Personal Data Protection Policy

1. Overview

We, Time Design International Pte. Ltd. (“Time Design”) are committed to ensuring the safety and security of personal data. We only collect such personal data that is necessary for us to provide you with the services that you have requested, understand your needs, and serve you better as a whole.

The purpose of this document, Time Design’s Personal Data Protection Policy, is to inform you as to how Time Design manages, collects, uses and discloses personal data. In Singapore, such business activities are subject to the Personal Data Protection Act (No. 26 of 2012) (the “PDPA”). We conduct our business in compliance with the PDPA and have implemented various measures to ensure that any personal data relating to you remains safe and secure.

2. Personal Data

In this Personal Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data, or 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.

3. Collection of Personal Data

The Personal Data that Time Design may collect may include an individual’s name, age, gender, nationality, email address, phone number, date of birth, passport/identification card number, passport expiry date, passport issuing country, emergency contact information,  travel preferences, loyalty or frequent flyer information, and any other Personal Data necessary for Time Design to provide its services.

Typically, Time Design will collect Personal Data relating to you when you:

• visit our website;
• use our mobile or web-based applications;
• register for our services and/or submit any forms relating to our products and services to us;
• use or engage our services;
• sign up for alerts or newsletters;
• contact us with enquiries or requests for assistance; or
• are referred to us by business partners or third parties.

In particular, please note that Personal Data relating to you may be collected by automated technologies when you visit our website and/or our web-based applications. Such technologies include

• click-stream data;
• cookies;
• flash cookies;
• web beacons and tracking links;
• web analytics;

and shall collect data including a visitor’s IP address, the pages visited on our website, the date and time of the visit, the referral website, and information about the visitor’s browser.

Further, apart from collecting Personal Data directly from you, Time Design may also collect your Personal Data from third parties (e.g. affiliated entities, business partners, your use of social media sites, social media applications or third party websites and applications that interact with Time Design) or from publicly available sources.

4. Use of Personal Data

We may use Personal Data for:

• providing our services (e.g. making arrangements for travelling, booking accommodations and/or tours);
• responding to your queries and requests and contacting you for customer service, if necessary;
• improving our products, services, benefits and website;
• carrying out data analytics and tracking;
• conducting market research and surveys;
• conducting marketing and/or promotional campaigns;
• administering and processing any applicable insurance claims and payments;
• tailoring and customising your browsing experience and/or advertising on our website;
• managing our administrative and business operations;
• enforcing obligations owed to Time Design;
• performing internal audits;
• accounting, security and risk management purposes;
• processing of payment instructions, direct debit facilities and/or credit facilities;
• legal, regulatory and other compliance requirements (including providing assistance to law enforcement, judicial, regulatory or other government agencies and statutory bodies); and
• other work and business related requirements.

We will not use Personal Data for purposes which we are not permitted to or required under local law and regulations.

5. Disclosure of Personal Data

We may share and disclose Personal Data with:

• Companies affiliated with and/or related to Time Design in Singapore, Japan and other countries;
• Suppliers, such as such as hotel, airline, car rental, insurance companies;
• Partners, licensors, vendors, agents, contractors or third party service providers who provide services to Time Design including but not limited to insurance, consultancy, courier services, telecommunications, IT, payment, printing, billing, payroll processing, technical services, training, business analytics, data analytics, market research, call centre, security or other such services to Time Design;
• Partners, licensors, vendors, agents, contractors or third party service providers who provide operational services for and on behalf of Time Design; and
• Any relevant government regulators, statutory boards or authorities or law enforcement agencies as required by any laws, rules, guidelines and regulations or schemes imposed by any government to bodies and authorities. 

In the event of an actual or prospective business asset transaction (such as any merger, acquisition or asset sale), we may share and disclose your Personal Data with or to any business partner, investor, assignee, or transferee for the purposes of facilitating such a transaction.

Personal Data is disclosed to the above-mentioned parties only for relevant purposes (please refer to those mentioned in this Policy) or to protect the individual’s interests.

In exceptional circumstances, Time Design may also be required to disclose Personal Data, where there are grounds to believe that disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes.

In some cases, we shall encrypt, anonymize, and aggregate Personal Data before sharing or disclosing it. Anonymizing means stripping the information of personally identifiable features. Aggregating means presenting the information in groups or segments (e.g. age groups).

We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations.

6. Accuracy and Updating of Personal Data

Time Design will strive to keep Personal Data accurate. You will be given the ability to review and update your Personal Data that we have in our possession.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct

Further, when you provide us with any Personal Data relating to a third party (including your spouse, children and/or parents), you represent to us that you have obtained the consent of the relevant third party to provide us with their Personal Data unless otherwise provided in the PDPA.

If there is any Personal Data relating to you that you are unable to update and which you wish to make corrections to, you may contact our Data Protection Officer (whose contact details are set out below) and we will be happy to help you as best as we can.

7. Access to Personal Data and Respecting Individual’s Consent

If you wish to access the Personal Data that we have relating to you, inquire about the way in which Personal Data relating to you has been used or disclosed by Time Design in the past year, or wish to withdraw your consent to our use of such Personal Data, you may contact our Data Protection Officer (whose contact is set out below) and we will seek to attend to your request as best as we reasonably can. Please note that:

• in order for us to provide any Personal Data we will need to verify your identity and may request further information about your request;
• we may refuse access to your Personal Data if it would affect the privacy rights of other persons or if it breaches any confidentiality that attaches to that information;
• we may also refuse your request where we are legally permitted to do so and give you such reasons;
• we should be aware that we may take a reasonable time to process your application for access as we may need to retrieve Personal Data from storage and review the information in order to determine what information may be provided; and
• kindly note that we may have to charge you a reasonable administrative fee for retrieving Personal Data relating to you.

8. Security of Personal Data

Safeguarding and respecting the confidentiality of Personal Data is important to Time Design. We will use our best efforts to protect Personal Data.

The Personal Data provided to us are stored on secure servers. Time Design also has security measures in place to protect against unauthorized access, loss, misuse and alteration of Personal Data under our control. However, please note that we will not be held liable or responsible for any loss, misuse or alteration of Personal Data that may be caused by third parties.

9. Retention of Personal Data

We will only retain Personal Data for only as long as there is a business or legal need.

In the event that retention of Personal Data is no longer necessary for any business or legal purposes or when the purpose for which the Personal Data was collected is no longer being served by the retention of the Personal Data, Time Design will remove, destroy or anonymise the Personal Data.

10. Disclosure of Personal Data Policy

If you believe that we have breached this Personal Data Protection Policy, or any other applicable privacy or data protection laws or regulations which may apply to Time Design, you should make a complaint to Time Design in the first instance. You should address your complaint in writing to our Data Protection Officer (whose contact details are set out below), and you should include as much detail as you can about the Personal Data affected, and the circumstances that you believe amount to a breach of this Personal Data Protection Policy or the applicable privacy or data protection law or regulation.

If you have any questions about our Personal Data Protection Policy or concerns about our commitment to your privacy, please feel free to email or write to the Data Protection Officer (whose contact is set out below).

11. How to contact us

Please feel free to contact our Data Protection Officer at [e-mail].

12. Changes to the Personal Data Protection Policy

Time Design reserves the right to modify and update this Personal Data Protection Policy at any time to ensure it is consistent with industry trends and/or any changes in legal or regulatory requirements.

13. Governing Law

This Data Protection Policy shall be governed in all respects by the laws of Singapore.