Data Protection Policy
The purpose of this document (“Data Protection Policy”) is to inform you of how
Property name: Bawah Reserve, Indonesia
Sole Distributor: Below The Wind Pte Ltd, Singapore
Below The Wind Pte Ltd manages Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any Products and Services offered by us, you agree and consent to Below The Wind Pte Ltd (including its related corporations) (collectively, the “Companies”), as well as their respective representatives and/or agents (collectively referred to herein as “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection 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 to any of the Companies may have at law to collect, use or disclose your Personal Data.
Below The Wind Pte Ltd may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website . Please check back regularly for updated information on the handling of your Personal Data.
1. Personal Data
1.1 In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
2.1 Generally, we collect Personal Data in the following ways:
(a) when you submit an application form or other forms relating to any of our Products and Services (defined below);
(b) when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
(c) when you use some of our services, for example, websites and apps including establishing any online accounts with us;
(d) when you request that we contact you, be included in an email or other mailing list;
(e) when you respond to our promotions, initiatives or to any request for additional Personal Data;
(f) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(g) when we receive references from business partners and third parties, for example, where you have been referred by them;
(h) when we seek information from third parties about you in connection with the Products and Services you have applied for; and
(i) when you submit your Personal Data to us for any other reasons.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, Below The Wind Pte Ltd collects, uses and discloses your Personal Data for the following purposes:
(a) responding to your queries and requests;
(b) managing the administrative and business operations of Below The Wind Pte Ltd and complying with internal policies and procedures;
(c) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) resolving complaints and handling requests and enquiries;
(f) preventing, detecting and investigating crime and analyzing and managing commercial risks;
(g) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(h) organising promotional events;
(i) legal purposes (including but not limited to obtaining legal advice and dispute resolution);
(j) conducting investigations relating to disputes, billing or fraud;
(k) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Below The Wind Pte Ltd (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
(l) purposes which are reasonably related to the aforesaid.
3.2 In addition, Below The Wind Pte Ltd collects, uses and discloses your Personal Data for the following purposes:
(a) If you are a customer or an employee of an organisation which is a customer of Below The Wind Pte Ltd (for products and services relating to, without limitation, hotels and resorts, restaurants, spas, meetings, and events (“Products and Services”):
(i) establishing or providing you with the Products and Services you request for (including but not limited to service activation, service operations, service delivery and order processing);
(ii) facilitating the daily operation of the Products and Services (including but not limited to billing, customer service, customer verification, and technical support);
(iii) processing of payment instructions, direct debit facilities and/or credit facilities requested by you;
(iv) enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
(v) credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
(vi) generating internal reports (including but not limited to annual, operational and management reports);
(vii) administering fee adjustments, refunds and waivers;
(viii) analysing your use of our Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and
(ix) purposes which are reasonably related to the aforesaid.
(b) If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Below The Wind Pte Ltd:
(i) managing project tenders or the supply of goods and services;
(ii) processing and payment of vendor invoices;
(iii) purposes which are reasonably related to the aforesaid.
(c) If you submit an application to us as a candidate for an employment or representative position:
(i) conducting interviews;
(ii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;
(iii) providing or obtaining employee references and for background screening;
(iv) assessing your suitability for the position applied for;
(v) processing staff referrals;
(vi) any other purposes relating to any of the above.
(d) If you are an existing employee of Below The Wind Pte Ltd:
(i) administering compensation and benefits;
(ii) providing remuneration and reviewing salary and bonuses;
(iii) facilitating onboarding processes;
(iv) manpower and logistical management;
(v) learning and talent development;
(vi) conducting evaluation and staff appraisals;
(vii) facilitating overseas travel arrangements;
(viii) managing corporate social responsibility projects;
(ix) conducting analytics and research for human resource planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;
(x) ensuring that the administrative and business operations of Below The Wind Pte Ltd function in a secure, efficient and effective manner (including but not limited to examining or monitoring any computer software and/or hardware installed within Below The Wind Pte Ltd, your work emails and personal digital and storage devices);
(xi) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authoriti
es (including but not limited to disclosures to regulatory bodies, conducting audit checks or surveillance and investigation);
(xii) legal purposes which include obtaining legal advice and dispute resolution;
(xiii) administering cessation processes; and
(xiv) any other purposes relating to any of the above.
3.3 Furthermore, where permitted under the Act:
(a) Below The Wind Pte Ltd may also collect, use and disclose your Personal Data for the following “Below The Wind Pte Ltd Additional Purposes”:
(i) analytics and tracking, including facilitating the sale of analytical data on an aggregated and/or non-personally identifiable basis;
(ii) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to Below The Wind Pte Ltd’s Products and Services;
(iii) providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from Below The Wind Pte Ltd;
(iv) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by Below The Wind Pte Ltd;
(v) leads generation and management for marketing Below The Wind Pte Ltd’s Products and Services;
(vi) administering contests, competitions and marketing campaigns, and personalising your experience at Below The Wind Pte Ltd’s touchpoints;
(vii) communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);
(viii) organising promotional events and corporate social responsibility projects; and
(ix) purposes which are reasonably related to the aforesaid.
In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Below The Wind Pte Ltd Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Below The Wind Pte Ltd.
3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Below The Wind Pte Ltd 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.
3.5 In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.6 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
3.7 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to [30 working days] for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you have requested from Below The Wind Pte Ltd.
4. Disclosure of Personal Data
4.1 Below The Wind Pte Ltd will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
(a) Below The Wind Pte Ltd’s related corporations and employees to provide Products and Services to you, address your questions and requests in relation to your billing arrangements with us as well as our Products and Services, to maintain and operate our systems and/or services;
(b) companies providing services relating to insurance and consultancy to Below The Wind Pte Ltd;
(c) agents, contractors or third party service providers who provide operational services to Below The Wind Pte Ltd, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Below The Wind Pte Ltd;
(d) vendors or third party service providers in connection with marketing promotions and services offered by Below The Wind Pte Ltd;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
(f) collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
(g) external banks, credit card companies and their respective service providers;
(h) our professional advisers such as auditors and lawyers;
(i) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(j) any other party to whom you authorise us to disclose your Personal Data to.
5.1 When you interact with us on our websites, we automatically receive and record non-personally identifiable information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page). Please also see para 2.2 above.
5.2 Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
5.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to use certain services or enter certain part(s) of our website.
6. Data Security
6.1 Below The Wind Pte Ltd will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
7. Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
7.1 If you:
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access and make corrections to your Personal Data records, please contact Below The Wind Pte Ltd as follows:
7.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Below The Wind Pte Ltd on your behalf.
7.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Below The Wind Pte Ltd may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Below The Wind Pte Ltd, and your being in breach of your contractual obligations or undertakings. Below The Wind Pte Ltd’s legal rights and remedies in such event are expressly reserved.
8. Governing Law
8.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.