PRIVACY POLICY
INTRODUCTION
As Asia’s favourite fast ferry operator, BatamFast (together with its subsidiaries and affiliates) values the information that our passengers share with us and information that we collect about our valued customers. We commit to protect that information and ensure that the information is only used for relevant purposes, the primary purpose of which is for enhancing your experience and enjoyment of our services and facilities.
By using BatamFast passenger ferry services, transacting at our counters, using our e-Ticketing system, visiting or using the BatamFast website, you agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully before transacting with us, using our e-Tickeing system, visiting or using our website, or otherwise providing us with any of your personal data Unless you opt-out and instruct us otherwise, BatamFast does and will continue to share the Customer Data that it collects from you with other BatamFast subsidiaries and affiliates, including those outside of Singapore, as permitted under applicable local laws and the Singapore Personal Data Protection Act (“PDPA”).
BatamFast collects relevant Customer Data from you in order to provide you with a safe, smooth, efficient and customised experience with BatamFast. The collection and processing of Customer Data enables BatamFast to provide services and products that are most likely to meet your needs and requirements.
As such, this Privacy Policy (which is divided into two Parts – A & B) outlines BatamFast’s policy and responsibility in relation to the collection, processing and disclosure of your Customer Data. PART A refers to BatamFast’s general policy and PART B addresses Customer Data issues specific to usage on BatamFast ‘websites' and usage of BatamFast’s ‘mobile services’ facility.
PART A
GENERAL CUSTOMER DATA PRIVACY POLICY STATEMENT
1. TYPES OF CUSTOMER DATA
The types of Customer Data that BatamFast collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken. There are two broad categories of Customer Data that we collect at BatamFast:
Individual Customer Data which is personal information that links back to an individual e.g., name, address, phone number and email address etc.; and
Statistical Data e.g., number of passengers carried, hits to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand BatamFast customer profile and improve our service offerings.
2. PURPOSE FOR COLLECTION, PROCESSING AND DISCLOSURE
Collection
Generally, BatamFast collects Customer Data in order to fulfil the following purposes:
Providing services to you such as processing a transaction e.g. making a booking, e-Ticketing, providing trip alert messages through BatamFast’s on-line and mobile services facility, internet check-in, registering for a BatamFast membership account;
Marketing and communicating with you in relation to products and services offered by BatamFast, our affiliates and service partners, as well as our appointed agents; and Safety, security, statutory and legal compliance.
Processing and Disclosure
BatamFast may process and disclose your Customer Data with and to third parties, such as our travel and freight service providers or travel-related businesses, partners, terminal and seaport management, security personnel and other carriers for the purpose of processing your travel arrangements. BatamFast shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, processing and disclosure of Customer Data will observe and adhere to the terms of this Privacy Policy.
BatamFast may disclose your Customer Data to law enforcement agencies and government for security, customs and immigration purposes. For example, BatamFast and other carriers are required by laws in Singapore and other countries to provide Immigration and Checkpints Authority (ICA) with access to your booking information or trip itinerary. Accordingly, relevant Customer Data (known as Passenger Name Record (PNR) or Advance Passenger Information (API)) may be disclosed to the appropriate customs and immigration authorities as required by law. Please be informed that the initial recipients of such information may share your PNR and API data with other government agencies or enforcement authorities.
In addition, BatamFast may disclose Customer Data to our lawyers and legal advisors for establishing, exercising or defending our legal rights, or as otherwise authorised or required by law. BatamFast will also reserve the right to share your Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entitiy such as BatamFast. Furthermore, BatamFast may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
3. TRANSFER OF INFORMATION OVERSEAS
BatamFast Head Office is based in Singapore. Customer Data may be transmitted to data storage facilities where we keep our central records. Your Customer Data is transferred for BatamFast to perform our contract with you. The Customer Data may also be transferred to our offices and appointed agents in other countries in connection with our performance of the contract with you.
4. CONSENT
Generally, in the course of BatamFast performing servicing functions such as making a trip booking, transmitting trip alert messages or accepting special arrangements, Customer Data will, by nature of the task or transaction, be provided by our customers and passengers to BatamFast. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for BatamFast to provide the requested or necessary service and/or product to them. However, where required by law, BatamFast will adopt an ‘opt-in' policy for attaining customer consent, in which event, express written consent will be sought from you when collecting your Customer Data e.g., signing a form or checking a box.
In addition, you are able to withdraw your express consent at any time by contacting BatamFast or amending your Customer Data by logging on to your website account. (Note: this service only applies on-line e-Ticket customers and customers who have registered a membership account through our website).
BatamFast will not seek consent for Statistical Data as this is not linked to a customer record.
5. ACCESS
BatamFast may, upon your written request to our Customer Service Department , allow you to view and update your stored individual Customer Data. BatamFast reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, BatamFast reserves the right to deny you access to your personal Customer Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include where:
- an investigating authority or government institution objects to BatamFast complying with a customer’s request,
the information may, in the exercise of BatamFast reasonable discretion and/or assessment, affect the life or security of an individual, and
data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
6. RETENTION
BatamFast will retain your Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required by relevant laws.
If you have ceased to be a customer or passenger of BatamFasT and have cancelled your account or membership, BatamFast will not send you marketing materials or share your personal data with unrelated third parties. However, BatamFast may still retain your records and use your information for legal and/or business purposes, including for compliance with the PDPA or other laws.
If you do not want your personal data to be shared among affiliates or partners of BatamFast, you may opt-out of such information sharing by sending us the appropriate withdrawal of consent form in the following link: PDPA-Consent-Withdrawal-From.pdf Please note that if you withdraw your consent for a limited purpose, such as for marketing, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such personal data may still be shared, as permitted under the PDPA and other applicable law. If you do not wish to receive any further information from BatamFast regarding BatamFast products, offers, promotions or special events via email, you may unsubscribe by clicking the unsubscribe link included in our email correspondence.
7. ACCURACY
BatamFast needs your assistance to ensure that your Customer Data is current, complete and accurate. As such, please inform BatamFast of changes to your Customer Data by contacting BatamFast and submitting your updated particulars to BatamFast in writing. If you are are a member or a registered website user, you may log onto your website account. BatamFast may also request Customer Data updates from you from time to time. As detailed in Section 2 above under the “Processing and Disclosure” sub-section, your booking information or trip itinerary may be disclosed to the appropriate customs and immigration authorities as required by law. As such, it is important to ensure that the Customer Data contained in your booking information or trip itinerary should also be current, complete and accurate.
8. SECURITY SAFEGUARDS
BatamFast takes the security and protection of your Customer Data very seriously. As such, BatamFast uses procedural and technical safeguards to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure.
As an example of a procedural safeguard, BatamFast has implemented various authentication procedures internally and with our external service providers that will involve BatamFast requesting various personal particulars from you in order to verify your identity (or that of your duly authorised agent) before BatamFast process your request for a particular service, product or transaction.
Examples of technical safeguards include encryption, “firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through our websites and our mobile services facility are set out at Part B below.
If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, BatamFast will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact BatamFast (see Section 10).
9. UPDATES TO THE PRIVACY POLICY
BatamFast reserves the right to amend or change this Privacy Policy from time to time and the updated versions will be posted on our website and date stamped so that you are aware of when the Privacy Policy was last updated. If we make material changes to the Privacy Policy, we will post any changes on this page. We encourage you to review this page periodically to understand our policy regarding the collection and use of your personal data.
Subject to applicable laws, the prevailing language of the Privacy Policy will be English. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.
Your continued use of our website and acceptance of our services at BatamFast after any changes to this Privacy Policy constitutes your consent to any such changes; to the extent such consent is not otherwise provided.
10. CONTACT US
If you have comments or questions about this Privacy Policy statement, please contact BatamFast in writing at the address below referencing ‘Privacy Policy': customer- [email protected]
PART B
PRIVACY POLICY STATEMENT FOR CUSTOMER DATA COLLECTED THROUGH OUR WEBSITE AND OUR MOBILE SERVICES FACILITY
1. SECURITY SAFEGUARDS
BatamFast takes the protection of your Customer Data on our website and through our ‘mobile services’ facility very seriously. All Customer Data collected through our ‘websites', e.g., http://www.batamfast.com and through our ‘mobile services’ facilities are protected by a secure server. In addition, data encryption ensures secure transmission of data from the internet to our systems. For example, when you transmit sensitive information such as credit card details through our website, such information will be automatically converted into codes before being securely dispatched over the internet. To further secure the integrity of your internet transactions on our websites, BatamFast also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies.
To give you secure access to our online services, arising from your utilisation of our ‘mobile services’ facility, and your membership account, you can register with us, and we will give you a membership number/ User ID with a PIN that is unique and personal to you. You should not share your membership number/User ID or PIN, and should always ‘log off' once you have finished your session on the websites as well as take the recommended precautions that ensure the safe and secure provision of our ‘mobile services’ facility. As an additional security feature, BatamFast has implemented a time stamp showing the time you have been on our websites and the last time you logged out. If you detect any anomalies you should inform BatamFast immediately . BatamFast has also provided a lock out feature in the event you fail to log in successfully after a number of attempts. Also, if you leave our Website idle for a period of time, we will give you a ‘warning' dialogue box giving you the option to end your session.
2. COOKIES
Most websites like ours use cookies to enhance your online experience. Cookies are alphanumeric identifiers that are transferred to your computer's hard drive from your web browser to recognise your preferences and to tailor content to you. The cookies do not contain your Customer Data (unless you specifically chose our “Remember Me” feature) but only Statistical Data which is entirely anonymous. Please refer to your browsers documentation to check if cookies have been enabled on your computer or to request not to receive cookies.
Information and procedures regarding cookie handling are provided by the respective browsers documentation within the browser itself by clicking on ‘help' and performing a search on ‘cookies'.
3. CLICKSTREAM DATA
In order to improve your online experience, BatamFast may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.
4. LINKS TO OTHER WEBSITES
BatamFast provides you with links to other websites for your convenience and information. Whilst BatamFast will protect your Customer Data on BatamFast websites, BatamFast cannot control the policies of other sites we may link to, or the use of any Customer Data you may share with them. Please note that BatamFast Privacy Policy does not cover these other websites, and BatamFast would recommend that you are apprised of their specific policies.
5. MINORS
BatamFast cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided BatamFast with Customer Data without parental or guardian consent, the parent or guardian should contact BatamFast to remove the relevant Customer Data and unsubscribe them
Issue/Rev: COR/02/GPP/1/R1, 05 February 2014