1. What Personal Data do we collect?
We may collect, use and disclose the following kinds of Personal Data:
(a) information that you provide by filling in any booking forms or other forms on our website or which you give us over the telephone, including your name, (home or office) address, date of birth, (business or private) email address, (mobile, home or office) telephone number, credit card details (i.e. credit card type and number, CVC code, expiration date, credit card holder name) and to the extent available, preferred departure airport, reservation preferences and smoking preferences
(b) information about your computer and about your visits to and use of this website including where you have clicked on any of our advertising links or banners, (including your IP address, geographical location, browser/platform type and version, Internet Service Provider (ISP) and (for users of our service through a mobile device) Unique Device Identifier, operating system, referral source/exit pages, length of visit, page views, website navigation, date/time stamp information and details like the number and location of (mouse) clicks on a given page, mouse movements, scrolling activity and the (search) words you use and the text you type while being on and using our website)
(d) information that you provide to us for the purposes of subscribing to our website services, email notifications and/or newsletters and
(e) any other information that you choose to provide to us.
2. Using your Personal Data
We may use your Personal Data in the following ways:
For the purposes of our contract with you:
(b) manage, administer, mediate and contract the services offered by us via the website and/or our call centre
(c) manage, administer, mediate and contract your holiday bookings made through the website and/or our call-centre
(d) send you email notifications confirming your bookings made via the website and/or our call centre and any other email notifications you have specifically requested
(e) screening purposes, immigration and customs control purposes, safety, security, health, administrative and legal purposes
(f) manage and administer the website and
(g) deal with enquiries and complaints made by or about you relating to the website, your bookings and/or the services offered by us or our suppliers.
For such purposes as may be in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization:
- improve your browsing experience by personalising the website
- to analyse and improve the services offered on our website and to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate for marketing and strategic development purposes
- send you general (non-marketing) commercial communications including communications about any important changes to the website and/or surveys we may ask you to complete and
- to monitor, record, store and use any telephone, email or other communication with you for monitoring purposes, in order to check any instructions given to us by you, for staff training purposes, for crime prevention and to improve the quality of our customer service.
For purposes pursuant to your consent:
- deliver marketing and adverts to you that show our services and deals that we think you will be interested in including via targeted advertising on third party websites and/or platforms.
3. Information about other people
In addition, we may disclose your Personal Data:
(a) to the extent that we are required to do so by law
(b) in connection with any legal proceedings
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) and
(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.
6. International data transfers
Information which you provide may be transferred to countries which do not have data protection laws equivalent to those in force in Singapore, in particular where your booking destination is outside Singapore. Please note, if we cannot pass this information to the relevant accommodation and/or service providers, whether in Singapore or not, we cannot provide the services to you.
Information may be transferred to companies contracted by us to perform services in connection with this website who are based outside Singapore and outside of the European Economic Area (“EEA”), including in the United States, where such organisations have signed up to the US Safe Harbour Principles and/or contracts providing an adequate level of protection have been signed. Where we transfer Personal Data outside the EEA, this is done either on the basis that it is necessary for the performance of the contract of carriage between you and us, or that the transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and Decision 2010/87/EU.
7. Security of your Personal Data
We will take reasonable security arrangements to protect your Personal Data against unauthorised access, access, collection, use and disclosure.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in to the website).
In addition, Personal Data that you submit for publication on the website as a review will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
We will retain Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, our legal or business purposes, or as required by relevant laws.
9. Policy amendments
10. Third party websites
11. Data Subject Rights
You also have the right to the following data subject rights by contacting us in writing by post or by email to the address firstname.lastname@example.org.
You have the right to know whether we process Personal Data about you, and if we do, to access Personal Data we hold about you and certain information about how we use it and who we share it with.
If you require more than one copy of the Personal Data we hold about you, we may charge an administration fee. We may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person) or where another exemption applies.
You have the right to receive a subset of the Personal Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. The relevant subset of Personal Data is data that you provide us with your consent or for the purposes of performing our contract with you.
If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).
You have the right to correct any Personal Data held about you that is inaccurate. Please note that whilst we assess whether the Personal Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
You may request that we erase the Personal Data we hold about you in the following circumstances:
- you believe that it is no longer necessary for us to hold the Personal Data we hold about you
- we are processing the Personal Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Personal Data
- we are processing the Personal Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Personal Data
- you no longer wish us to use the Personal Data we hold about you in order to send you marketing or
- you believe the Personal Data we hold about you is being unlawfully processed by us .
Also note that you may exercise your right to restrict our processing of the Personal Data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.
Where you have requested that we erase Personal Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Personal Data or providing links to the Personal Data to erase the Personal Data too.
Restriction of Processing to Storage Only.
You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection)
You may request we stop processing and just store the Personal Data we hold about you where:
- you believe the Personal Data is not accurate for the period it takes for us to verify whether the Personal Data is accurate
- we wish to erase the Personal Data as the processing we are doing is unlawful but you want us to retain the Personal Data but just store it instead
- we wish to erase the Personal Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims or
- you have objected to us processing Personal Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Data whilst we determine whether there is an overriding interest in us retaining such Personal Data.
At any time you have the right to object to our processing of Personal Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Personal Data for that purpose.
You may object where:
- we are processing the Personal Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Personal Data whilst we make the assessment on an overriding interest.
12. MinorsThis Website is not directed at children under the age of 16 and we cannot distinguish the age of persons who access and use this Website. If a minor (according to applicable laws) has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact us to remove the relevant Personal Data and unsubscribe the minor. If we become aware that Personal Data has been collected from a person under the age of 16 without parental or guardian consent, we will delete this Personal Data and, where that minor has an account, terminate the minor’s account.