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East West Planners Pte Ltd Privacy Policy

  1. Introduction

East West Planners Pte Ltd (“EAST WEST PLANNERS”, ”we”, “our” or “us”) is committed to respecting your privacy.

We are a corporation registered in the Republic of Singapore with company number 201218537G and a registered office at 15 Queen Street, #03-03 Tan Chong Tower, Singapore 188537.

We collect Personal Data about our customers, partners and other interest groups of East West Planners (where they are natural persons, or, of their employees, agents and representatives), about the users of our website, and about the individuals that attend any events (including any training, courses and programmes) organized by us (and these individuals about whom we collect Personal Data shall herein be referred to as “you” in this Privacy Policy).

The collection of data, use and disclosure of Personal Data (as defined below) is for the purpose of providing you with a safe, smooth, efficient and customised experience with East West Planners based on your needs and requirements. This Privacy Policy outlines East West Planners’ policy and responsibility in relation to the collection, use and disclosure of Personal Data.

  1. About this Policy

This Privacy Policy (“Policy”) sets out the essential details relating to your personal data relationship with East West Planners and applies to all East West Planners services and any associated Services (“Services”).

In this Policy, we set out how we collect Personal Data about consumers (including travel advisors), what Personal Data we collect, how we use it, and what rights you have in relation to our processing of your Personal Data.

For the purposes of this Policy, “Personal Data” refers to any information, whether true or not, relating to an identified or identifiable natural person.

Kindly note that, from time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data, we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

  1. Who is the data controller/data processor

The identity of the data controller of the personal information we hold about you will depend on whether you are engaging us directly or if we are processing your Personal Data in the course of our engagement with a third party (e.g. travel advisors).

  1. How do we collect Personal Data

Depending on the nature of your interaction with us, we use different methods to collect Personal Data from and about you, including and without limitation through:

a. Direct Interactions

We may collect your Personal Data through our direct interactions with you, including Personal Data you may provide when you:

  1. register, request and/or engage us for and in relation to any of our Services, whether in writing, orally or through our website;
  2. use any of our Services;
  3. interact with us in relation to our Services (including any queries, surveys, questionnaires, feedback, etc.)
  4. request or register for marketing being sent to you (including news, information, promotions, updates, etc.); and/or
  5. submit your Personal Data to us for any other reason, whether voluntarily or otherwise.
b. Automated Interactions

We may collect your Personal Data automatically in the following situations:

  1. when you access our website, submit information through our website and/or your browser loads our internet cookies; and/or
  2. when your image is captured by us through CCTV recordings while you are within our premises, or through photographs, videos and/or audio recordings taken by us or our representatives when you participate in any of our events or activities.
c. Third Parties

We may collect your Personal Data from third parties that we work with (e.g. vendors and partners) for the provision of our Services, including when:

  1. we receive references from business partners and third parties, including where you have been referred by them;
  2. we seek information from third parties about you in connection with the Services you have applied for or have engaged us for; and/or
  3. your Personal Data is in publicly available sources.

Where your Personal Data is collected from third parties, we will only use such Personal Data either where you have provided your consent to the third party or to East West Planners to the sharing of your Personal Data or where East West Planners has a legitimate interest to use the Personal Data in order to provide you with our Services.

  1. What Personal Data do we collect

Generally, we may collect, use, process, store and transfer different kinds of Personal Data about you, including the following:

Categories of Personal Data

Description

Registration Data

We collect Personal Data when you register, request and/or engage us for and in relation to any of our Services, including:

  • Identification information (e.g. title, first/given name, last/family name, date of birth, identification/passport number);
  • Contact information (e.g. email address, mobile number, business number);
  • Business information; and/or
  • Employment information.

While some of the Personal Data we ask for may be mandatory in order to register or engage us for our Services, you will also have the option to provide us with additional Personal Data to allow us to provide you with more personalized Services.

Service Usage Data

We collect Personal Data through your use of our Services in order to operate, maintain and provide you with these Services, including:

  • Identification information;
  • Contact information;
  • Business information;
  • Employment information;
  • Information relating to the use of our website; and/or
  • Information about how you use our Services.

Third Party Data

We may receive or collect Personal Data about you from third parties (e.g. travel advisors, customers, clients, publicly available sources, service providers) from time to time.

Payment Data

We collect payment information when you register or engage us in for or in relation to any of our Services to facilitate any transactions made in connection with the provision of the Services.

While the exact Personal Data we may collect may vary depending on the Service being provided or the payment method, such payment information will include:

  • Name;
  • Date of Birth;
  • Credit card or debit card details;
  • Bank account details;
  • Address;
  • Contact number; and/or
  • Transaction details and history.

Marketing Data

We may collect Personal Data in relation to our marketing efforts (e.g. promotions, updates, newsletters), including:

  • Identification information;
  • Contact information; and/or
  • Any information that enables us to personalize our marketing material.

Usage Data

We may collect information about how you use our website, products and services including:

  • Aggregated Data such as statistical or demographic data for any purpose.

Aggregated Data may be derived from your Personal Data but is not considered personal data in law as this data is not directly or indirectly reveal your identity (e.g. calculate the percentage of users accessing a specific website feature)
  1. How do we use your Personal Data

We may process your Personal Data for more than one legal basis, depending on the specific purpose for which we are using your Personal Data.

For ease of reference, we have set out below a brief, non-exhaustive description of our processing purpose, the categories of Personal Data that will be processed and the legal bases we rely on. Where applicable, we have also identified our specific legitimate interests. 

Processing Purpose

Categories of Personal Data for the Processing Purpose

Legal Basis for Processing

To manage our relationship with you and facilitate the provision of our Services
  • Registration Data
  • Service Usage Data
  • Third Party Data
  • Marketing Data
  • Necessary for the performance of a contract and/or to take steps at your request prior to entering into a contract
  • Necessary for our legitimate interest (administering the Services)

To communicate with you for any purposes related to our provision of the Services
  • Registration Data
  • Service Usage Data
  • Third Party Data
  • Necessary for the performance of a contract and/or to take steps at your request prior to entering into a contract
  • Necessary for our legitimate interest (administering the Services and communicating with individuals in connection with the provision of the Services)
  • Necessary to comply with a legal obligation

To provide, personalize and improve the Services we provide to you
  • Registration Data
  • Service Usage Data
  • Third Party Data
  • Marketing Data
  • Necessary for the performance of a contract and/or to take steps at your request prior to entering into a contract
  • Necessary for our legitimate interest (tailor our Services to our customers and improve in the provision of our Services)
  • Consent

To administer and protect our business (e.g. maintenance of our systems, troubleshooting, preventing or detecting crime, analyzing commercial risks)
  • Registration Data
  • Service Usage Data
  • Third Party Data
  • Necessary for our legitimate interest (for running our business and provision of any services, including to prevent cyber risks or fraud)
  • Necessary to comply with a legal obligation

To process your payment
  • Payment Data
  • Necessary for the performance of a contract and/or to take steps at your request prior to entering into a contract
  • Necessary for our legitimate interest (administering the Services and preventing fraud)

To provide suggestions and recommendations to you based on your preferences
  • Marketing Data
  • Necessary for our legitimate interest (to develop our business and improve on our Services)
  • Consent

To verify the identification of individuals who may contact us from time to time
  • Registration Data
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interest (to prevent fraud)

To manage our administrative and business operations and complying with internal policies and procedures
  • Registration Data
  • Service Usage Data
  • Third Party Data
  • Necessary for our legitimate interest (to prevent fraud, and to ensure compliance with regulations, laws, standards and professional obligations)

Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our Services to you or respond to your other requests.

If you wish to seek further clarification in relation to our legal bases for processing your Personal Data, do feel free to contact us at info@eastwestplanners.com.

  1. Disclosing your Personal Data

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We share the personal information we obtain with third parties who perform services on our behalf, such as hotel, transport companies, restaurant and third party vendors.

We may share your Personal Data with the following parties:

Parties

Reason for Sharing

Service Providers

We may engage third party vendors or service providers that we need to provide our Services, including:

  • Hosting services
  • Mailing services
  • Accounting services
  • Payment processing services
  • Fraud prevention
  • IT services
  • Data analytics
  • Marketing services
  • Research services

Our Affiliates or Partners

We may share your Personal Data with East West Planners affiliates or partners in order to facilitate our business operations and the provision of our Services to you.

Regulatory or Supervisory Authorities

We may share your Personal Data if we, in good faith, reasonably believe that such action is necessary to comply with the law, respond to requests from a regulatory or supervisory authority, uphold national security, protect the safety of any person, and/or facilitate any litigation or criminal investigation.
  1. Data Protection and Retention
a. Protection and Security

As part of our commitment to protecting your privacy, we implement appropriate technical and organization measures to protect your Personal Data against accidental, unauthorized or unlawful use, disclosure, access, destruction, loss, change or damage. Some of the measures we have taken include pseudonymization, encryption, limited access and robust retention policies.

Nevertheless, do note that while we will endeavor to take all reasonable measure to protect your Personal Data, you should similarly take all necessary precautions, such as implementing strong passwords, limiting access to your computer and avoiding misplacing any documents or access passes.

b. Retention

We keep your Personal Data only for as long as necessary to provide you with the Services, to fulfil our processing purposes, in accordance with our legal obligations and for legitimate business purposes.

The retention period for your Personal Data may vary based on the specific circumstances. Nevertheless, in determining the appropriate period to lawfully retain your Personal Data, we will consider inter alia, the following factors:

  1. Amount of Personal Data;
  2. Nature and sensitivity of the Personal Data;
  3. Risks from accidental, unauthorized or unlawful use or disclosure; and
  4. Necessity of the Personal Data for the processing purposes.

If you withdraw your consent (where we rely on consent as our legal basis) or object to our processing of your Personal Data, you may at any time request that we erase or delete your Personal Data. Upon receipt of such request, we shall, within a reasonable time, delete or anonymize your Personal Data unless we are legally permitted or required to retain such Personal Data (e.g. ongoing dispute, tax or obligations, accounting purposes, compliance with any legal obligations).

If you wish to seek further clarification in relation to the retention of your Personal Data, do feel free to contact us at info@eastwestplanners.com.

  1. Transfer to other countries

In the provision of our Services, the Personal Data we collect may be transferred to and processed by third parties in other countries. In all such instances, East West Planners shall ensure that the transfer of your Personal Data is carried out in accordance with any applicable laws and that appropriate safeguards (e.g. contractual, technical and organizational measures) are put in place before such transfer takes place.

If you wish to seek further clarification in relation to the safeguards being implemented for the transfer of your Personal Data, do feel free to contact us at info@eastwestplanners.com.

  1. Use of Cookies and Website
a. Cookies

Our website uses cookies in order to facilitate your experience when browsing our website and accessing any of our online pages.

For the purposes of this Policy, a “cookie” is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser.

East West Planners uses cookies which are necessary for the functioning and operation of our website. In addition, we may also use cookies that allow us to track, record and analyze data in relation to the activity on our website, or that allow us to recognize you whenever you return to our website for us to customize your browsing experience based on our preferences.

If you wish not to receive cookies, kindly change your cookie setting in your browser under the “options” or “preferences” tool selection.

Please note that if you choose not to receive cookies, we may not be able to provide you with the full functionality of our website.  

b. Website

In addition, when you visit our website, we obtain certain information by automated means, such as through the use of cookies, web server logs and web beacons. The information collected in this manner includes IP addresses, operating systems type, browser type, domain and other system settings. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

Our websites may contain links to other websites for your convenience and information. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

  1. How to Access & Control your Personal Data

We offer you certain choices in connection with the personal information we obtain from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified in the Contact Us section of this Privacy Policy.  You may unsubscribe from receiving future marketing and promotional emails by clicking on the unsubscribe link provided in our emails.  We may still contact you to respond to an inquiry and for certain account-related or transactional purposes.

Individuals are given rights in relation to their Personal Data pursuant to the applicable law. In general, the rights afforded to individuals are:

a. Right to Access

The right to be informed of and request access to the Personal Data that we process about you. This will enable you to check what Personal Data we are processing and whether the processing is lawful.

b. Right of Correction/Rectification

The right to request that we amend or update your Personal Data where it is inaccurate or incomplete. Kindly note that while we shall make a reasonable effort to ensure that the Personal Data we collect is accurate and complete, you are responsible for ensuring the accuracy of the Personal Data that you provide to us directly.

For individuals who are covered by the GDPR, they will also be afforded the following rights (as available and subject to any applicable law):

a. Right to Erasure

The right to request that we temporarily or permanently stop processing all or some of your Personal Data.

b. Right to Object

The right to object to your Personal Data being processed by us for direct marketing purposes, or to, at any time, object to us processing your Personal Data on grounds relating to your particular situation

c. Right to Data Portability

The right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service.

d. Right not to be subject to Automated Decision-making

The right to not be subject to a decision based solely on automated decision-making where the decision would have a legal effect on you or produce a similarly significant effect.

If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection at no cost. The electronic marketing messages you receive from East West Planners (e.g. email updates) will also include an “unsubscribe” option within the message itself to enable you to manage your Personal Data.

Additionally, you have the right at any time to lodge a complaint with your local Data Protection Authority if you are unhappy with the way in which we are using your Personal Data.

In order to enable you to exercise these rights with ease and to record your preferences in relation to how East West Planners uses your Personal Data, you may manage your privacy preferences at any time by contacting us at info@eastwestplanners.com.

  1. Changes to this Policy

We may update this Policy from time to time.

When we make any material changes to the Policy, we will provide you with notice as appropriate under the circumstances of such change, including by displaying the notice within our website or by sending you an email. Additionally, you may also wish to refer to the “last modified” date at the end of this Policy.

  1. Contact Us

If you have any questions about your privacy, your privacy rights, or how to exercise them, please feel free to contact us at info@eastwestplanners.com.

We will respond to your request within a reasonable period of time upon verification of your identity.

Last Modified: 25 May 2018