, without authorisation, might unlawfully access the systems or otherwise access personal information. We are also not responsible for the authenticity of any information which is provided by you or otherwise collected from your use of the Services, whether personal or otherwise.
It is important that you also play a role in keeping your personal data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls we provide you in our Platform.
Please further note that identity theft and the practice known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
(a) You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) and for a reasonable period after the termination of your account on the Platform or access to the Services to comply with our legal rights and obligations.
(b) In some circumstances, we may aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You are aware that in the event we go through or propose to go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, reorganisation or in the event of bankruptcy, your personal data might be among the assets transferred or sold or otherwise shared. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
(a) We regularly review and may occasionally update our Policy. If we make changes to this Policy, we will notify you of the changes through the Platform or through other means, such as email. We encourage you to periodically review this Policy for the latest information on our privacy practices. If you do not agree with our processing activities as described in this Policy, please do not access or use the Services.
(b) It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
(c) To the extent permitted under applicable law, by accessing our Platform or Services after such notice, you consent to updates made to this Policy.