The Personal Data Protection Act (“PDPA”) is the principal data protection law in Singapore governing the collection, use, disclosure and care of personal data. We are committed to comply with the PDPA provisions and other applicable data protection laws in Singapore in our collection, use and disclosure of personal data.
This Policy supplements but does not supersede nor replace any other consent you may have previously provided to New Shan Travel with respect to the contents of your Personal Information, and your consents herein are additional to any rights reserved by New Shan Travel may have at law to collect, use or disclose your Personal Information. This Policy supplements our Terms & Conditions (“Terms”) and may be changed at any time and without prior notice.
1.1. This Policy statement provides information on our obligations and policies in respect of an individual User’s Personal Data. We undertake to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2. Our officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, us. We shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by us shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3. By interacting with us, submitting information to us, or signing up for any products and/or services offered by us, you agree and consent to us as well as to our respective representatives and/or agents (“Representatives“) (collectively referred to herein as “New Shan“, “us“, “we” or “our“) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Policy.
1.4. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5. For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual User who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in our possession or that which shall be collected by us in future.
2. Purposes for Collection, Use, Disclosure and Processing of Personal Data
2.1. The purposes for which we collect your personal data is related to the provision of personal travel, business travel, and meeting and events services, such as but not limited to:
- Processing travel, transportation and hospitality bookings;
- Meeting and events booking including the provision of badges and stationery;
- Website account details (including user login identification and password);
- Responding to travel enquiries;
- Providing customer support and/or technical assistance;
- Catering and audio-visual services;
- Visa application assistance;
- CCTV recordings when you visit our premises or photo taking or video recording at events;
- Account administration and billing (including processing fees and payment);
- Travel client policy compliance and expense consolidation reporting;
- Communication of essential travel information;
- Receiving information about you from third party social networking services when you choose to connect with those services;
- Internal marketing analysis;
- Conducting market research and client surveys to enhance the provision of our services.
We also collect personal data for the purposes of marketing products and/or services which you may be interested in, monitoring the performance of our marketing effort, internal job training, and informing you of new developments and services of New Shan Travel and other third parties which we are associated with.
2.2. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
3. Collection of Personal Data
3.1. In the course of booking with us, we would have obtained your personal data either via phone, email, and website or in person; there may be occasions when we collect your personal data from a third party. This happens when another person makes travel bookings on your behalf, such as but not limited to the case of a designated travel arranger booking a business trip on behalf of his/her assigned traveller.
3.2. As part of its day-to-day activity, New Shan Travel may collect from you, through various means, including via our websites and/or online travel platform, marketing events (e.g. road shows) and any forms used by New Shan Travel from time to time, some or all of the following Personal Data:
- Name (first and surname);
- Postal address;
- Company name;
- Company address;
- Phone number (including mobile);
- Office number;
- Email address;
- Bank account/credit card details;
- Personal Data of your emergency contacts;
- Travel and booking details (including Passenger Name Record);
- Frequent flyer details or flight membership details;
- Health issues;
- Dietary requirements;
- Travel preferences where expressed (including seats, meals, and special assistance);
- Photographs and images
- Storage and Retention of Personal Data
New Shan Travel retains Personal Data as needed to provide our products and/or services, respond to enquiries, comply with our legal obligations, and meet our regulatory agreements.
We will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of New Shan Travel and where the Personal Data is deleted from New Shan Travel’s electronic, manual, and other filing systems it is in accordance with New Shan Travel’s internal procedures and/or other agreements.
4. Data Confidentiality
We will not disclose, share, transfer, sell or rent any of your Personal Data to any third party. We do not send unsolicited marketing emails to our customers. We ensure all information is accurate and up-to-date, and only authorised staff have access to our systems
5. Specific Issues for the Disclosure of Personal Data to Third Parties
5.1. We respect the confidentiality of the Personal Data you have provided to us. In that regard, we will not disclose your Personal Data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your Personal Data between our brands, subsidiaries, related corporations, affiliates and agents.
We will not disclose your Personal Data to other third parties without first obtaining your consent in certain situations, including, without limitation, the following:
- Cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
- Cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
- Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
- Cases in which the disclosure is necessary for any investigation or proceedings;
- Cases in which the Personal Data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the Personal Data is necessary for the purposes of the functions or duties of the officer;
- Cases in which disclosure is required by credit, debit and charge card companies, banks and other entities processing payment;
- Cases in which potential buyers or investors of our company require your personal data;
- Cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
- Where such disclosure without your consent is permitted by the PDPA or by law.
5.2. To make travel and hospitality reservations, and in line with travel industry practices, we may share specific Personal Data with our strategic partners that work for us to provide services. Examples include but are not limited to:
- Service providers who provide services such as payment processing, data storage, hosting, insurance related services, information processing, analytics, marketing, research, and other service providers who enable specific features and functionalities of the products and/or services you have requested.
- Travel suppliers such as airlines, General Distribution Systems (GDS), hotels, property owners, cruise lines, rail providers, insurance providers, car rental providers, ground transportation providers, tour operators, online travel agencies, and intermediaries who will fulfil your travel reservations.
- Service administrators employed within an organisation, which engages our business travel services. Your employer’s service administrator’s use of our services shall be deemed as authorisation of and consent to your employer’s access to and disclosure of your Personal Data in accordance with their internal policy. Please refer to your organisation’s internal policy if you have questions about this.
- In some instances, you may be requested to provide certain Personal Data that may be used to further improve New Shan Travel’s products and/or services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service dependent on your providing all requested data, failure to provide the requested data may prevent New Shan Travel from providing the service to you.
5.3. The instances listed above are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at statutes.agc.gov.sg.
5.4. The instances listed above are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at statutes.agc.gov.sg.
6. Accuracy of Personal Data
Where possible, New Shan Travel will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, New Shan Travel can validate the data provided against pre-existing data held by New Shan Travel. In some cases, New Shan Travel is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of New Shan Travel, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the Data Protection Officer at the email address provided at Section 14.2.
7. Transfer of Personal Data Overseas
Your Personal Data may be processed by New Shan Travel, its subsidiaries, related corporations, affiliates, agents and third parties providing services to New Shan Travel, in jurisdictions outside of Singapore. In this event, New Shan Travel will comply with the terms of the Act.
8. Request to Withdraw Consent
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to the email address provided in Clause 14.2. We will process your request within a reasonable timeframe from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
9. Automated Data Collection
9.1. Google Analytics
Our website and/or online travel platform may contain web analytic services provided by Google Analytics. This means that when you visit our website and/or online travel platform, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies. Google Analytics acts as our agent, which means that we solely determine the purposes for which the data is being used.
9.2. Web Cookies
- To improve your user experience on this website;
- To remember your preferences;
- To help us understand how this website is performing;
- To monitor traffic to the website;
- To enable this website and/or online travel platform to function properly.
10. Protection of Your Personal Data
New Shan Travel uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside New Shan Travel, other than to you or as described in this Policy. However, New Shan Travel cannot ensure or warrant the security of any information you transmit to New Shan Travel and you do so entirely at your own risk. In particular, New Shan Travel does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of New Shan Travel’s physical, technical, or managerial safeguards.
We reserve the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by us. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will review and update our policies, procedures and processes from time to time. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
12. Contacting You
To the extent that any of the communication means which you have provided New Shan Travel with (which may include, your telephone number) is/will be listed on the Do Not Call Registry (the “DNC”), by checking the box on the Consent Form, or by any other means of indication, you hereby grant New Shan Travel your clear and unambiguous consent to contact you using all of your communication means you have provided to New Shan Travel including using via voice calls, SMS, WhatsApp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Clause 2.1. This will ensure your continued enjoyment of New Shan Travel’s services.
13. Contacting the Data Protection Officer
13.1. Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of New Shan Travel, we shall provide and/or correct that data within thirty (30) days and in a manner in accordance with its standard procedures as stated hereinafter.
13.2. In accordance with the Act, New Shan Travel has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that New Shan Travel receives your complaints and enquiries, and for the purpose of withdrawing your consent for the collection, use and/or disclosure of your Personal Data in our possession, you can contact us at the following:
The Office of the Data Protection Officer
New Shan Travel Service Pte. Ltd.
20 Maxwell Road,
#01-02 Maxwell House
13.3. Please note that if your Personal Data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to New Shan Travel on your behalf.
13.4. Should you not wish for New Shan Travel to use your Personal Data for any of the purposes listed in Clause 2.1, or not to receive promotional materials from New Shan Travel, you may opt-out by sending a clearly worded email to the DPO via the email address provided in Clause 14.2. Your request shall be processed within thirty (30) days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.
14.1 This Policy only applies to the collection and use of Personal Data by New Shan Travel. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. New Shan Travel does not share your Personal Data with third party websites. New Shan Travel is not responsible for the privacy and conduct practices of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
14.2 New Shan Travel will not sell your Personal Data to any third party without your permission, but we cannot be responsible or held liable for the actions of third-party sites which you may have linked or been directed to New Shan Travel’s website.
14.3 New Shan Travel’s websites do not target and are not intended to attract children under the age of 18 years old. New Shan Travel does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.
15. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts. For more information about the Singapore Personal Data Protection Act, please visit http://www.pdpc.gov.sg.