OUR PLEDGE
We, Guardian Health And Beauty (B) Sdn. Bhd. ("GHBBB", "our", "we" or "us") are committed to safeguard your privacy and ensure that your personal data and health information to which it is entrusted, is protected. Therefore, we make sure that our policies and practices in relation to personal data comply with the requirements of Personal Data Protection Order 2025 (the "Act") under the laws of Brunei Darussalam.
By participating in Guardian BN ("GUBN"), you acknowledge that you have reviewed the terms of our Privacy Policy and agree that we may collect, use and transfer your Personal Data (as defined below) in accordance therewith. If you do not agree with these terms, please refrain from signing up for the Loyalty Programme and please do not provide us with any of your Personal Data. This Acknowledgement forms part of our GUBN Terms and Conditions and shall be governed by and construed in accordance with the laws of Brunei. Please note that our Personal Data and Privacy Policy will apply to the processing of your Personal Data for GUBN, and in such circumstances as you may agree with us when using our services and/or purchasing goods from us. Please read the entire Privacy Policy carefully. Should you have any questions about the Privacy Policy or about our data collection, storage and use practices, please contact us as provided below.
Introduction
By participating in the GUBN, we will collect and use personal data about you. Through participating in GUBN we will learn about what you buy, and you may receive offers and marketing from GHBB or its points issuance or redemption partners ("Partners"), the companies whose products they sell or advertise ("Brands") and other third parties through various Marketing Channels (by this we mean ways of receiving advertising or offers, including email, our Mobile App and Website, and may include other digital channels such as websites, apps, social media and advanced TV). This privacy policy shall also be applicable to individuals below 18 years old who are registering for GUBN membership, where parental consent is required.
This privacy policy explains what personal data we collect, the way we use it and why, the circumstances when we may share it, and your choices and rights with respect to your personal data.
1) What personal data do we use?
(i) Personal data you share with us
Account Information
This is personal data such as your name, gender, date of birth, postal code, email address, and telephone number that you share with us when you create your account with us.
Transaction Information
When you shop with Guardian or its Partners and use your GUBN ID, e.g. when you scan your GUBN barcode or buy something on an account you've linked with GUBN, we receive personal data about that transaction. This can include details about the transaction such as what you purchased and where you purchased it and how much you spent. The transaction information also includes details collected offline in our stores or through our customer services.
Programme Analytics
This is personal data regarding how you interact with GUBN. This includes:
• which offers you engage with and use
• the Points redemptions you make
• how you interact with and experience our websites and apps
• predictions about your interests, shopping habits and characteristics – we call these "profiled characteristics"
Surveys and Market Research
This is personal data that you share with us when you take part in surveys, questionnaires or market research run by us, our Partners, or research partners.
Contact Centre Information
This is the contents of chats, calls and correspondence with our Contact Centre or with our chatbot on the Guardian website, and any associated data.
Competitions Data
When you enter competitions operated by GHBB or our Partners, you may share personal data with us, such as your entry, contact and delivery details.
Device information, cookies & similar technologies
This is personal data from devices you use to access the internet, including our services such as our websites and apps, received via e.g. cookies and other similar technologies such as pixels. This could be information such as IP addresses, MAC addresses, unique IDs such as advertising IDs, location data, information about your browser, or details contained in URLs used in our communications with you (e.g. offer links in emails).
To find out more about cookies and similar technologies, please visit our Cookie Policy.
(ii) Additional personal data we receive about you
Data from Partners and Brands
Partners and Brands may share personal data with us (e.g. when you link your account) which they have collected during their relationship with you. This may be information such as how you use their website and apps, your transactions with them, competitions, surveys and marketing you've responded to, other loyalty schemes you've engaged in, or profiled characteristics attributed to you from your interactions with that company.
Data from third party data companies
This is personal data that we receive or use provided by companies that provide customer information or that is publicly available. These might be companies that help us verify or update your address, or companies that provide us with information on your modelled household profile. This could be received at an individual or an anonymous level such as information based on your post code.
Social Media and Digital Advertising – If we market to you using social media or digital advertising platforms (e.g. Google or Meta), we may use segmentations available on those platforms to help make our marketing more relevant to you.
Anonymous data
When personal data has identifying details removed, that information can become anonymous. This can happen if we remove details such as names and addresses, or aggregate personal data into groups and keep only the information about the groups (e.g. information about people at a post code level or a report of shopping behaviour broken down by age), or when we create models from personal data that identify certain characteristics associated with certain traits (e.g. customers likelihood to buy a particular product or category).
Because we can't identify people within anonymous data, it is treated differently from personal data and is not covered by this policy.
Pseudonymised data
Pseudonymised data is similar but slightly different from anonymous data. Although identifying details such as names and addresses are removed, it is possible to identify them by reference to a ‘key' held separately. Pseudonymised data may be used to enhance security and privacy by enabling data to be processed at an individual level without requiring identifying details to do so. Pseudonymised data remains personal data and is covered by this policy.
(iii) How we will use your personal data, and our basis for doing so?
This section explains when we process your personal data, and why we do it. In these use cases, we may use an automated decision-making process which takes into account the types of data listed in each section. For example, when using automated decision-making processes to market to you based on your GUBN profile, we might take into account Transaction Information, Account Information and Programme Analytics.
In some cases, you have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects for you or affects you in a similarly significant way.
If you are seeking to exercise this right, please contact us.
To operate GUBN
We will use your personal data to operate the Programme, including to:
|
Use |
Category of Personal Data |
Legal basis |
|
Manage your GHBB and GUBN account, and operate our apps and websites and tailor these to you |
• Account Information • Transaction Information • Programme Analytics • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies, or if certain sharing of data is on an opt-in basis) • Contractual Necessity |
|
Allow you to link your GUBN account with your accounts at our Partners |
• Account Information • Device information, cookies & similar technologies • Data from Partners and Brands |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies, or if certain sharing of data is on an opt-in basis) |
|
Enable you to collect and redeem points at Partners |
• Account Information • Transaction Information • Programme Analytics • Device information, cookies & similar technologies |
• Legitimate Interest • Contractual Necessity • Consent (e.g. for Device information, cookies & similar technologies) |
|
Interact with offers in our app and at Partners |
• Account Information • Transaction Information • Programme Analytics • Device information, cookies & similar technologies • Data from Partners and Brands |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies, or if certain sharing of data is on an opt-in basis) • Contractual Necessity |
|
Personalise your GUBN experience based on your location |
• Account Information • Transaction Information • Programme Analytics • Device information, cookies & similar technologies |
• Legitimate Interest • Consent |
|
Provide other Programme- related services |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Contact Centre Information • Competitions Data • Data from Partners and Brands • Data from third party data companies • Device information, cookies & similar technologies |
• Legitimate interest • Contractual Necessity • Consent |
|
Create and apply anonymous data models from and to your personal data |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Data from Partners and Brands • Data from third party data companies |
• Legitimate Interest |
Analyse your use of GUBN
We will use information about your use of GUBN, our websites and apps to analyse your behaviour for various purposes, including to:
|
Use |
Category of Personal Data |
Legal basis |
|
Provide information about you to our Partners and Brands |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Data from Partners and Brands • Data from third party data companies • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
|
Understand how you use GUBN |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Data from Partners and Brands • Data from third party data companies • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
|
Build a profile about you and your profiled characteristics, based on the personal data we have about you from your use of your GUBN account, our websites and apps, as well as personal data we receive from Partners, Brands and third parties |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Contact Centre Information • Data from Partners and Brands • Data from third party data companies • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
|
Create and apply anonymous data models from and to your personal data for the uses listed above |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Data from Partners and Brands • Data from third party data companies |
• Legitimate Interest |
Market to you based on your profile
We will use the information available to us to build a profile of you for marketing purposes, including to:
|
Use |
Category of Personal Data |
Legal basis |
|
Personalise the marketing and offers you receive from GUBN, our Partners and Brands through various marketing channels, including email, SMS, our app, as well as digital channels such as websites, apps, social media and advanced TV |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Contact Centre Information • Data from Partners and Brands • Data from third party data companies • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
|
Assess the effectiveness of the marketing activities of GUBN, our Partners, Brands and third parties |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Data from Partners and Brands • Data from third party data companies • Competitions Data • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
|
Personalise marketing and offers based on your location |
• Account Information • Transaction Information • Programme Analytics • Device information, cookies & similar technologies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
|
Create and apply anonymous data models from and to your personal data for the uses listed above |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Data from Partners and Brands • Data from third party data companies |
• Legitimate Interest |
|
Use data matches to identify relevant audiences of GUBN Members and find them on digital channels for the purposes of marketing |
• Account Information • Device information, cookies & similar technologies • Data from Partners and Brands • Data from third party data companies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
Conduct Surveys and Market Research
Your personal data may be used to conduct surveys and market research. For example, Transaction Information may be used to identify relevant shoppers for a survey on e.g. dental hygiene.
|
Use |
Category of Personal Data |
Legal basis |
|
Conduct Surveys and Market Research |
• Account Information • Transaction Information • Programme Analytics • Surveys and Market Research • Competitions Data • Device information, cookies & similar technologies • Data from Partners and Brands • Data from third party data companies |
• Legitimate Interest • Consent (e.g. for Device information, cookies & similar technologies) |
Create data models
We combine the personal data we have and analyse it to look for patterns, trends and characteristics that align with a particular outcome – for example, items that are often purchased together, or popular times to redeem points. We use this analysis to create a framework that maps out these patterns, trends and characteristics on an anonymous basis - we call these frameworks "data models" and the process of making them "data modelling".
Data modelling helps us to analyse the way that groups of people are shopping. We can then apply data models to a personalised data set, to help us tailor the offers that we server to Members.
|
Use |
Category of Personal Data |
Legal basis |
|
Create data models |
• Account Information • Transaction Information • Surveys and Market Research • Competitions Data • Data from Partners and Brands • Programme Analytics • Data from third party data companies |
• Legitimate Interest |
Who will we share your personal data with?
We may share your personal data within the DFI Retail Group, with Partners and Brands, Service Providers and other organisations in connection with carrying on our business, including to provide products and services to you either directly or via third parties.
DFII RETAIL GROUP, SUBSIDIARIES AND AFFILIATES
GUBN is operated by GHBB who in turn is part of the DFI Retail Group. We share your personal data withing the Group for purposes such as:
• To operate GUBN
• Analyse your use of GUBN
• Market to you based on your Profile
• Competitions
• Conduct Surveys and Market Research
• Create and apply data models
• Provide customer service support
• Security and fraud
BN LOYALTY PARTNERS
We may share your personal data with Partners, for purposes such as:
• To operate GUBN
• Analyse your use of GUBN
• Market to you based on your Profile
• Competitions
• Conduct Surveys and Market Research
• Security and fraud
• Create data models
The types of personal data we share with Partners include:
• Account Information
• Transaction Information
• Programme Analytics
• Surveys and Market Research
• Contact Centre Information
• Competitions Data
• Device information, cookies & similar technologies
BRANDS
We may share your personal data with Brands for the following purposes:
• Analyse your use of GUBN
• Market to you based on your Profile
• Competitions
• Surveys and Market Research
The types of personal data we share with Brands include:
• Account Information, with your consent
• Pseudonymised Account Information
• Device information, cookies & similar technologies
• Programme Analytics
• Transaction Information
• Surveys and Market Research
• Competitions Data
SUPPLIERS AND SERVICE PROVIDERS
We work with different companies so that they can help us run GUBN, as well as deliver other services you require from us or we think you might be interested in. We share the personal data we have with those suppliers and service providers for the following purposes:
To operate GUBN, e.g.:
• Mailing houses to send you information or offers by post
• Affiliate marketing networks to bring you some of our offers
• Companies that provide IT and Cloud infrastructure services and support
Market to you based on your profile, e.g.:
• Online and social platforms
• Advanced TV platforms
• Advertising and marketing agencies
• Companies which help us deploy our emails
• Companies which help us deploy SMS and other campaigns through electronic means
• Coupons you receive via the App
Analyse your use of GUBN, e.g.:
• Companies that provide analytics support
• Companies that provide data matching support
Competitions, e.g.:
• Companies who administer competitions for us so they run smoothly and fairly
Surveys and Market Research, e.g.:
• Companies who conduct market research on our behalf or in conjunction with us
Provide Customer Service Support, e.g.:
• Companies who run our contact centres, which need your personal data to identify or contact you as well as deal with your query
Create Data Models and anonymise data, e.g.:
• Companies which offer anonymisation and data modelling services
OBJECT, RESTRICT, WITHDRAW CONSENT AND PORT
• You can use the Account section of our website app or via email to opt-out of receiving marketing newsletters
• Opt-out of your personal data being used to tailor the Digital Advertising you receive
Where we rely on consent as the legal basis for processing your personal data, you may withdraw that consent at any time. To do so, please contact us via email at guardianbnrewards@dfiretailgroup.com and address your request to Customer Service. Please note that withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal.
INTERNATIONAL TRANSFER
From time to time we transfer your personal data outside of Brunei for the purposes described in this privacy policy. When we do this, your personal data will continue to be subject to one or more appropriate safeguards set out in the law.
Where we put in place appropriate safeguards to protect personal data we transfer, the safeguards may include securing additional legal agreements to protect your information.
RIGHT OF ACCESS TO PERSONAL DATA
1. Under the Act, you have the right of access to your Personal Data held by GHBB on payment of a prescribed fee. You may also request: (i) correction of your Personal Data that is inaccurate, incomplete, misleading or not up-to-date; (ii) deletion of your Personal Data held by us, subject to our right to retain copies of that Personal Data as permitted by applicable law, and (iii) cessation of the processing of your Personal Data.
2. If you have any questions regarding GHBB's Privacy Policy or if you wish to request access to your Personal Data or if you wish to correct or delete your Personal Data or if you wish to withdraw your consent to GHBB for the processing of your Personal Data for the purposes of BNGuardian Rewards or for the transfer of your Personal Data to the third parties stated, you may request and email at guardianbnrewards@dfiretailgroup.com addressed to Customer Service.
3. GHBB reserves the right to charge you a reasonable fee for the processing of your personal data request in accordance with applicable law.