BRZY, a brand of STRUGGLES OF THE 90s KIDS LLP (UEN: T24LL1182C)
Version 1.1 — effective 19 September 2026
How this notice works with our main Privacy Policy
Our main Privacy Policy is published at brzy.sg/policies/privacy-policy. It is maintained through our e-commerce platform, Shopify, and is kept up to date as privacy law changes. It describes the categories of personal information we collect, where it comes from, how we use it, and who we disclose it to.
That policy is written to apply across jurisdictions. This Supplement adds the information required specifically under Singapore's Personal Data Protection Act 2012 (the "PDPA"), and describes practices particular to BRZY that a general policy cannot cover.
Read the two together. Where this Supplement and the main Privacy Policy differ on a matter of Singapore law, this Supplement applies.
1. Who we are
BRZY is a brand operated by Struggles of the 90s Kids LLP, a limited liability partnership registered in Singapore.
- Registered name: Struggles of the 90s Kids LLP
- UEN: T24LL1182C
- Registered office: 12 Woodlands Square, #13-79, Woods Square, Singapore 737715
Where our main Privacy Policy refers to "BRZY", the organisation responsible for your personal data is Struggles of the 90s Kids LLP.
2. Our Data Protection Officer
As required by section 11 of the PDPA, we have designated a Data Protection Officer. You may contact them about anything in this notice, or about how we handle your personal data:
Data Protection Officer
Izdihar Jamil, Manager
Struggles of the 90s Kids LLP
12 Woodlands Square, #13-79, Woods Square, Singapore 737715
Email: contact@sot90k.com
BRZY customer enquiries: contact@brzy.sg · Telephone: +65 8761 8119
3. Consent, and how to withdraw it
The PDPA is built on consent. By providing your personal data to us, placing an order, or otherwise interacting with us, you consent to our collecting, using and disclosing it for the purposes described in our main Privacy Policy and in this Supplement.
You may withdraw your consent at any time by contacting our Data Protection Officer. We will act on your request within a reasonable time and will tell you the likely consequences before we do — for example, we cannot deliver an order without your delivery address, and we cannot send drop announcements if you withdraw marketing consent.
Withdrawing consent to marketing does not stop transactional messages about orders you have already placed.
In the limited circumstances permitted by the PDPA, we may collect, use or disclose personal data without consent — for example where necessary to comply with a legal obligation.
4. Advertising data we share with Meta (Facebook and Instagram)
Our main Privacy Policy refers generally to sharing data with marketing partners. This section sets out what that means in practice for BRZY. This sharing began on 18 September 2026.
We use Meta's advertising tools to measure how our advertising performs and to show BRZY advertising to people likely to be interested. We share customer activity data with Meta Platforms, Inc. through three mechanisms:
- The Meta Pixel — code on brzy.sg that records actions you take on the site: viewing a product, adding to cart, beginning checkout, and completing a purchase, together with technical data such as your IP address and browser.
- Advanced matching — sends Meta a hashed (obscured) form of details you enter at checkout, such as email address, name and phone number, so Meta can match your activity to a Meta account where one exists.
- The Conversions API — sends the same categories of event data to Meta directly from our systems, server-to-server, in addition to what is sent from your browser.
We have also created a product catalogue in Meta containing our product information — names, descriptions, prices, images and availability. The catalogue holds product data, not customer data.
We use the "Enhanced" data-sharing level offered by Shopify. We have not enabled the "Maximum" level, which would share a broader set of customer data than we consider necessary.
Your choices:
- You can disconnect this activity data from your Facebook or Instagram account through Meta's "Off-Facebook Activity" settings within your Meta account.
- You can ask us to stop disclosing your personal data to Meta for advertising, by contacting our Data Protection Officer.
5. The Shop app
Added 19 September 2026.
BRZY has a storefront in the Shop app, Shopify's consumer shopping app. To operate it, Shop (provided by Shopify) receives:
- your name, email address, telephone number and physical address;
- device and activity data, including approximate geolocation, IP address, browser and operating system;
- order and shipping information; and
- store analytics and billing information.
Shop handles this data under Shopify's own privacy policy. If you would rather we did not make your data available to the Shop app, contact our Data Protection Officer.
6. How long we keep your personal data
Our main Privacy Policy states that retention depends on several factors. In practice, for customers in Singapore:
- Order and transaction records: at least 5 years from the transaction, to meet Singapore tax record-keeping requirements;
- Customer account information: until you ask us to delete it, or 24 months after your last interaction with us, whichever is earlier;
- Marketing data: until you withdraw consent;
- Customer service records: 24 months from resolution; and
- Website and advertising analytics we hold: 24 months. Data held by Meta, Shop and other platforms is retained under their own policies, which we do not control.
Once we no longer need personal data for a legal or business purpose, we delete or anonymise it.
7. Transfers of personal data outside Singapore
Several of the parties we work with — including Shopify, Shop and Meta — store or process personal data outside Singapore, including in the United States.
Under section 26 of the PDPA we may only transfer personal data overseas where we have taken appropriate steps to ensure the recipient is bound by legally enforceable obligations providing a standard of protection comparable to the PDPA. We rely on the contractual terms in our agreements with these providers for that purpose.
Our main Privacy Policy refers to European and United Kingdom transfer mechanisms. Those are not the mechanisms that apply to you as a customer in Singapore; section 26 of the PDPA is.
8. Access and correction requests
You may ask us for a copy of the personal data we hold about you, and for information about how it has been used or disclosed in the year before your request. You may also ask us to correct personal data that is inaccurate or incomplete.
Send requests to our Data Protection Officer. We will respond within 30 days, or tell you if we need longer and why. We may charge a reasonable fee for an access request, as the PDPA permits, and we will tell you the fee before proceeding.
9. If something goes wrong — data breach notification
If a data breach occurs that is likely to result in significant harm to affected individuals, or that affects 500 or more individuals, we will notify the Personal Data Protection Commission within 3 calendar days of assessing the breach to be notifiable, and will notify affected individuals as soon as practicable, in accordance with the Personal Data Protection (Notification of Data Breaches) Regulations 2021.
10. Complaints
If you are unhappy with how we have handled your personal data, please contact our Data Protection Officer first — we would rather hear from you and fix it.
If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.
11. Children
BRZY products are sold to adults, and our Terms of Service require purchasers to be 18 or over. We do not knowingly collect personal data from children under 13 without verifiable parental consent, and we do not direct advertising to them. If you believe a child has given us personal data, contact our Data Protection Officer and we will delete it.
12. Changes to this Supplement
We will update this Supplement when our practices change — for example if we begin sharing personal data with a new advertising platform. The current version is always published here with its revision date. Material changes will be notified by email or a prominent notice on our website.
13. Governing law
This Supplement is governed by the laws of the Republic of Singapore.
Last updated 19 September 2026. See also our main Privacy Policy.