P R I V A C Y

1.    Who are we

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1.1    At Bespokcracy Pte Ltd ("we"), we are committed to protecting and respecting your privacy, whilst also providing the very best user experience. We work hard to keep your information safe and we want our services to be safe and enjoyable for everyone. We follow strict security procedures on how personal information is stored and used, and who is able to view it, to prevent any unauthorised person obtaining it. We also recognise that it is important for you to understand how we use your personal information.

 

1.2    This privacy policy (and any other documents referred to in it) describe the way we process and use any personal information of our customers, potential customers, visitors to our and any other individuals whose data we process in the course of our business. Please read this privacy policy carefully to understand our practices regarding your personal information and how we will treat it.

 

1.3    We have a legal duty to protect personal information that we collect under the Singapore Personal Data Protection Act 2012 (and any regulations and subsidiary legislation) (the “PDPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”). For the purpose of the PDPA and GDPR, we are the data controller and our contact details are set out in section 9 (“Contact and Complaints”) of this privacy policy.

 

2.    Personal information we collect, how we use it and our lawful basis for processing

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2.1    We may collect and use various types of personal information about you. Details of this information, together with an overview of the way that we use it and our lawful bases for the processing in each case are set out below:

 

2.1.1    Enquiries and bookings

(a)    We collect personal information from you when you make an enquiry or request a brochure from us. This includes your name and any type of contact information, details about the destinations and countries that you are interested in, the brochures that you request and any additional details of your travel plans which you voluntarily give to us. We may also collect details about the best time to contact you and any in-person appointments that you request as well as any other information that is relevant.

 

We use this information so that we can provide you with information that you have requested or contact you if you have indicated you wish to hear from us. We also collect personal information from you when you make a booking through us.

 

We have a legitimate interest to use your information in this way to make sure that we are able to help you with all your travel needs. Where we rely on our legitimate interests, we will always ensure that your rights are protected.

 

(b)    If you book trips with us, we will ask you to provide certain details about your travel arrangements. These include, without limitation, details of your passport information, emergency contacts, travel insurance arrangements and information, frequent flier club membership, visa requirements and flights (if you arrange your own flights). This also includes details of any other person(s) who is/are part of your booking.

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We will use this information to help us organise your trip, make bookings on your behalf and ensure that you (and any other person(s) in your group) receive the products and services set out in your itinerary.

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We collect this information so we can fulfill our contract with you and provide you with the highest quality of service.

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Where you are a regular customer, we retain some or all of your personal information so that we can use it when you next book with us as we have a legitimate interest to improve our customer journey and ensure we look after our regular customers.

2.1.2    Websites, apps, marketing and advertising

(a)    We may collect certain technical information about you when you visit our website. This is likely to include the internet domain you use, your IP address or other device identifier, your browser type and version, the operating system and platform that you are using, the dates and times when you access our website and the websites or links that you use to access our website, login information, details of products or services that were viewed and the length of visits to certain pages of the website.

 

We use this information for site management and security purposes (such as troubleshooting and testing) as well as to help us improve our website. We do not try to identify individual users or their usage habits from this data. Raw data logs are retained temporarily as required for security and site management purposes only.

 

We collect this information so we can fulfil our legitimate interests as a business to ensure that our website is fit-for-purpose and promotes our services appropriately to you, including by displaying information that you are interested in. We also rely on our legitimate interest in measuring customer satisfaction and troubleshooting any website issues. Whenever required by law, we will seek and rely on your consent.

 

(b)    We may collect and use information from various sources to market and advertise our products and services. This may include your contact details (and your marketing preferences) to contact you with certain marketing messages (e.g. electronic mailers). We may also use data we collect from you (either directly or via our website or advertising) to help us measure the effectiveness of our advertising and to establish what interests you.

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We rely on your consent to contact you directly about our products and services. You can withdraw your consent or opt out of our direct marketing at any time by contacting us directly or through the 'unsubscribe' option in any electronic mailer. 

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(c)    We may collect your contact details when you enter into competitions or promotions, or complete surveys.

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We will rely on your consent or on our legitimate interests (depending on whether we are marketing or carrying out market research), whilst always ensuring that your rights are protected.

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(d)    We may collect details about you, such as your user name, when you engage with us on social media (by mentioning or tagging us in a post or contacting us directly) so that we can respond to any comments and queries you have.

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We rely on our legitimate interests to do this as we want to ensure our customers have the best possible experience, whilst always ensuring that your rights are protected.

2.1.3    Administrative or other business purposes

(a)    We may collect and use certain other personal information when we correspond with you (whether by telephone, e-mail or otherwise).

 

For example, we may record both in-bound and out-bound telephone calls or collect information when you use any messaging features on any social media platform to speak us to ensure quality of service and for training purposes.

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We collect this information so we can fulfil our legitimate interests as a business to ensure that our Specialists are trained to the highest level so that our customers receive the very best travel advice.

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(b)    We may collect certain other information that you give us, for example, when you contact us for a particular reason other than those set out above such as to report problems with our website.

 

It is in our legitimate interests as a business to use your data in this way, for example, we have a clear interest in ensuring that our website works properly and in ensuring that we operate our business efficiently. We will always ensure that your rights are protected.

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2.2    As well as collecting personal information directly from you, we also collect some from third parties such as Google Analytics.

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2.3    We may also collect and use certain sensitive personal information about you, including without limitation, specific details of any relevant health conditions, disabilities, access requirements and special dietary requirements that you may have. We collect this information directly from you to try to ensure that your trip is appropriate for your needs and to try and keep you safe during any trip that you plan through us. We may need to ask for your explicit consent in order to process this information.

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2.4    To the extent you provide us with information about third parties (such as other travellers or guests on your trips) we ask you to confirm that you have obtained consent from the relevant third parties to do this. Please also tell them about this privacy policy and give them our contact details if they have any queries. Please make sure you let us know if any of these third parties would like to speak to us directly, either about the trip or about our use of their data.

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3.    How we share personal information

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3.1    In order to make sure that we run our business efficiently, and to make sure that you get the service that you expect, we will share your personal information, from time to time, as required, with the following third parties:

(a)    Trusted third party business partners (such as the local businesses we partner with in the locations you are travelling to) and other service providers to perform services related to the contracts we enter into with you.

(b)    Prospective buyers of our business or assets, which may include your personal information.
(c)    Any other third parties in order to comply with legal and regulatory obligations, or enforce agreements, for example, we are required to provide airlines with a passenger mobile phone number and email contact details under IATA Resolution 830d for the airline to inform the passenger of any operational difficulties.
(d)    Any other third parties in order to protect our or your rights, property, or safety and/or those of others.

 

3.2        We do not share your personal information with third parties for them to use for the purposes of sending you marketing information or for those third parties to use your information for their own purposes.

 

4.       Where we transfer and store personal  information

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From time to time we may process (or ask or permit a third party to process) your personal information outside of Singapore where local laws may not provide legal protection for your information in the same way as is applicable in Singapore. For example, when you book a trip, we will need to provide your information to local service providers. 

 

Whenever we send (or permit a third party to send) your personal data outside of Singapore, we will make sure that we take steps necessary to protect your data as required by applicable laws of Singapore. For example, we may require the overseas recipient to enter into particular contract terms, or we will make sure that the information that we give to them will be limited to what is needed to perform our contract with you.

 

If you wish to learn more about the safeguards in place to protect your personal information when we transfer it outside of Singapore, please contact us using the details in section 9 (“Contact and Complaints”) of this privacy policy. The personal data that we collect from you will also be processed by staff operating outside Singapore who work for us or for one of our suppliers. This includes staff involved in, among other things, providing support services.

 

5.       Security of your personal information

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We take the security of your information very seriously and have put physical, technical, operational and administrative strategies, controls and measures in place to help protect your personal information from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We shall always review these periodically to make sure that said measures remain appropriate and apposite.

 

6.       Retention of personal information

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We keep your personal information for limited and appropriate periods of time only, and the applicable retention periods will always be linked to our purposes for processing your personal information, subject to the maximum retention period prescribed by the PDPA and GDPR. This means that the retention periods will vary according to the type of personal information. For example, some transaction information will be kept for a number of years in order to comply with various finance and tax related obligations. 

 

7.       Your rights in your personal information

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7.1    You have certain rights in respect of the personal information that we hold of you. Details of these rights are set out below. To exercise any of these rights, please contact us via the details set out in Section 9 (“Contact and Complaints”) of this privacy policy.

 

7.2     Your rights:

(a)    Access: We will confirm to you whether or not we are processing and using personal information about you, at your request and, if so, provide you with access to and a copy of such personal information and the other details to which you are entitled, subject to possible administrative fees being charged for such a request and to allow for a turnaround time as prescribed by applicable laws.
(b)    Rectification: We will correct any inaccurate personal data and complete any incomplete personal data that we hold of you.
(c)    Prevention of processing likely to cause damage or distress: We will respect your rights to require us to cease or not to begin processing your personal information for a specific purpose, or in a specific way, that is likely to cause you or any third parties unwarranted damage or distress.
(d)    Erasure: We will erase your personal information at your request without undue delay where there is no good reason for us to continue to use it.
(e)    Restriction: We will restrict the processing of your personal information in certain circumstances, if you ask us to do so.
(f)    Data portability: We will provide you or third parties on your behalf with a copy of any personal information that we hold of you which you have provided to us in a structured, commonly used and machine readable format. We may charge possible administrative fees for this request.
(g)    Objection (including objection to direct marketing): We respect your general rights to object to the processing of your personal information in certain circumstances, including for direct marketing purposes.
(h)    Automated decisions and profiling: We do not make automated decisions or profile you based on your data.

 

8.    Changes to our policy

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We reserve the right to modify this privacy policy from time to time. For example, if we need to reflect changes to the way that we use your personal information. Any changes we make in the future will be posted on the following website: www.bespokcracy.com and, where appropriate, notified to you by email. You should revisit our website frequently to check on any updates or changes to our privacy policy.

 

9.    Contact and complaints

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9.1    We are keen to hear from you regarding any question, concern, comment, request or complaint regarding this privacy policy, our website and/or our use of your personal information. Please contact general@bespokcracy.com.

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9.2    If you have any complaints regarding this privacy policy or the way that we use your personal information, you may also contact the Singapore Data Protection Commission at https://www.pdpc.gov.sg/.