Last updated: 19 January 2023
Because The Xcess is not a financial institution, we have no reporting obligations under the Foreign Account Tax Compliance Act (FATCA) or the Common Reporting Standard (CRS) of the Organisation for Economic Cooperation and Development (OECD).
Summary of Key Points
What information does The Xcess collect? We collect Personal Information you provide to us directly such as your contact information and purchase details. We collect Personal Information automatically when you use the Services such information about your browser or device, the products you view, and your navigation on the Site. We also collect Personal Information from other parties to support our business operations and marketing efforts. Learn more about what information we collect.
How does The Xcess use this information? We use your Personal Information to provide the Services, enhance the Services and market the Services. This includes delivering your products, maintaining your account with us, communicating with you about our Services, developing new features or new product offerings, personalising your experience on the Services, and meeting our legal and compliance obligations. Learn more about how we use your Personal Information.
To whom does The Xcess disclose my information? We disclose Personal Information to service providers who help us provide the Services to you, such as cloud providers and payment processors. We also disclose Personal Information to advertising partners and may disclose it to other business partners such as affiliates. Finally, we disclose Personal Information to governmental authorities when under an obligation to do so. Learn more about our sharing of information.
Do I have any privacy rights concerning my information? You may, depending on where you live. But The Xcess has extended certain data choices to all The Xcess consumers, regardless of where you live. You may request that we delete your information, correct your information, or provide access to your information. Learn more about your privacy rights.
1. Personal Information We Collect About You
We collect and process Personal Information about you or your devices from various sources described below.
Personal Information you provide to us.
This is Personal Information about you that you provide directly to The Xcess and our service providers, including:
- Region and language. When you visit our Sites or Apps, we may ask you to select your region and language to provide you with the relevant Services.
- Registration and profile information. When you create an account on our Services, we will collect your name, email address, and a password. You may also provide optional profile information such as watches you own and products you’re following. When you enquire, make an offer or complete a transaction on the Services, that information will be tracked in your account.
- Marketing information. When you sign up to receive SMS marketing messages from us, you provide us with your mobile phone number. Our SMS program is subject to the terms and conditions found at https://thexcess.com/terms.
- Purchase information. When making a purchase via our Services, we collect your shipping address, payment information and billing address. Payment information is collected through a third-party payment gateway and we do not store payment card information. Depending on your jurisdiction, you may also need to provide additional information related to customs and taxes, for example a VAT ID.
- User information. Users must provide payout information including date of birth, address, and bank account information when using certain Services. This information is collected through a third-party payment gateway and we do not store payment card information. We may additionally require a government identification number (e.g., National ID, Passport ID) to satisfy information reporting obligations.
- Identity Verification Information. Under certain circumstances, we may need to verify the identity of a User on the Services. To do this, we may request that you provide government photo identification, and a Live Photo to us, which can confirm a match between your government identification and live photo. This process may employ the use of biometric data, which you can read more about here: Biometric Data Policy.
- Communications. When you contact us via a contact form, email, phone, or other means (e.g., to submit a query, or to report a problem with our Services), you may provide us with Personal Information, such as your name and contact details, language, and the content, date, and time of our communications.
- Contests and sweepstakes. If you enter a contest or sweepstakes sponsored by us, you may provide us with your name, date of birth, mailing address and e-mail address if you enter via postal mail. If you enter through a social media platform, you will provide your social media handle and potentially other Personal Information as part of your entry.
- Surveys and reviews. If you have chosen to receive marketing messages from us, we may contact you to participate in surveys about the Services or provide product or Services reviews. If you decide to participate, you may be asked to provide Personal Information.
- Career information. If you apply for a job with us directly, you may provide us with your resume, name and contact details, and any other information that you submit to us. If you apply for a job with us through a third-party platform (such as LinkedIn), we will collect the information you make available to us through such a third-party platform.
Some of this information is considered “sensitive personal information” under some laws. Where we collect sensitive personal information, we do so either with your consent or because it is necessary to provide the Services to you (e.g., Bank Account Information), to fulfil a legal reporting requirement, or to prevent and detect fraud on the Platform. In some cases, provision of your Personal Information may be necessary to provide you with our Services. In these cases, if you fail to provide certain Personal Information when requested, we may be required to suspend your access to our Services.
Personal Information collected automatically from your use of the Services
Like most websites, when you use our Services or open our marketing messages, we automatically collect certain information via automated means such as cookies, pixels, beacons, invisible tags, and similar technologies (collectively “Cookies”). These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you.
We may collect the following types of information via Cookies:
- The type of device or browser you’re using, time zone setting, browser plug-ins and operating system information
- Your IP address (from which we may approximate your geographic location)
- Your browsing behaviour while on the Services, including your login information, products viewed or searched for, time spent on the Services, page response times, download errors and page interactions
- The URLs of the websites you visited immediately before visiting our Services
- Unique numeric identifiers associated with your device or browser
- Interactions with our marketing messages, such as when you click on a link in an email or SMS message
- Interactions with our advertising partners, including the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase
Personal Information we collect from third-parties
We also collect Personal Information about you from other sources and third-parties. We may add this information to the information we have already collected from you via our Services. This third-party information includes:
- Social networks. We may collect Personal Information about you post photos, comments, or reviews on our pages available through third-party platforms (e.g., Facebook, Instagram, etc.). This information may include your social media user ID and email address. You may also be able to post products from the Services through third-party social networks. If you do so, we and other users on those third-party platforms may be able to view the Personal Information you make available in your posts.
- Data Partners. We receive additional Personal Information about you (such as approximate geographic location, demographic information, and mail order responses for categories of interest) from third parties that provide information about you based on your IP address, unique online identifier, or other data points you have provided to us.
- Fraud Prevention and Identity Services. We may receive Personal Information about you if we engage third-party service providers to confirm users’ identities and prevent fraud on the Services.
2. How We Use Your Personal Information
We use your Personal Information to:
- Provide you with our Services, including to administer your account with us, process transactions, and notify you about changes to our Services.
- Conduct internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Ensure that content from our Services is presented in the most effective manner for you and for your computer, including personalising the content presented to you on our Services based on your past interactions with the Services, your location, or other information.
- Perform marketing analysis and provide you with promotional updates and information about our products we feel may interest you. You can opt-out of further marketing at any time by managing your account settings or selecting the “unsubscribe” link at the end of our marketing and promotional update communications to you.
- Deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- Keep our Services safe and secure (including fraud prevention via third-party identity verification services).
- Analyse and improve our Services and develop new products and services.
- Enforce our legal rights and maintain compliance with applicable laws and regulations.
The types of Cookies we use can be classified as follows:
- Strictly necessary cookies. These Cookies are required for the operation of our Services and under our terms with you. They include, for example, Cookies that enable you to log into secure areas of our Services, use a shopping cart, or make use of e-billing services.
- Functional cookies. These Cookies are used to recognise you when you return to our Services and provide enhanced functionality. This enables us to personalise our content, and remember your preferences (for example, your choice of language or region).
- Performance cookies. These Cookies allow us to recognise and count the number of users and to see how users move around our Services. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.
- Targeting cookies. These Cookies record your visit to our Services, the pages you have visited and the links you have followed. We will use this information to make our Services and our advertising more relevant to your interests (as further set forth below). We may also disclose this information to third parties for this purpose.
You may not be able to take full advantage of our Services if you disable certain Cookies. The effect of disabling Cookies depends on which Cookies you disable but in general, the Services may not operate properly if all Cookies are switched off.
Our use of targeted advertising. We use online advertising to keep you aware of our brand and help you to find and see our products. We partner with platforms such as Google, Meta, and similar digital advertising partners. Targeting Cookies help us and the advertising partners we work with gather information about the content you visit on our Services and other websites. This may result in you seeing The Xcess banners and ads when you are on other websites, apps and social media platforms.
We may also target ads using Personal Information we have collected when you create an account on the Services. We may disclose certain pseudo-anonymised (hashed) portions of your Personal Information (typically your email address) to social media and internet platforms. If you have an account on one of these platforms, you may be shown The Xcess marketing messages while you are using the social media or internet platform.
Targeted advertising preferences. You may opt-out of us using your Personal Information for targeted advertising by changing your Cookie preferences on your web browser. If you are using a web browser with Global Privacy Control enabled, we will recognise that signal as a request to opt-out of Targeting Cookies.
Additionally, our advertising partners may participate in programs that provide simple ways to opt out of ad targeting across the internet.
4. To Whom We Disclose Your Personal Information
We may disclose Personal Information we collect from or about you as described below or as otherwise disclosed to you at the time of collection.
The Xcess group. Any member of our group, which includes our subsidiaries, our ultimate holding company, and its subsidiaries, who support our processing of Personal Information.
Service providers. We also disclose your Personal Information to service providers (“processors”) that perform services on our behalf (e.g., shipping carriers, software services providers, identity verification services, etc.). This includes payment processing providers who provide secure payment processing services. Note that we do not have access to your payment card details.
Other selected third parties. Our selected third parties may include:
- Analytics and search engine providers that assist us in the improvement and optimisation of our Services.
- Advertising Partners that we work with to show you ads that we think may interest you and provide ad measurement services to us. In “Targeted advertising preferences” above, we describe options for opting out of the sharing of your data for these purposes.
- Business partners who jointly with us provide Services to you.
- Other parties at your direction, including:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorised by you through the Services).
- Social media services (if you intentionally interact with them through your use of the Services).
- Third-party business partners that you access through the Services.
- Other parties authorised by you.
- Merger, sale, or other asset transfers. In connection with the consideration, negotiation, or completion of a corporate transaction in which we sell or transfer all or a portion of our business or assets, but only to the extent that your Personal Information is necessary for such transactions, in which case we will comply with applicable legal requirements when processing your Personal Information.
- As required by law and similar disclosures. If we are under a duty to disclose your Personal Information in order to comply with any legal obligation, regulation, process or governmental request, or in order to enforce or apply our terms and other agreements with you; or to protect the rights, property, or safety of The Xcess, our customers, or others. This includes exchanging information with other companies and organisations, including law enforcement agencies, for the purposes of fraud protection, tax reporting, and to prevent cyber or other suspected or alleged crime.
- With your consent. We may also disclose Personal Information from or about you or your devices with your permission obtained in accordance with applicable law.
We do not sell your Personal Information, in so far as the term “sale” is commonly understood to be an exchange for monetary consideration. However, under the Singapore PDPA, our sharing of information for targeted advertising uses could be considered a “sale” of Personal Information.
5. Your Rights
You may have the following rights with respect to your Personal Information:
- to be provided with a copy of your Personal Information (right of access), including the right to have your Personal Information provided in a commonly used and machine-readable format (right of portability) ;
- to request the correction of your Personal Information;
- to request the deletion of your Personal Information;
- to request that we restrict the processing of your Personal Information;
- to object to the further processing of your Personal Information, including the right to object to marketing communications;
- to provide instructions about your Personal Information after death; and
- to opt-out of sharing your personal information with third parties for some purposes, notably targeted advertising, which may be defined as a sale under applicable laws.
You may also have the right to appeal a decision we make regarding your rights.
These rights vary depending on where you reside, but we make efforts to honour requests for access/portability, deletion, and correction from all The Xcess users, regardless of where they live. You may exercise these rights by submitting a written request to privacy@The Xcess.com.
You may also opt out of receiving marketing emails from us at any time through your Account Settings or by clicking the unsubscribe link at the bottom of our marketing emails. You can opt out of receiving promotional text messages by responding “STOP” to one of our text messages.
To exercise other rights, ask questions about your rights, or to appeal a decision we have made about your rights, please contact us at privacy@The Xcess.com. We will not discriminate against you because you have exercised your rights.
6. How We Transfer Your Personal Information
The Xcess has its headquarters in Singapore. Information we collect about you will be processed in Singapore and depending upon the nature of your interaction with us, may be further processed in other countries. For example, if your goods are being shipped from a country other than where you are located, your Personal Information will be disclosed to a carrier in that country as part of our shipping process.
We comply with applicable legal requirements when transferring Personal Information to other countries under the Singapore PDPA.
7. How We Protect Your Personal Information
We take steps to secure the Personal Information you provide through the Services, although no method of data transfer or storage on networks is 100 percent secure. All information you provide to us is stored on our secure servers. We implement appropriate technical and organisational measures to protect it from unauthorised access, loss, destruction or alteration.
You have a role to play in protecting your information, too. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to disclose a password with anyone, and to use a unique password on the Services.
We do not collect or store the credit or debit card or other payment information that you provide in the context of the Services. Payments made on the Services using a credit or debit card are made directly through a third-party payment gateway provider. We do not collect or store Personal Information that you may provide to our identity verification service providers, if any. Personal Information that you supply to third-parties is not within our control and is subject to those third-parties’ privacy policies and terms of service.
8. How Long We Keep Your Personal Information
When determining the retention period, we consider various criteria, such as the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on our ability to provide you with certain features of our Services if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.
We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services. You cannot be identified from aggregate information retained or used for these purposes.
9. Personal Information of Children
We do not knowingly collect or solicit Personal Information from children under 16; if you are a child under 16, please do not attempt to register on or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us with their Personal Information, please contact us at https://thexcess.com/contact.
12. Contact Us
You may find additional information and tips in our Help Center. If you cannot find the information you are looking for in the Help Center, you may contact us at firstname.lastname@example.org.
The entity responsible for the processing of your Personal Information is:
The Xcess Pte. Ltd.
1016 Gelling East Avenue 3,Floor 4 Unit 153
13. Biometric Data Policy
We may collect your Biometric Data under certain circumstances to identify and authenticate you for purposes of security and fraud prevention. Biometric Data in this context consists of facial recognition data, as well as mathematical representations of your facial geometry. We will seek your consent to collect your Biometric Data.
We collect this Biometric Data through our third-party service provider of identity verification services, Persona. Persona captures a photo of your ID and your face and compares the facial geometry extracted from the photos of your ID and your face to verify your identity.
Persona does not use your Biometric Data for any purpose other than to verify your identity and to improve its verification services. It does not disclose your Biometric Data to us or any other third party. We can however view a copy of the photographs of your face and ID.