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.
In this Personal Data Protection Policy, “Personal Data” refers to any data, whether or not true 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;
- 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.Purpose of and Legal Basis for Processing Personal Data
We process Personal Data based on your consent for:
- carrying out data analytics and tracking;
- conducting market research and surveys; and
- conducting marketing and/or promotional campaigns.
You have the right to withdraw your consent at any time.
When we knowingly process Personal Data of a child under sixteen (16), we will seek the consent of parents, tutors, or other adults holding parental responsibility over the child, if required under the applicable law.
Information such as health or religion (including your allergies, disabilities, and other relevant health information) might be necessary to arrange bookings. We collect and use it to provide you with our services, cater to your needs, or act in your interest. We only accept such sensitive Personal Data on the condition that we have your explicit consent.
We also process Personal Data to fulfil contractual obligations for:
- providing our services (e.g., making arrangements for travelling, booking accommodations and/or tours, user account);
- responding to your queries and requests and contacting you for customer service, if necessary;
- administering and processing any applicable insurance claims and payments; and
- processing of payment instructions, direct debit facilities and/or credit facilities;
We process Personal Data for the purposes of our legitimate interests for:
- improving our products, services, benefits and website;
- 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;
- 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.
If we collect and use your Personal Data in reliance on our legitimate interests (or the legitimate interests of any third party), this interest will typically be to operate or improve our services and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us, to respond to your queries or for the purposes of potentially detecting or preventing illegal activities.
We will not use Personal Data for purposes which we are not permitted to or required under local law and regulations.
If you fail to provide your Personal Data, we might be unable to maintain our relationship with you or provide our services to you to the extent that such Personal Data are necessary to maintain the relationship or to provide the services.
In some cases, we may use automated decision-making. For example, to assessing fraudulent transactions or suspicious activity on our site, automated decisions may be made by putting your Personal Data into a system and calculating the decision using automatic processes. If you pose a fraud risk, this may affect your ability to book on our site. You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or to contest a decision based solely on automated processing.
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 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.
You have the following rights:
- Access to your Personal Data
- Rectification of your Personal Data
- Erasure of your Personal Data
- Restriction on processing of your Personal Data
- Objection to processing of your Personal Data
- Portability of your Personal Data
- Request information about the logic involved in our automated decision-making that is used in our fraud prevention practices, and the result of such decisions
- Objection to our disclosure of your Personal Data
- Request information about the purpose of the processing activities
- Request information about records that are made when sharing your Personal Data with a third party or receiving your Personal Data from a third party
- Opt out of the sale of your Personal Data
- Complain to a data protection authority about our collection and use of your Personal Data.
To exercise your rights, or if you require further information about how your Personal Data is used by us, you can contact us here.
8.International data transfer
The Personal Data that we process may be transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country.
Time Design operates in Singapore and Japan, and third-party service providers or travel suppliers operate in many countries around the world. When we collect your Personal Data, it may be transferred and processed in any of those countries. Japan has the adequacy decision by the European Commission under Article 45 of GDPR.
We have taken appropriate steps and put safeguards in place to help ensure that your Personal Data remains protected. We protect the Personal Data that they process in accordance with applicable data protection law.
We also require that third-party service providers or travel suppliers to whom data transfers are made have appropriate safeguards in place to protect your Personal Data, in compliance with applicable data protection law.
9.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 is 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.
10.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.
11.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 write to the Data Protection Officer (whose contact is set out below).
12.How to contact us
Please feel free to contact our Data Protection Officer here.
You can also contact us by writing to the following address:
Time Design International Pte Ltd.
Attention: Data Protection Officer
FOUND8 1 NORTH BRIDGE ROAD, #08-08 HIGH STREET CENTRE, SINGAPORE 179094
13.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.
This Data Protection Policy shall be governed in all respects by the laws of Singapore.
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