DATA PROTECTION POLICY
This Data Protection Policy (“Policy”) applies to all personal data collected by Easy-Fly International Holding Pte. Ltd. and our subsidiaries and associated companies (hereafter collectively referred to herein as “Easy-Fly Holding Group”, (“we”, “us” or “our”) may collect, use, disclose, transfer and store your Personal Data (as defined below). We are committed to protecting your privacy. The Companies may share your Personal Data with each other and use it in a manner and for purposes which are consistent with this Privacy Policy and consistent with the Personal Data Protection Act 2012 of Singapore. We may combine your Personal Data with other information for the purposes of providing products and services to you, or to improve our products, services, and content.
Easy-Fly International Holding Pte. Ltd.’s related companies include the following:
• Easy-Fly Travel Pte Ltd; and
• Emperor International Travel Pte Ltd; and
• Hua Sin Trading Pte Ltd.
PERSONAL DATA
1. In this Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you such as your name, passport information, details, nationality, age or date of birth, gender, qualification, marital status and any other data relating to any individuals which you have provided us via third personal party Travel Partners in China.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you ( or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you ( or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
4. We may collect and use your personal data for any or all of the following purposes:
a) Performing obligations in the course of or in connection with provision of goods and/ or services requested by you;
b) Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and /or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
c) Verifying your identity;
d) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
e) Managing your relationship with us;
f) Processing payment or credit card transactions;
g) Sending you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
h) Complying with any applicable law, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and or regulatory authority;
i) Any other purposed for which you have provided the information;
j) Any other incidental business purposes related to or in connection with the above.
5. We may disclose your personal data:
a) Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
b) To third party service providers, agents and other organisations we have engaged to perform any of the function listed in clause 4 above for us.
6. The purposes listed in the above clauses may continue to apply even in situation where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
WITHDRAWING YOUR CONSENT
7. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and /or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to Data Protection Officer at the contact details provided below.
8. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same time, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
9. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 7 above.
10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSOANAL DATA
11. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data; or (b) a correction request to correct or update any of your personal data, which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
12. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
13. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we unable to do so (expect where we are not required to do so under PDPA).
PROTECTION OF PERSONAL DATA
14. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third-party service providers agents only on a need-to-know basis.
15. You should be aware, however, that no method of transmission over the internet or method of electronics storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
16. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
17. We may retain your personal data for as long as it is necessary to fulfil the purpose for which is was collected, or as required or permitted by applicable laws.
18. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE
19. We generally do transfer your personal data to countries of Singapore. However, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
20. You may contact our Data Protection Officer if you have any enquiries or feedback our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
DPO’ details:
• Name of DPO: Ms Chong
• Contact Number: +65 62915305
• Email address: [email protected]
EFFECT OF NOTICE AND CHANGES TO NOTICE
21. This policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
22. We may revise this policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this policy was last updated. Your continued use of our service constitutes your acknowledgement and acceptance of such changes.
Effective Date: 01 April 2019