PRIVACY POLICY


LAST UPDATED: 25 MAY 2018

This is the Tradewinds Tours and Travel Pte Ltd ('TTT', 'we', 'our') Privacy Policy, a member of the Singapore Airlines Group.
We are a corporation registered in the Republic of Singapore with company number 199201264R and a registered office at 3 Tampines Central 1, #02-04 Abacus Plaza, S(529540) . For the purpose of the General Data Protection Regulation ("GDPR"), we are the data controller. Our data protection officer can be contacted at dpo@singaporeair.com.sg. Our representative in the European Union is our establishment in the United Kingdom, Singapore Airlines Limited, a branch registered at Building 11, Chiswick Park, 566 Chiswick High Road, London W4 5YS.
TTT collects, uses and discloses Customer Data (as defined below) in order to provide you with a safe, smooth, efficient and customised experience with TTT. The collection, use and disclosure of Customer Data enables TTT to provide services and products that are most likely to meet your needs and requirements. This Privacy Policy outlines TTT's policy and responsibility in relation to the collection, use and disclosure of Customer Data.
By continuing to use TTT's services, you signify that you have read and understood this Privacy Policy.

SUMMARY

What information do we collect about you?

We collect information when you book hotels or other products on our website, such as your contact details, travel information and credit card details. We also collect information about your preferences from your interactions with our staff, and from specific requests you make.

How will we use the information about you?

We use your information to provide you with different types of service travel arrangements, and to administer your account. We also use your information to maintain our website, and to tailor our products and services to your preferences to provide the best service possible.

Who do we share your information with?

We share your data with our third party service providers to the extent necessary for them to provide their services such as payment processors, hotels and tours. We use these third parties services solely to process or store your information for the purposes described in this policy. We also share your information with related group companies and with government bodies as required by law.

Where do we process your information?

Our servers are located in the United States of America.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of TTT, or as required by relevant laws. We will usually keep your Customer Data for up to 7 years to ensure that any contractual disputes can be addressed. For EU residents, we will endeavour to delete your data within 30 days of a request for erasure or contact you if it will take longer.

How can I exercise my rights over my information?

You may have various rights in relation to your data.

Dispute Resolution

If you have any concerns or complaints, please contact us: sia_holidays@singaporeair.com.sg or +65 – 6506 7733.

How will we notify you of changes?

TTTwill amend this Privacy Policy from time to time and the updated versions will be posted on TTT's Website and date stamped so that you are aware of when the Privacy Policy was last updated. Please check back frequently to see any updates or changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice including by banner on our website.

GENERAL CUSTOMER DATA PRIVACY POLICY STATEMENT

1. THE TYPES OF CUSTOMER DATA WE COLLECT

The types of Customer Data that TTT collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.

There are two broad categories of Customer Data that TTT collects:
1) Personal Data. The data we collect includes but is not limited to:

  • (i) personal information that can be used to identify an individual, such as name, gender, date of birth, passport or other personal identification numbers;
  • (ii) contact information, such as mailing address, phone number and email address;
  • (iii) payment information, such as credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
  • (iv) travel details, such as destinations and dates;
  • (v) your customer preferences, such as dietary, places that you would like to visit or other service preferences;
  • (vi) information about your interactions with our staff, such as the details of any complaint cases, call details, and other information relevant to assist our staff to service you;
  • (vii) health information, such as doctors' notes, medical certificates and letters and requests related to medical conditions;
  • (viii) business contact information, such as the contact details of the employees of our corporate customers.
2) Technical Data. This includes device and technical information you give us when using our website ("Website").
Information on cookies may be found in our cookie policy.
For purposes of this policy statement, Customer Data means Personal Data and Technical Data.
We also use Customer Data to derive Statistical Data, such as the number of customers. This is processed and stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand TTT's customer profile and improve TTT's service offering.

Special categories of information or "sensitive personal data"

Certain categories of Customer Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or "sensitive personal data" under the GDPR.
Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your travel arrangements that reveal or suggest something about you that could be considered "sensitive personal data", or if you otherwise choose to provide such information to us (or a third party such as the travel agent through which you made your booking).

For example:

if you request a particular type of meal, e.g. halal or kosher meals, this may imply or suggest that you are a member of a particular religion; or
if you request specific medical assistance from us and/or an airport operator, e.g. the provision of a wheelchair, this may reveal that you have a particular medical condition.

How we collect data from you

TTT collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised and/or persons who have been validly identified as being your authorised representative (e.g. your organisation's corporate travel manager) pursuant to our then-current security procedures).
TTT also collects Customer Data from third parties which are located in various countries. This includes, but is not limited to, travel agents and our service providers.
Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to TTT has authorised the disclosure, is informed of and agrees to the provisions of this Privacy Policy.

2. IS THE PROVISION OF CUSTOMER DATA REQUIRED?

The collection of the following types of Customer Data is mandatory to enable TTT to fulfil our contract of travel arrangement with you. These types of Customer Data are marked as mandatory on our booking form. If you do not provide this information, we will not be able to provide you with our services and/or products required.

  • Traveller details, e.g title, first/given name, last/family name, date of birth and nationality.
  • Contact details, e.g. email address, mobile phone number, home number or business number.
  • Payment details, e.g. the name on the credit or debit card, the credir or debit card number, expiry date, card verification value and billing address.

2. IS THE PROVISION OF CUSTOMER DATA REQUIRED?

The collection of the following types of Customer Data is mandatory to enable TTT to fulfil our contract of travel arrangement with you. These types of Customer Data are marked as mandatory on our booking form. If you do not provide this information, we will not be able to provide you with our services and/or products required.

  • Traveller details, e.g title, first/given name, last/family name, date of birth and nationality.
  • Contact details, e.g. email address, mobile phone number, home number or business number.
  • Payment details, e.g. the name on the credit or debit card, the credir or debit card number, expiry date, card

3. HOW WE USE YOUR CUSTOMER DATA

If you are an EU resident, we are required to disclose the legal basis for processing your data under the GDPR. We will use the Customer Data in the following ways:
In accordance with our contract with you, we will use the Customer Data to:

  • Process and assist you with any transactions related to your booking (e.g., making a booking, providing services related to the booking (e.g., accommodation, tour, etc), and fulfilling such booking); and
  • Contact details, e.g. email address, mobile phone number, home number or business number.
  • notify you about changes to our service, including through alert messages.
    As it is in our legitimate interests to be responsive to you, to provide customised services and to ensure the proper functioning of our products and organisation, we will use your Customer Data to:
  • Improve the Website and to ensure content from the Website is presented in the most effective manner for you and your device;
  • Administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • Monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
  • send you surveys by email. You can opt-out of receiving these surveys at any time by contacting us;
  • Respond to your enquiries, requests or feedback;
  • Enforce our terms, conditions and policies;
  • Communicate with you;
  • Customise our products and services to you, including by responding to and catering for your customer preferences;
  • Keep the Website safe and secure;
  • Aggregate Customer Data into anonymised statistical data (such as number of customers booked in a particular hotel), which we will use for statistical analysis so that we can better understand TTT's customer profile and improve TTT's service offering; and
  • If you are an employee of an entity with a contractual relationship with us:
    - To contact you to perform our services, and in particular, to monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
    - Enforce our terms and conditions against your employer; and
    - Communicate with you about products, services and other news and information we think will be of interest to you.

4. DISCLOSURE OF YOUR CUSTOMER DATA

TTT will share your Customer Data with selected third parties in the situations set out below:

  • Our travel or travel-related businesses and service providers (including ground personnel, security personnel and providers of accommodation and other tour product, if you elect to use this service);
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and
  • Analytics and search engine providers that assist us in the improvement and optimisation of the Website.
    TTT will share your Customer Data with any member of the Singapore Airlines Group, which includes Singapore Airlines Limited, Scoot Pte. Ltd. and SilkAir (Singapore) Private Limited for the following purposes:
    (a) Fulfill bookings and facilitate flight transfers of travellers;
    (b) Providing an enhanced customer experience and personalising offers to travellers; and
    (c) Understanding customers better through analytics and research (including marketing research) to support personalisation.

TTT will also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.

TTT will disclose your Customer Data to law enforcement agencies, public or regulatory authorities, securities commissions or other organisations for security, customs and immigration purposes, if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- Comply with legal obligation, process or request;
- Enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- Detect, prevent or otherwise address security, fraud or technical issues; or
- Protect the rights, property, health or safety of us, our users, a third party or the public as required or permitted by law (including exchanging Customer Data with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We will also disclose your Customer Data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case Customer Data held by us about our users will be one of the transferred assets; or
- To comply with legal obligations, processes or requests (such as disclosing Customer Data to executors in response to court orders).

In addition, TTT may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. TTT also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entities. Further, TTT will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

5. TRANSFER OF INFORMATION OVERSEAS

The TTT Head Office is based in Singapore. Customer Data will be transmitted to data storage facilities where TTT keeps its central records. Customer Data will be transferred to TTT's offices and appointed agents, including contact centre agents, in Singapore and around the world in connection with TTT's performance of the contract with you.
This means that Customer Data will be transferred to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA"), and in particular to the United States.
We will transfer Customer Data to hotels and other service providers. The Customer Data is transferred outside the EEA on the basis that it is necessary for the performance of the contract of carriage between you and TTT.
If you are an EU resident, where we transfer Customer Data outside the EEA, this done either on the basis that it is necessary for the performance of the contract of carriage between you and TTT, 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 as appropriate.
The Customer Data will also be processed by our business partners. Such partners are engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

6. NON-EU DATA SUBJECT RIGHTS

If you are not a resident in the EU, you may have certain rights in relation to the Customer Data we hold about you, which we detail below.

Access

You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.
Where permitted by law, TTT reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, TTT reserves the right to deny you access to your Customer Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include (to the extent allowable under applicable law) where:
- An investigating authority or government institution objects to TTT complying with a customer's request,
- The information may, in the exercise of TTT's reasonable discretion and/or assessment, affect the life or security of an individual, and
- Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.

Correction

You have the right to correct any Customer Data held about you that is inaccurate.

Feedback and complaints

If you have any concerns, feedback or complaints about the use and/or sharing of your Customer Data, we are open to receiving your feedback or complaints

Exercise of Rights

To exercise any of your rights, please use the Request for Report of Personal Data and submit it to sia_holidays@singaporeair.com.sg.

7. EU DATA SUBJECT RIGHTS

If you are a resident in the EU, you may have certain rights in relation to the Customer Data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.

These rights include:
The right of access.
The right of data portability.
The right of rectification.
The right of erasure.
The right to restrict processing.
The right to object.

Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please use the Request for Report of Personal Data and submit it to sia_holidays@singaporeair.com.sg referencing: Data Subject Rights.

Complaints

In the event that you wish to make a complaint about how we process your Customer Data, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.

Access

You have the right to know whether we process Customer Data about you, and if we do, to access Customer 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 Customer Data we hold about you, we may charge an administration fee. We may not provide you with certain Customer Data if providing it would interfere with another's rights (e.g. where providing the Customer Data we hold about you would reveal information about another person) or where another exemption applies.

Portability

You have the right to receive a subset of the Customer Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Customer Data to another party.
The relevant subset of Customer 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 Customer 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 Customer Data or its processing once received by the third party. We also may not provide you with certain Customer Data if providing it would interfere with another's rights (e.g. where providing the Customer Data we hold about you would reveal information about another person).

Correction

You have the right to correct any Customer Data held about you that is inaccurate. Please note that whilst we assess whether the Customer 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.
To exercise any of your rights, please use the Request for Report of Personal Data and submit it to sia_holidays@singaporeair.com.sg referencing: Data Subject Rights.

Erasure

You may request that we erase the Customer Data we hold about you in the following circumstances:
- You believe that it is no longer necessary for us to hold the Customer Data we hold about you;
- We are processing the Customer 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 Customer Data;
- We are processing the Customer 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 Customer Data;
- You no longer wish us to use the Customer Data we hold about you in order to send you special offers; or
- You believe the Customer Data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing the Customer 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. However, we may retain the Customer 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. Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
Where you have requested that we erase Customer 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 Customer Data or providing links to the Customer Data to erase the Customer Data too.
To exercise any of your rights, please use the Request for Report of Personal Data and submit it to sia_holidays@singaporeair.com.sg referencing: Data Subject Rights.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the Customer Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Customer 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 Customer Data we hold about you where:
- You believe the Customer Data is not accurate for the period it takes for us to verify whether the Customer Data is accurate;
- We wish to erase the Customer Data as the processing we are doing is unlawful but you want us to just store it instead;
- We wish to erase the Customer 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 Customer Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Customer Data whilst we determine whether there is an overriding interest in us retaining such Customer Data.

Objection

At any time you have the right to object to our processing of Customer Data about you in order to send you special offers and we will stop processing the Customer Data for that purpose.
You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below by using the Request for Report of Personal Data and submitting it to sia_holidays@singaporeair.com.sg referencing: Data Subject Rights.
You may object where we are processing the Customer 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 Customer Data whilst we make the assessment on an overriding interest by indicating this in our Request for Report of Personal Data.

8. RETENTION

TTT will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of SIA, or as required by relevant laws. We will usually keep your Customer Data for up to 7 years to ensure that any contractual disputes can be addressed.

9. ACCURACY

TTT needs your assistance to ensure that your Customer Data is current, complete and accurate. As such, please inform TTT of changes to your Customer Data by contacting TTT and submitting your updated particulars to TTT in writing (see Section 14).

10. SECURITY SAFEGUARDS

TTT takes the protection of your Customer Data seriously but, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Customer Data, we cannot guarantee the security of your Customer Data transmitted through the Website; any transmission is at your own risk.

11. LINKS TO OTHER WEBSITES

TTT may, from time to time, provide you with links to other websites for your convenience and information. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You access these websites at your own risk and TTT is not responsible for these websites. Whilst TTT will protect your Customer Data on TTT Website, TTT cannot control or be responsible for the policies of other sites we may link to, or the use of any Customer Data you may share with them. Please note that the TTT Privacy Policy does not cover these other websites, and TTT would recommend that you are apprised of their specific policies.

12. MINORS

TTT's Website is not directed at children under the age of 16 and TTT cannot distinguish the age of persons who access and use its Website. If a minor (according to applicable laws) has provided TTT with Customer Data without parental or guardian consent, the parent or guardian should contact TTT (see Section 14) to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 16 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor's account.

13. UPDATES TO THE PRIVACY POLICY

TTT will amend this Privacy Policy from time to time, and the updated versions will be posted on TTT's Website and date stamped so that you are aware of when the Privacy Policy was last updated. Please check back frequently to see any updates or changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice including by way of a banner on our website. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language.

14. CONTACT US

If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact TTT in writing at the address below referencing 'Privacy Policy'
DPO
Singapore Airlines DPO
08D Airline House
25 Airline Road
Singapore 819829
Or email dpo@singaporeair.com.sg referencing: Privacy Policy.