At The Ice Bath Club (“TIBC”), we are committed to maintain the security and confidentiality of the personal information held by us. This Privacy Policy (“Policy”) describes how we (TIBC Group Pte. Limited, as the data controller or data user) look after the personal information about you that we obtain or you provide us with when you use the TIBC Website (www.theicebathclubs.com, the “Website”) and the TIBC Mobile Application (the “App”) when you sign-up for our products and services.

I. Your Privacy

We will take reasonable care to ensure that your personal information is accurate, complete, up-to-date and stored in a secure environment, protected from unauthorised or accidental access, use, processing, erasure, modification, loss or disclosure.

II. Personal Information

“Personal information” refers to information obtained by us in the course of our dealings with you that enables us to identify you directly or indirectly.

Such personal information includes your use of our products and services, personal particulars such as name, mailing addresses, phone number, email addresses, service details, payment details and credit history. Through “cookies”, it might also include how you use our Website to help us develop and improve our website, including details of your domain name and Internet Protocol (IP) address, operating system, browser version, cookie details, how long you stayed on a page, the route you took to navigate through the pages and the website that you visited prior to accessing our site.

We collect your personal information from you, from third parties such as credit reporting agencies and from our own systems.

The provision of your personal information is voluntary. However, if you do not provide certain types of personal information to us, we may not be able to provide you with some of our products and services.

III. How we use Your Personal Information

Collecting personal information helps us better understand what you need from us. We may collect personal information either directly from you or your authorised representatives, from third parties or through our Website, mobile and web applications, services application forms and other methods such as surveys.

We may collect and use your personal information to:

verify your identity;

plan, provision and bill for products and services;

provide access to, personalise your experience on, and improve the functionality of our TIBC Website and TIBC App;

manage your relationship with customer care related activities and technical assistance through remote access;

subject to receiving your consent (to use) [and written consent (to transfer)] your personal information (name and contact details) where required by law, conduct direct marketing by notifying you with details of products, services, special offers and rewards that we think will be of interest to you, namely [insert classes of marketing subjects to which the direct marketing will relate – must be specific and not generic / no references to “and other products and services”], [and we may transfer your personal information to our group companies and business partners to conduct direct marketing in relation to the same categories of goods and services];

carry out market and product analysis to improve our products and services and the marketing of our products and services;

gather feedback and statistics to improve our network, servers, Website and App;

improve your user experience through profiling and analysing your preferences;

manage bad debt and prevent fraud or illegal activities;

carry out activities connected with running of our business (such as personnel training, quality control, dispute resolution, and network monitoring) and in connection with the transfer of any part of our business in respect of which you are a customer or potential customer;

investigate any action that may threaten network security or integrity;

comply with any applicable law, regulations, guidelines or rules or to render assistance to law enforcement, governmental and regulatory agencies;

provide complementary products or services, or rewards to you from our business partners; and

other related purposes.

The Ice Bath Club will not use your personal information for any purpose not permitted by law or beyond the stated purpose you have consented to or that we are permitted by law to use it for.

The Ice Bath Club Website may contain links to other sites. We are not responsible for the privacy practices or the content of such Websites.

IV. Whom we can give Your Personal Information to

From time to time, we use other third parties to perform obligations related to the provision our products or services. Those entities may include:

companies related to us;

our business partners, marketing partners and authorised service providers;

credit providers or credit reporting agencies; and

law enforcement, governmental and regulatory agencies

We are required to disclose your personal information to the parties described above so that they may carry out their obligations to us, and to you. Our disclosure of your Personal information may, at times, be subject to their privacy policies. To every extent possible, we require these parties to act consistently with the personal information protections we have put in place.

V. Your Rights - How You can access, correct and update Your Personal Information

You can access, correct or update your listed customer details by logging in to your The Ice Bath Club account on the Website or App.

If you would like to know what personal information we hold about you, you may request access to or a copy of your personal information within our possession by contacting us according to Clause VIII and we will assess your request. In some cases, we may impose a reasonable charge for making copies of personal information available to you. If so, we will advise you of the charge prior to making the information available to you.

Depending on the country or territory in which you reside, you may have the right under local law to request erasure or deletion of the personal information we hold about you. If you wish to request for the removal of personal information we hold, and/or the deletion of your account, please contact us according to Clause VIII. Our compliance with your request for the removal of your personal information is subject to the availability of such right under local law, and is subject to any applicable legal or business requirements to retain certain records of your personal information. Please note that removal of personal information may result in limited or no access to the service that we provide.

VI. Your Rights - Withdrawing your Consent

Where you have provided your consent to any data processing activities and if such right is granted under applicable law, you may request to withdraw your consent by contacting us according to Clause VIII. Your request for withdrawal of consent will take effect within 30 days upon receipt of your request, or within the time period required by applicable law. Please note that use of your personal data may be essential for us to provide the product or service that you subscribed for. Therefore, your withdrawal of consent may impair our ability to continue providing the product or service to you. Your withdrawal of consent does not affect our right to continue to collect, use and disclose personal data where permitted or required under applicable laws.

Depending on your country or territory of residence, you may have additional rights in relation to your personal information, including:

the right to data portability,

the right to restrict or object to processing,

the right to file a complaint with your local data protection authority.

Please contact us according to Clause VIII if you wish to exercise any of these rights.

VII. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time without prior written notice. Updates to the Privacy Policy will be published on this page. We recommend that your review this page periodically for updates. However, if we are required by law to obtain your consent to use of your personal information for a new purpose, we will do so.

VIII. Contacting Us

If you have any query or feedback regarding this Privacy Policy, or on our data protection policies and procedures, or if you wish to exercise any of the rights outlined above, you may email [our guest experience officer] at help@theicebathclubs.com.

IX. International Operations and Data Protection Compliance

As The Ice Bath Club expands internationally we are committed to protecting your personal information in accordance with the applicable privacy laws of each jurisdiction in which we operate, including without limitation:

The Personal Data Protection Act (2012) in Singapore

The General Data Protection Regulation (EU) 2016/679 (GDPR) in the European Union and United Kingdom,

The Personal Data (Privacy) Ordinance (Cap. 486) in Hong Kong.

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Where your personal information is transferred across borders (e.g., from the UK or Hong Kong to Singapore or vice versa), we take appropriate safeguards to ensure your data remains protected, including by the use of standard contractual clauses and data processing agreements where required by applicable law.