Privacy Policy for Jetbay Air Charter Services Pte. Ltd.
This privacy policy (“Privacy Policy”) describes how Jetbay Air Charter Services Pte. Ltd. ("JETBAY"), operating at CapitaGreen #24-53, 138 Market Street, Singapore 048946, manages Personal Data (as defined below) in compliance with the Singapore Personal Data Protection Act 2012 (“Act”). We encourage you to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
1. Application of this Privacy Policy
1.1. "Personal Data" refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which we may have access or are likely to have access and includes the definition in the Act as amended from time to time (“Personal Data”).
1.2. “Usage Data” refers to data collected automatically, either generated by the use of the website or from the website infrastructure itself. Usage Data may include information such as your IP address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data (“Usage Data”).
1.3. By accessing or using the website of JETBAY, signing up for or using any products, services, or campaigns offered by JETBAY or submitting information to or otherwise communicating with JETBAY, you agree and consent to JETBAY and our related entities, affiliates, and subsidiaries (individually and collectively, "Companies"), as well as their respective representatives and/or agents (collectively referred to herein as "JETBAY", "us", "we" or "our") collecting, using, and disclosing your Personal Data, Usage Data or such data as set out in Clause 8 in accordance with this Privacy Policy . “You” or “your” means any individual to whom the Act applies and includes an individual actual or prospective customer who is an individual but excludes any corporate entity (including corporate customers) and any other entity that is excluded under the Act.
1.4. This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other circumstances under which any of the Companies are permitted at law to collect, use, or disclose your Personal Data.
1.5. Please note that this website, and our products, services, and campaigns are not directed at any data subjects in the European Union.
1.6. This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.
2. Collection & Consent
2.1. Personal Data may be collected from you in one or more of the following ways:
· When you order or purchase products or services from us;
· When you post feedback or interact with our customer service officers, e.g. via meetings, emails, or telephone calls (which may be recorded for training, quality control, business, and/or other lawful purposes);
· When you use some of our services including establishing any online accounts with us;
· When you request us to contact you, or include you in an email or other mailing list;
· When you respond to our promotions, campaigns, or other initiatives, or attend our events;
· When we receive references from business partners and third parties, e.g. where you have consented to be referred by them;
· When you visit our websites;
· When you take part in any contest, survey, or promotion conducted by us and/or our business partners (including submission of photographs);
· When we receive information about you from third-party social networking services when you choose to connect with those services;
· When you provide or contemplate providing security to us for a transaction;
· When you submit your Personal Data to us for any other reason; and/or
· When we collect your Personal Data by other lawful means.
2.2. We process most of your information on the grounds of the fulfilment of our contract with you, namely to confirm your order, contact you about delivery of services, arrange for your payment to be processed and provide you with the products you have purchased. We may also use your personal data for our legitimate interests, including for the purposes of fraud protection and for training and quality.
2.3. Unless permitted by applicable laws, we will not collect, use, or disclose your Personal Data (including your NRIC number, Passport number or, where applicable, a copy of your NRIC or Passport) without your consent. We will limit our collection, use, and disclosure of your Personal Data to what is adequate and relevant to the purposes for which they are needed and to which you have consented.
2.4. You warrant and represent to us that (a) Personal Data which you disclose to us is accurate and complete; and (b) where you volunteer Personal Data of another person to us, that you are authorised by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.
2.5. You shall consult your parent or guardian before giving us your Personal Data if you are under the age of eighteen.
2.6. We may collect your personal data from third parties, such as our customers who may be providing your passenger details for the purpose of arranging a charter. We may also collect information from publicly available sources and data suppliers to validate or supplement the information we hold.
3. Purposes for which we collect, use and disclose your Personal Data
3.1. Your Personal Data may be collected, used and/or disclosed for the following purposes:
· To verify and process your personal particulars and payments;
· To provide goods and services to you;
· To respond and deal with inquiries, complaints, and other customer-care matters or otherwise communicate with you;
· To monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
· To manage payment, billing, account, credit checks and debt-recovery matters;
· To send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and that of the Companies;
· To manage, develop, and improve our business and operations to serve you better;
· To carry out marketing promotions and campaigns, contests, and lucky draws, and personalise your experience at our customer touchpoints;
· To carry out market research and customer surveys;
· To conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
· To comply with legal and regulatory requirements;
· To enforce our legal rights and obligations;
· To facilitate business asset transactions (which may extend to any mergers, acquisitions, or asset sales);
· For other purposes for which we have obtained your consent; and
· For any other purposes reasonably necessary, ancillary or related to the above-specified purposes.
3.2. Your Personal Data may be disclosed for the purposes indicated above to our officers, employees, third parties, affiliates, service providers, and advisors, which include without limitation, the following persons or entities:
· Banks, credit card companies, and payment vendors;
· Debt collection agencies;
· Credit information companies;
· Logistics and courier services companies;
· Call centre services providers;
· Relevant government regulators or authorities or law enforcement agencies;
· Our insurers and advisors, including consultants, auditors, and lawyers;
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets (to the extent that it is necessary);
· Data intermediaries; and
· Any other party to whom you authorise us to disclose your Personal Data.
Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under a duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.
3.3. If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receive marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax, or other means) with information about our products and services.
3.4. Likewise, we will only collect, use, and/or disclose your Personal Data for marketing purposes where you have consented to us doing so after being informed of such purposes and the consequences of providing consent.
3.5. Health data will only be processed for the purposes of ensuring your safety prior, during and after a flight, and where we have received your consent. By providing this sensitive personal data to us, you explicitly agree that we may collect, use, share with third parties (such as airlines) and transfer such data.
3.6. To the extent that the transfer is necessary for the performance of our contract with you or for the performance of a contract between JETBAY and a third party which is entered into at your request, your Personal Data may be transferred, stored, and/or processed in a country or territory outside Singapore upon your consent to any such transfer, storage, and/or processing of your Personal Data outside Singapore. Where the disclosure is reasonably necessary (i) for the performance of this contract between JETBAY and me; or (ii) for the conclusion or performance of a contract between JETBAY and a third party which is entered into at my request, or which a reasonable person would consider to be in my interest, I agree that my personal data may be processed and transferred outside of the Republic of Singapore to any overseas recipient which is bound by legally enforceable obligations to protect my personal data to a standard comparable to the data protection laws of the Republic of Singapore.
We will however ensure that any party to whom we transfer your Personal Data outside Singapore is bound by legally enforceable obligations to provide to such Personal Data a standard of protection at least comparable to the protection under the Act. This includes, without limitation, ensuring that any party coming into contact with the Personal Data outside Singapore:
· Complies with the Act and accompanying guidelines issued by the relevant regulatory authorities, all applicable laws and regulations, and this Privacy Policy (“Data Standards”) and shall not do or permit anything to be done which might cause such party or us to breach the Data Standards;
· Takes all appropriate measures to ensure such compliance by implementing such data handling principles as notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal Data that is comparable to the protection under the Act; and
· Protects Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure, or modification.
4. Withdrawal of Consent & Access
4.1. You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to the office of our Data Protection Officer (as defined below). You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated in our email or other marketing messages.
4.2. In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 days for any request for consent withdrawal to be reflected in our systems.
4.3. We will, at your request, within 30 days, endeavour to provide you with an account of your Personal Data in our possession or control or inform you of the deadline by which we will respond. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request, where permitted under applicable laws.
4.4. Where applicable, we will, at your request, within 30 days, provide you with your personal data in a structured, commonly used and machine-readable format and have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.
5. Accuracy & Correction
5.1. We will endeavour to ensure that the Personal Data we use is sufficiently accurate and complete to make any decisions that impact you.
5.2. To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to the office of our Data Protection Officer. We will, within 30 days, correct or complete your Personal Data or inform you of the deadline by which we will respond.
6. Protection, Policies and Procedures
6.1. We will endeavour to protect your Personal Data in our possession or control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal, or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and that they meet industry standards. To prevent unauthorised access, maintain data integrity and confidentiality, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the Internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.
6.2. In the unlikely event that your Personal Data has been breached, we will endeavor to stop the leak as soon as practicable and inform you immediately. We will also notify the Personal Data Protection Commission and affected individuals as soon as practicable.
7. Retention of Personal Data
7.1. We will retain your Personal Data for as long as you use our products or services and it is necessarily required or relevant for business or legal purposes.
7.2. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.
7.3. When the circumstances under which we need to retain your Personal Data as described above are all eliminated, we will cease to retain documents containing your Personal Data, and remove the means by which the Personal Data can be associated with particular individuals.
8. Cookies
8.1. We gather information on our website activity through cookies, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. Such information may be tied up with the Personal Data we collect separately and used for the purposes set out in Clause 3.1. In this case, we will treat such information as Personal Data. We do not automatically collect Personal Data on our website unless you provide such information or log in with your account credentials.
8.2. Cookies are small bits of data automatically stored on the hard drive of the end user and are commonly used to track preferences in relation to the subject of such a website. If you enable these cookies, then your web browser adds the text to a small file. You may wish to set your web browser to notify you of a cookie placement request or refuse to accept cookies by modifying relevant internet options or browsing preferences of your computer system, but by doing so, you may not be able to utilise or activate certain available functions on our website.
8.3. By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons, and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons, and information by us or our representatives or agents.
9. Third-Party Links and Products on Our Services
Our website and/or services may link to third-party websites and services that are outside our control. For example, we may enable you to share certain materials on the services with others through social networking services such as Facebook. We are not responsible for the security or privacy of any information collected by third-party websites or other services. You should exercise caution and review the privacy statements applicable to the third-party websites and services you use. To the fullest extent permitted under laws, we cannot be responsible for a third party's acts, omissions, data policies, or their use of cookies nor the content or security of any third-party websites, even if linked to our website. Any such liability is expressly disclaimed and excluded.
10. Contact Us
We have appointed Data Protection Officer(s) (“Data Protection Officer”) to oversee our compliance with the Act. Should you have any queries, requests, or feedback relating to your Personal Data, please contact us at the following:
- The office of the Data Protection Officer of Jetbay Air Charter Services Pte. Ltd. CapitaGreen #24-53, 138 Market Street, Singapore 048946, dpo@jet-bay.com.
For more information about the Singapore Personal Data Protection Act, please visit PDPC.
11. Google Analytics
11.1. We use Google Analytics to monitor and analyse visitor behaviour. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic (“Google Analytics”). Google uses the data collected to track and monitor the use of our services. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
11.2. Furthermore, we use the Google Analytics Advertising Features (as defined below). By enabling the Advertising Features, we enable Google Analytics to collect data about your traffic via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation.
We implemented the following Google Analytics Advertising Features (“Advertising Features”):
· Google Signals
· Granular Location Device Data Collection
· Ads Personalisation
· Cross Platform Reporting
· Remarketing with Google Analytics
· Advertising Reporting Features
· Demographics and Interests
We use these Advertising Features to evaluate website usage and obtain reports and metrics that help us improve performance and user experience and serve relevant advertising. We use third-party advertising services, which means that our advertisements may be displayed on other websites, such as partner websites. Through these advertising services, we can display ads that are tailored to your individual interests. These advertising services may also track your online activity over time across multiple websites and apps by collecting information through automated means. This data collection takes place both on our website and on third-party websites and apps that participate in these advertising services.
11.3. Visitors can opt out of Google Analytics by the following means:
· Google Analytics Opt-out Browser Add-on: You can opt out of having your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about your visit activity.
· Managing Cookies in Your Browser: Most browsers allow you to manage how cookies are set and used as you’re browsing, and to clear cookies and browsing data. Also, your browser may have settings letting you manage cookies on a site-by-site basis. For example, Google Chrome’s settings allow you to delete existing cookies, allow or block all cookies, and set cookie preferences for websites. Google Chrome also offers incognito mode, which deletes your browsing history and clears cookies on your device after you close your incognito windows.
· Managing Other Technologies in Your Apps and Devices: Most mobile devices and applications allow you to manage how other technologies, such as unique identifiers used to identify a browser, app, or device, are set and used. For example, the advertising ID on Android devices or Apple’s advertising identifier can be managed in your device’s settings, while app-specific identifiers may typically be managed in the app’s settings.
11.4. For more information on the privacy practices of Google, please visit the Google Privacy Policy.
12. Update to the Privacy Policy
We reserve the right to modify or update this Privacy Policy from time to time without any prior notice to you. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. The date stated at the bottom of this Privacy Policy indicates the last time this document was revised. We encourage you to check back regularly for the latest version of this Privacy Policy.
Last updated: 17 July 2024