Privacy Policy

Last Updated: 1 May 2019

DataPro Technologies Private Limited ('DataPro', 'we', 'us', 'our') are committed to protecting and respecting your personal data privacy and complying with data protection principles and provisions under applicable laws, including the Singapore's Personal Data Protection Act (“PDPA”) 2012 (No. 26 of 2012) and EU General Data Protection Regulation (“GDPR”).

This document represents a legal document that serves as our privacy policy (“Privacy Policy”) which sets out the basis and terms upon which DataPro collects, processes, uses and/or discloses your personal information ('Personal Information') that is obtained from you when you access our website (“Website”), mobile application (“App”) or Self-Service Ticket Kiosk and/or use the mobile wi-fi device and data services operated by DataPro under the “Hotspot” brand (or such other brand name) (“Hotspot Devices”) that is offered to incoming travellers to Singapore, (“Hotspot Services”) and/or such other products and services provided by DataPro, our partners and affiliates and our third party services providers. The Personal Information includes :-

• your name;
• residential address;
• telephone number;
• email address;
• travel document information;
• travel information; and
• credit card details.

In addition, we collect device and technical information from you when you use the Website, App or Self Service Ticket Kiosk.

Please read this Privacy Policy carefully.

Please read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Information.

We may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to any rights that you may have at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on the Website, App and Self Service Kiosk. Please ensure that you visit the Privacy Policy on the Website and App regularly to obtain updated information on the handling of your Personal Information.

By interacting with us, submitting information to us, or signing up for the Hotspot Services or any other products and services provided by DataPro and any of our partners and affiliates and our third party services providers (“Other Services”), you agree and consent to DataPro (including its related corporations and business units, partners and affiliates), as well as our and their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Information.

For the purpose of GDPR and other applicable data protection laws, we are the Data Controller. Our Data Protection Officer (DPO) can be contacted at DPO@hotspot.travel

Collection of Personal Information

• DataPro collects, uses and discloses Personal Information so as to comply with laws, rules and regulations imposed upon it as well as in order to provide you with a smooth, efficient and customised experience using the Hotspot Services or any Other Services. The collection, use and disclosure of Personal Information enables us, our partners and affiliates and our third party services providers to provide services and products that are most likely to meet your needs and requirements.
• Generally, we collect Personal Data in the following ways:-
  • when you submit your registration for the Hotspot Services or any of the Other Services as well as our and their respective representatives and/or agents;
  • when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, emails or social media;
  • when you request that we contact you, be included in an email or other mailing list;
  • when you respond to our promotions, initiatives or to any request for additional Personal Information;
• If you provide us with any Personal Information 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 Information for the respective purposes set out in this Privacy Policy.
• You shall ensure that all Personal Information 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 Hotspot Services and /or the Other Services you may have requested.

Storage of Information

• The Personal Information and other data we collect from you may be transferred to, processed and stored in our servers or the servers of our partners, affiliates and third party services providers.
• We will usually keep your Personal Information as long as is necessary to fulfil any of the purposes described in this Privacy Policy, or to comply with any contractual or legal requirement but in any event no longer than 7 years. This provision is also applicable for EU and Swiss residents.
• DataPro will use reasonable endeavours to maintain appropriate physical, electronic and organisational procedures to ensure that your Personal Information and other data is treated securely and in accordance with this Privacy Policy, and to protect such data against unauthorized access or unauthorized alteration, disclosure or destruction of data. DataPro has constructed our Website and Self-Service Ticket Kiosk using industry standard encryption and authentication tools to protect your Personal Information. When we collect your Personal Information through the Website, App or Self-Service Ticket Kiosk, we encrypt this information and attempt to prevent unauthorized access to it by using industry standard technologies, such as encryption software, routers and firewalls
• Unfortunately, due to the nature of the Internet, we cannot completely guarantee that your Personal Information is completely protected. DataPro does not give any representation, warranty or undertaking that the Personal Information you provide to us will be secure at all times, and to the extent DataPro has fulfilled its obligations under no circumstances shall DataPro be responsible for any losses, damages, costs and expenses which you may suffer or incur arising from unauthorised access to or use of your Personal Information.
• All payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using online encryption technology. You are responsible for keeping your chosen password confidential and not to share your password with any third party.

Usage of Information

• DataPro will not sell or rent your Personal Information to third parties.
• DataPro will use Personal Information and other data collected to provide you with the Hotspot Services or Other Services, to continually improve the Hotspot Services or the Other Services and to contact you in relation to the Hotspot Services and Other Services, to provide customer support and to provide you with timely notice of new products and services and special offers.
• From time to time, we may also make use of your Personal Information to contact you for feedback on your use of Hotspot Services and/or the Other Services provided to assist us in improving the said Hotspot Services and Other Services or to offer special savings or promotions to you, where you have indicated your consent to receiving such communications. If you would prefer not to receive notices of special savings or promotions, you may simply opt-out from receiving them by replying to us through the hyperlink provided in such notices.
• We may also use your Personal Information for the following purposes:-
  • to respond to your queries and requests;
  • to manage our administrative and business operations and complying with internal policies and procedures;
  • to resolve complaints and handle requests and enquiries;
  • to prevent, detect and investigate crime and analyse and manage any commercial risks;
  • to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;
  • to conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
  • to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
  • for any other purpose which we may notify you at the time of obtaining your consent.
• If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), we may, from time to time, contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services or those products and services offered by our partners and affiliates and third party services providers (including discounts and special offers). You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. To do so, you may contact us at DPO@hotspot.travel

Disclosure of Information

• We may from time to time share and disclose your Personal Information and other data to third parties as specified in this Privacy Policy, some of whom may be located outside your home country. The circumstances under which such sharing and disclosure will take place may include without limitation, the following “-
  • to successfully complete your registration and/or purchase of the Hotspot Services and/or the Other Services;
  • to our third party service providers (including Google Analytics), which we engage amongst others for the performance of certain services on our behalf, such as web hosting services, data analysis, marketing, market research, and to otherwise provide you with customer service;
  • DataPro may be legally required to disclose your Personal Information, if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our rights; (d) necessary to protect us and our employees from legal action or claims from third parties; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of DataPro and employees, and affiliates.
  • to our advisors, agencies or other parties concerned in order to protect the rights and property of DataPro and our employees.
• In case of a corporate transaction, in connection with the sale, merger, acquisition, or other corporate reorganization or restructuring of our corporation, your Personal Information may be disclosed, shared or transferred to the new controlling entity or its authorised third party for carrying on our business.
• In any other case, to any third parties with your prior written consent (and in which case we will make it possible for you to withdraw your consent as easily as it was to provide consent).
• You understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Website, App and Self-Service Ticket Kiosk.
• Your Personal Information may be transferred outside of your home country and outside of the European Union, for the above mentioned purposes. If such transfer takes place to a country that does not provide an adequate level of protection, DataPro will use reasonable endeavours to ensure that appropriate safeguards are in place.
• There may be links present on the Website, App or Self-Service Ticket Kiosk which could result in you leaving the Website, App or Self-Service Ticket Kiosk and/or being taken to other third party websites or mobile applications. You should note that any Personal Information that you provide to these third party websites/mobile applications are not subject to this Privacy Policy and DataPro is not liable for any losses, damages, costs or expenses which you may suffer or incur in connection with you providing or making available Personal Information or other data to such third party websites.

Cookies

• The Website, App and Self-Service Ticket Kiosk uses “Cookies” to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. Enabling cookies on the Website and App will allow our Website and App to function properly. Conversely, if you disable cookies on the Website or App, you may not be able to experience the full functionality of the Website and App.
• We never place Personally Identifiable Information in Cookies.
• By proceeding without changing your settings, you agree to receive all cookies and other data collection tools. However, if you do not accept the use of these cookies, you can change your cookie settings at any time.

Automatic Information

• We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered the Website/App, if any, as well as the name of the website to which you’re headed when you leave the Website/App. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet website provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our Users to help improve our website.

Changing Your Information

• You may at all times access, correct or erase your Personal Information by sending your request by email to DPO@hotspot.travel
• Where mandatory under applicable legislation, you may also request restriction of processing of your Personal Information or object to processing by sending your request or objection by email to DPO@hotspot.travel. You may also request a copy of the information that we hold about you by sending your request by email to DPO@hotspot.travel
• Please contact us via DPO@hotspot.travel iif you have a complaint regarding the processing of your Personal Information.
• When handling a data access or correction request, we have the right to check the identity of the requester to ensure that he/she is the person entitled to make the data access or correction request.

Enquiries

• If you have any questions about this Privacy Policy, please contact us by email to DPO@hotspot.travel

Dispute Resolution

• Any dispute arising out of or in connection with the Website, App, Kiosk and the Hotspot Services and/or Other Services shall be governed and construed by the laws and courts of the Republic of Singapore.