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PRIVACY POLICY

Last updated: 10 November 2020

1. OVERVIEW

We, TUBER PRODUCTIONS PTE LTD (“The Company”, “we”, “our”, “us”), place great importance on the confidentiality, privacy and protection of your personal and transactional data. We handle all personal data provided to us in accordance with the standards prescribed by the Singapore Personal Data Protection Act (No. 26 of 2012) (“PDPA”) and the subsidiary legislation made thereunder, and, where applicable, the European General Data Protection Regulation (“GDPR”).

BY USING THIS WEBSITE, AND/OR BY ENTERING INTO A BUSINESS RELATIONSHIP WITH US, YOU AGREE THAT THE COMPANY MAY COLLECT, USE, PROCESS, STORE AND/OR DISCLOSE YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DISAGREE WITH ALL OR ANY PART OF THIS PRIVACY POLICY, PLEASE DO NOT USE OR CONTINUE ANY FURTHER USE OF THIS WEBSITE.

2. INFORMATION WE COLLECT

2.1 When you access our website, www.flyaway.sg, and all pages within the domain (the “Website”), and/or by entering into a business relationship with us, the following types of information may be collected from you:

2.1.1 Contact Information: These relate to the following information about you, some or all of which may be collected when you contact us or our representatives:

(a) Name

(b) Name of organisation

(c) Contact telephone number

(d) Email address

2.1.2 Access Information: These relate to information about your computer or mobile device and your access patterns, some or all of which may be collected when you use the Website:

(a) IP address

(b) Geographic location

(c) Operating system and browser type

(d) Device type

(e) Web traffic data

(f) Time spent on the Website

(g) Number of webpages within the Website viewed

(h) Access from third party websites linking to our Website

(i) Advertising information, e.g. what ads were clicked and/or viewed

2.1.3 Third Party Information: We may receive information about you from third parties that we work closely with (e.g. payment and delivery service providers, data analytics providers, advertising networks and social networking sites). Such information may be, but are not limited to, the various categories of Contact and Access Information listed in clauses 2.1.1 and 2.1.2 above.

2.1.4 Where we collect, use or disclose the personal data of residents of the EU, we will also comply with any specific requirement of the GDPR :a. We will obtain express consent from you for the collection, use and disclosure of your personal data. Your acceptance of this Privacy Policy by using our website or our services signifies that consent.b. We will not collect sensitive data, such as, race, ethnicity, political, religious or philosophical beliefs, trade union membership, genetic or biometric data, or sexual orientation unlessi. you give explicit consentii. it is in your vital interests that we collect the dataiii. is required for legal claims, public health, scientific or historical research purposes, oriv. it is required for reasons of substantial public interest.

2.1.5 This website (the “Website”) makes use of cookies to improve the site and to provide you with a more tailored user experience. A cookie is a small file that may be added to your device when you visit the Website, and which is sent back to the Website when you visit it again. The cookies we employ on the Website do not grant any access to your computer or any information about you, other than the data you choose to share with us.We use the following categories of cookies:

(a) Strictly necessary cookies: These are cookies that are required for the operation of the Website and the provision of our services to you. Specifically, we run the cookies for the following purposes:

(i) To verify that you’re not a robot; and

(ii) To remember preferences that you have set.While you may disable these cookies in your internet browser settings, doing so may result in restrictions in your use of the Website and/or the failure of the Website to work properly for you.

(b) Analytical/Performance/functionality/advertising cookies: These cookies enable us to collect information about how users use our Website, and to personalise our content and advertisements for you. Specifically, we use these cookies to:

(i) Perform data analytics of how users use the Website, in order for us to improve the Website, our content and services;

(ii) Recommend other content on the Website which you may be interested in; and

(iii) Provide you with targeted advertisements.While you may disable these cookies in your internet browser settings, please note that you will still receive recommendations for Website content, and that you will still see the same number of advertisements on the Website, except that these will not be tailored to you based on your personal information.

3. If you disagree with our use of cookies, you may choose to stop using the Website, or to disable cookies through your internet browser settings at any time. If you do neither, then you will be deemed to have consented to our use of cookies on the Website.

3. WHY WE COLLECT, USE AND DISCLOSE PERSONAL DATA

3.1 Insofar as the information collected allows you to be identified directly, or indirectly when combined with other information, it is “Personal Data”.3.2 We may collect, use, process, store and/or disclose your Personal Data, for the following purposes, where necessary or applicable:

(a) To verify your identity;

(b) To enable your device and/or software to access the Website;

(c) For the smooth administration and improvement of the Website, including troubleshooting, site analysis, testing, research, statistical and survey purposes and to obtain feedback so as to enable us to improve the operation of the Website and offer you a better user experience;

(d) For audit, customer service, administrative support, market research and business development purposes;

(e) To contact or notify you about matters relating to updates and/or developments to the Website, the Website Terms of Use, Cookies Policy and this Privacy Policy;

(f) To send you marketing information about our goods or services including notifying you of our marketing events, initiatives and other promotions;

(g) To respond to any queries, requests or reports which you may have submitted;

(h) To perform a contract to which you are a party to or deliver the services you have requested;

(i) To recommend and/or display content and advertisements on the Website that may be of interest to you;

(j) To comply with the requirements under any applicable law or requests from any competent authority, including but not limited to relevant governmental authorities, law enforcement agencies and regulatory bodies;

(k) Where required in any civil or criminal suit or for the protection and/or enforcement of our legal rights and obligations;

(l) In the event we sell or buy any business or assets, where necessary for the purposes of the sale or purchase;

(m) To enable any third parties to perform any of the above where necessary and/or applicable, including but not limited to law enforcement agencies, regulatory bodies, our business partners, affiliates, suppliers and sub-contractors;

(n) To post testimonials (with your consent). We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial; and/or

(o) Any other purpose for which you have provided the informationIf we intend to use your Personal Data for any purpose not listed above, we will notify you of this purpose and obtain your consent, unless otherwise prescribed by any applicable law.

3.3 We will retain your Personal Data for the length of time required to fulfil the purposes for which the Personal Data was collected, save where continued retention is necessary for us to comply with our other legal obligations or to meet our business requirements.

3.4 In respect of the transfer of data to third parties, we will do so only with your consent and ensure that your Personal Data is transferred to recipients who are legally bound to uphold strong data protection standards and to comply with applicable data protection laws and this Privacy Policy.We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

3.5 The Website may contain links to third party websites which are not subject to this Privacy Policy. We are not responsible for their collection and use of personal information, or their data security and integrity practices and procedures.

4. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

4.1 We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data. You may write to our Data Protection Officer at dpo@tuber.sg to:

(a) Correct or update your Personal Data;

(b) Reasonably request for access to your Personal Data. Do note that you may face reasonable charges for our provision of the Personal Data;

(c) Request for information relating to our use or disclosure of your Personal Data;

(d) Withdraw your consent for our collection, use or disclosure of your personal data;

(e) Request that we restrict the use of or stop processing your Personal Data for certain purposes;

(f) Delete any Personal Data we no longer have legally permissible grounds to use;

(g) Request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions; or

(h) Make a report about any actual or potential breach of security in relation to your Personal Data.

Upon receiving your request to withdraw consent to collect, use or disclose your Personal Data,stop processing your Personal Data or delete Personal Data, we will inform you of the consequences of your request. Please note that the withdrawal of your consent could affect the status of your contract for service with us. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

We may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) to action your request to withdraw consent to collect, use or disclose your Personal Data, stop processing your Personal Data or delete Personal Data, and for us to notify you of the consequences of us acceding to your request, including any legal consequences, which may affect your rights and liabilities to us. In general, we will process and complete your request within 10 business days of receiving it. If we need more time, we will inform you of how much longer we will take and provide you the reasons for it. We will endeavour to fulfill your request within 30 days.

For all other requests in 4.1 above, we will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we will generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable law).

5. DATA PROTECTION AND SECURITY

5.1 We will put appropriate and reasonable technical and administrative security measures in place to help ensure that your information is protected against unauthorised or accidental access, use, alteration or loss.

Please note that we use the following cloud service providers (CSP) for data storage and customer relationship management:

Google Drive: The privacy policy of Google Drive is available at https://policies.google.com/privacy

Hubspot: The privacy policy of Hubspot is available at https://legal.hubspot.com/privacy-policy

Mailchimp: The privacy policy of Mailchimp is available at https://mailchimp.com/legal/privacy/

We are satisfied that the above-mentioned CSPs have taken reasonable steps to protect your personal data in accordance with the guidance of Singapore’s Personal Data Protection Commission (PDPC).

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

5.2 All of our employees who deal with Personal Data are trained in the proper handling and protection of Personal Data.5.3 Any data protection breach will be handled in accordance with our internal procedures, a copy of which may be obtained from our Data Protection Officer at the contact details mentioned below.

6. VARIATION

6.1 We reserve the right to change this Privacy Policy from time to time at our sole and absolute discretion. The most updated Privacy Policy will be made available promptly on the Website and you will be notified of the update. It is your responsibility to keep yourself updated and aware ofthe latest version of this Privacy Policy. If any change is unacceptable to you, you should immediately cease all further use of the Website. If you continue using the Website after the changes take effect, you will be deemed to have accepted the changes.

7. DATA PROTECTION OFFICER (DPO)

You may contact our Data Protection Officer if you have any enquiries or feedback on our privacy policies, or if you wish to make any complaint or request. Please contact our DPO at: dpo@tuber.sg

 

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We have updated our Privacy Policy. The continued use of the website will be taken as consent.

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