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.

Our Privacy Policy is detailed as below. This Privacy Policy (the “Policy”) applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from the services and/or goods offered by Cruise Arena and Pacific Arena Pte Ltd (collectively referred to as “Pacific Arena”, “us”, “our” or “we”).

General

This Policy statement provides information on our obligations and policies in respect of an individual customer’s Personal Data. We undertake to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

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.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to us as well as to its respective representatives and/or agents ("Representatives") (collectively referred to herein as "Pacific Arena", "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.

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.

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 customer 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.

Purposes for Collection, Use, Disclosure and Processing of Personal Data

The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances/transactions for which we may/will need to process your personal data, which include but are not limited to:

(a) Name, address, passport number, flight and other travel details, credit/debit card number and expiry date, billing address, telephone numbers, frequent flyer number or other loyalty program membership details, dietary requirements (if any) and health issues relevant to your travel arrangements;

(b) Any other purposes that we notify you of at the time of obtaining your consent.

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.

Collection of Personal Data

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.

As part of its day-to-day activity, Pacific Arena may collect from you, through various means, including via our websites, smart phone applications, marketing events (e.g. road shows) and any forms used by Pacific Arena from time to time, some or all of the following Personal Data:

• Name (first and surname);
• Postal address;
• Phone number (including mobile);
• Office number;
• Fax number;
• Email address;
• Bank account/credit card details;
• Gender;
• Personal Data of your emergency contacts;
• Travel and booking details;
• Frequent flyer details or flight membership details;
• Health issues;
• Dietary requirements;
• Photographs and images;

The above Personal Data mentioned in Clause 3.2. is collected for the purposes of processing your booking(s) and travel details; internal job training; to conduct market research and client surveys to enhance the provision of our services; to contact you directly regarding other travel offerings which may be of interest through voice calls; text messages; e-mail; direct mail and/or facsimile messages; to respond to queries and feedback; for identification purposes; maintaining and updating your particulars; and informing you of new developments and services of Pacific Arena and other third parties which we are associated with.

Storage and Retention of Personal Data

Pacific Arena 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 Pacific Arena and where the Personal Data is deleted from Pacific Arena’s electronic, manual, and other filing systems in accordance with Pacific Arena’s internal procedures and/or other agreements.

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.

Specific Issues for the Disclosure of Personal Data to Third Parties

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.

6.2. In some instances, you may also be requested to provide certain Personal Data that may be used to further improve Pacific Arena’s 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 Pacific Arena from providing the service to you. This type of data includes, but is not limited to:

• Your age;
• Your gender;
• Your race;
• Particulars of next of kin;
• Travel details;
• Frequent flyer details/ membership details;
• Passport details;
• Health issues/details;
• Dietary requirements;
• Other related products and services subscribed to; and
• Family and household demographics.

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.

Accuracy of Personal Data

Where possible, Pacific Arena 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, Pacific Arenacan validate the data provided against pre-existing data held by Pacific Arena. In some cases, Pacific Arena 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 Pacific Arena, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.

Transfer of Personal Data Overseas

Your Personal Data may be processed by Pacific Arena, its subsidiaries, related corporations, affiliates, agents and third parties providing services to Pacific Arena, in jurisdictions outside of Singapore. In this event, Pacific Arena will comply with the terms of the Act.

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 time 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.

Automated Data Collection

Our website and mobile or web-based applications may contain web analytic services provided by Google Analytics. This means that when you visit our website or use any mobile or web-based applications, 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.

If you do not wish information about your behaviour at our website or any mobile or web-based applications being collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) to not send your site visit information to Google Analytics. The browser add-on is available for most modern browsers. The Google Analytics opt-out browser add-on does not prevent information from being sent to the website itself or in other ways to web analytics services.

Please note that we use cookies on our website. Cookies are text files that we put on your computer and they store/record information about your visit to and use of the website. Cookies can compile information about your browsing habits and can also enhance your browsing experience. We use cookies for the following purposes:

• 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 to function properly.

You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our website, please note that you may not be able to access the full range of functions that our website offers. Your use of our website constitutes consent by you to our use of cookies and to the matters set out herein.

Protection of Your Personal Data

Pacific Arena 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 Pacific Arena, other than to you or as described in this Policy. However, Pacific Arena cannot ensure or warrant the security of any information you transmit to Pacific Arena and you do so entirely at your own risk. In particular, Pacific Arena does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Pacific Arena’s physical, technical, or managerial safeguards.

Updates on Privacy Policy

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.

Contacting You

To the extent that any of the communication means which you have provided Pacific Arena with (which may include, your telephone number and fax 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 Pacific Arena your clear and unambiguous consent to contact you using all of your communication means you have provided to Pacific Arena including using via voice calls, SMS, WhatsApp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Clause 3.3. This will ensure your continued enjoyment of Pacific Arena’s services.

Contacting the Data Protection Officer

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 Pacific Arena, Pacific Arena shall provide and/or correct that data within thirty (30) days and in a manner in accordance with its standard procedures as stated hereinafter.

In accordance with the Act, Pacific Arena 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 Pacific Arena 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, please send the same via email to the Data Protection Officer (the “DPO”) of Pacific Arena at the following email address:dpo@pacificarena.travel. We will process your enquiry or request within a reasonable time.

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 Pacific Arena on your behalf.

Should you not wish Pacific Arena to use your Personal Data for any of the purposes listed in Clause 3.3, or not to receive promotional materials from Pacific Arena, 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.

Miscellaneous

This Policy only applies to the collection and use of Personal Data by Pacific Arena. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Pacific Arena does not share your Personal Data with third party websites. Pacific Arena 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.

Pacific Arena will not sell your personal information 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 Pacific Arena’s website.

Pacific Arena’s websites do not target and are not intended to attract children under the age of 18 years old. Pacific Arena does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.

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.