Privacy Policy

1. Personal Data

   1. “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the Cover Projects Group has or is likely to have access to, including existing data in our records which you have provided us, in any submissions you may have made to us or via any form of interaction with us.
   2. Examples of Personal Data include, but are not limited to, the following, or any combination of the following:
      1. name,
      2. identification numbers,
      3. address,
      4. email,
      5. telephone number,
      6. birth date,
      7. food allergies,
      8. photograph, image, picture, recording, film footage, likeness or other characteristics or identification, or such other medium in which your likeness may appear,
      9. credit card number/bank details,
      10. passport details, and/or
      11. other non-public information such as your IP or device MAC ID Address.
   3. “Non-Personally Identifiable Information”: We may also collect information that cannot be used to identify or contact you (hereafter referred to as “Non-Personally Identifiable Information”), such as demographic information (e.g., age, job position/title, profession, gender or reason for call) and physical information (area of call, general customer type). Non-Personally Identifiable Information may also include browser types, domain names and other anonymous statistical data created by aggregating user information collected through the use of our Website. Non-Personally Identifiable Information is used to help us better understand the characteristics of the individuals or businesses that may use our Services. We use the information collected and aggregated to improve and market our Services to you, and other individuals or businesses. In the event that we link any Non-Personally Identifiable Information with your Personal Data, we will treat such information as Personal Data and only use such information in accordance with this Privacy Policy.

2. How we Collect Personal Data

   1. We may collect, use, disclose and/or process Personal Data about you when you make any submissions via our Website, or in the course of providing us (directly or indirectly through third party service providers such as online travel agents) with information in order for us to render our Services to you or for the purposes of any actual or potential transaction with us. We may also collect, use, disclose and/or process Personal Data about you when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position.
   2. The purposes for which we may collect, use, disclose and/or process such Personal Data are set out below at paragraph 3.
   3. Our service providers also mass aggregate client data as part of their general business practices. Such aggregated data is used to identify and analyze trends to improve our systems and to create derivative materials that may be marketed to potential clients and used to service current clients; it does not contain your Personal Data.
   4. We also may supplement the information we collect with information from other sources to assist us in providing our Services to you. In addition, we may use this supplemental information in evaluating and improving our Website or Services and to determine your preferences so that we can tailor our Website and Services to your needs.
   5. When data is aggregated, we remove all personally identifiable information prior to use.

3. Purposes for the Collection, Use and Disclosure of your Personal Data

   1. Generally, the Cover Projects Group collects, uses and discloses your Personal Data in respect of the following purposes:
      1. to provide our Services to you, anyone involved in the process of making your travel or accommodation arrangements (e.g. online travel agents, group travel organisers, your employer) and vendors (e.g. payment gateways, credit card companies, airline operators and other loyalty programmes) in accordance with any agreements;
      2. to communicate with you on our promotions, Services, events, programmes, and initiatives, including products and services of other companies of the Cover Projects Group;
      3. to communicate with you on our vendors’, agents’, contractors’, third-party service providers’ or business partners’ (collectively referred to as our “Partners”) promotions, services, events, programmes and initiatives;
      4. to receive and respond to your enquiries, requests, or feedback on our Website or Services, including suggested improvements;
      5. to process and administer your actual or potential transactions with us (including, but not limited to, provision by us of Services or provision of products or services by you to us);
      6. to process your registrations as a registered user of the Website;
      7. to verify your identity and/or eligibility for discounts and promotions or activities or events organised by or on behalf of the Cover Projects Group;
      8. to facilitate our and/or our Partners’ provision of products and services to you;
      9. to manage our administrative and business operations and to comply with our internal policies and procedures, including any employment policies and practices;
      10. to facilitate business asset transactions (including, but not limited to, asset sales, mergers or acquisitions involving any of our companies);
      11. to obtain your feedback or participation in surveys, market research and/or analysis for statistical, profiling or other purposes to enable us to customise, review, improvise and develop our Services, to understand customer preferences, behaviour and market trends;
      12. to conduct data analytics, including to maintain, improve and customise our products and services, to analyse your behavioural patterns and to offer personalised products and services to you;
      13. to manage the safety and security of our premises including but not limited to conducting security clearances and carrying out CCTV surveillance, granting or refusing admission to our premises;
      14. to respond to any claims, actions or proceedings and/or to safeguard and enforce our contractual and legal rights and obligations;
      15. to manage and prepare any reports regarding incidents or accidents;
      16. to comply with any applicable rules, laws, regulations, codes of practice or guidelines as well as to assist in investigations and law enforcement by the relevant authorities; and/or
      17. any other purpose reasonably related to any of the above.
   2. If you submit an application to us as a candidate for an employment or representative position, the Cover Projects Group collects, uses and discloses your Personal Data in respect of the following purposes:
      1. processing your application including pre-recruitment checks, such as in relation to your previous employment, credit standing and qualifications;
      2. background screening / vetting including obtaining employment or character references provided by you;
      3. facilitating and conducting interviews in-person or over video-conferencing means;
      4. assessing your suitability for the position you have applied for;
      5. communicating with you as required by the Cover Projects Group to comply with our policies and processes, including for business continuity purposes; and/or
      6. any other purposes relating to the aforesaid.

      You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may affect the application result, cause delays to the processing of your application, or our inability to process your application.

   3. For any other purpose(s) not set out herein, the Cover Projects Group may notify and seek your further consent in accordance with the requirements of any applicable laws, regulations, codes of practice, guidelines or rules before using your Personal Data for that other purpose(s).
   4. You can generally use and browse our Website without disclosing your Personal Data to us (subject to paragraph 3.1 above), except where such disclosures may be necessary to allow us to respond to your requests, or in cases where you contact us directly in respect of our Services.

4. Disclosure of Personal Data to Third Parties

   1. Subject to the provisions of any applicable law and in order to carry out the purposes listed at paragraphs 3.1 to 3.3 above, we may disclose your Personal Data to the following third parties for any of the purposes described in this Privacy Policy:
      1. related corporations or affiliates of the Cover Projects Group;
      2. Partners contracted by the Cover Projects Group to perform functions including those listed at paragraph 3.1 above;
      3. Partners contracted by the Cover Projects Group (and the sub-contractors of such Partners) to provide our Services;
      4. banks or other financial institutions, credit card companies, payment processors or gateways, secretarial agents, billing organisations, or similar, and their respective service providers;
      5. our Partners, investors, assignees or transferees (actual or prospective) to facilitate business transactions which may include any merger, acquisition or asset sale or transfer;
      6. our professional advisors, which may include lawyers, auditors, accountants or other consultants;
      7. law enforcement agencies, relevant government ministries, regulators, statutory boards or authorities in compliance with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
      8. any other person to whom you authorise us to disclose your Personal Data to.
   2. The Cover Projects Group will use all commercially reasonable endeavours to ensure that our employees, officers, Partners and such other third parties who have access to your Personal Data observe and adhere to the terms of this Privacy Policy.
   3. We may also disclose or share your Personal Data, without notice, but only if required to do so by law or in the good faith belief that any such action is necessary to: (a) comply with any legal requirements or comply with legal process served on us or the Website; (b) protect and defend the rights or property of the Cover Projects Group; and (c) act under exigent circumstances to protect the personal safety of our customers, users of our Website, or the general public.

5. Consent to Collection, Use and Disclosure of Personal Data

   1. By submitting information to us, communicating with us, accessing or viewing any of the Cover Projects Group’s Websites, or signing up for any Services offered by any member of the Cover Projects Group, you agree and consent to the Cover Projects Group collecting, using, and disclosing your Personal Data amongst ourselves or to our Partners, in the manner set forth in this Privacy Policy (including for the purposes as stated in paragraph 3.1 above).
   2. When you provide the Cover Projects Group with any Personal Data relating to a third party (including, but not limited to, information on your dependants, spouse, children and/or parents), you represent and warrant that you are authorised to do so and/or the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data by us for any of the purposes listed herein.

6. Withdrawing your Consent

   1. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the purposes listed herein by submitting your request via email to our Data Protection Officer at the contact details provided below or by clicking on the unsubscribe link.
   2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same. In general, we shall seek to process your request within thirty (30) days of receiving it.
   3. Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose your Personal Data where such collection, use and disclosure without consent is permitted or required under the applicable laws.

7. Accuracy of Personal Data

   1. Subject to paragraph 7.2, we will take reasonable efforts to ensure that your Personal Data is accurate and complete in particular, if your Personal Data is likely to be used by us to make a decision that affects you, or is to be disclosed to another organisation.
   2. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data via the process at paragraph 8 below. We will not be responsible for any loss or damage suffered by you arising from our reliance on inaccurate or incomplete Personal Data due to you not updating us of any changes in your Personal Data that you had initially provided us with.

8. Access and Correction of Personal Data

   1. If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
   2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
   3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under any relevant laws).

9. Protection of Personal Data

   1. The Cover Projects Group will take reasonable steps to secure your Personal Data against any unauthorised access, collection, use, disclosure, copying, modification or similar risks and ensure that access to your Personal Data is limited to persons whom we reasonably believe require access for effective delivery of our Services to you for the purposes listed herein (where applicable) or any other purpose as consented by you.
   2. Unfortunately, even with these measures, we cannot guarantee the security of Personal Data. By using our Website or our Services, you acknowledge and agree that we make no such guarantee, and that you use our Website or our Services at your own risk.

10. Retention of Personal Data

    1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
    2. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

11. International Transfers of Personal Data

    1. Your Personal Data may be transferred from the country, state and city in which you are present while accessing our Website or using our Services (“Home Country”) to another country, state and city (“Alternate Country”). This may include transfers to other entities under the Cover Projects Group which are located outside your Home Country. The transfers to the Alternate Country may be required where Cover Projects Group’s servers and/or our Partners are located in the Alternate Country. Your Personal Data may also be stored and processed in the Alternate Country, including where you submit such Personal Data directly to our Partners or third-party service providers who operate in the Alternate Country.
    2. By submitting your Personal Data to any member of the Cover Projects Group, our Partners or third-party service providers, or signing up for any Services offered by any member of the Cover Projects Group, you consent to such transfer, storing or processing for the purposes described in this Privacy Policy or for the provision of Services to you by the Cover Projects Group. The Cover Projects Group will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
    3. When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including putting appropriate safeguards in place to ensure an adequate level of protection for your Personal Data. We will also comply with any applicable legal and regulatory obligations so that the recipient in the Alternate Country is also obliged to protect your Personal Data at a standard of protection comparable to the protection under the applicable laws of your Home Country.

12. IP Addresses

    1. hen you use or access our Website, we may collect and store information about your computer (including, but not limited to, your IP address, operating system and browser type) for the purposes of system administration, processing, and related analysis.

13. Cookies

    1. Our Website uses cookies to distinguish you from other users of our Website. We may also collect website traffic and statistical data, including but not limited to your browsing actions and patterns, individually or in the aggregate, for the purposes of system administration, processing, and related analysis. Such information assists in increasing efficiency when you browse our Website and enables us to improve our Website for a better user experience
    2. Should you wish to disable the cookies of our Website, you may do so by changing the settings on your browser. However, you may not be able to enter, view or experience certain part(s) of our Website.

14. Third Party Websites

    1. Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please ensure you carefully read and review the privacy policies of these websites before you submit any Personal Data to these websites.

15. Data Protection Officer

    1. You may contact our Data Protection Officer if you have any enquiries or feedback relating to your Personal Data or our Privacy Policy via e-mail to the following:
       Attention: Data Protection Officer
       Email Address: dpo@coverprojects.com
    2. Please note that for any Personal Data provided to us by a third party (including, but not limited to, any third-party service provider, online travel agents, your company, a recruiter or a parent), you should contact such party to write to us in respect of any queries, feedback, complaints, or access and correction requests regarding your Personal Data on your behalf.

16. Updates to Privacy Policy

    1. The Cover Projects Group may from time to time update this Privacy Policy to ensure it is consistent with our business requirements, industry trends and/or changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our Website.
    2. Any updates to the Privacy Policy will be effective fourteen (14) days following the date on which this Privacy Policy is updated and posted on our Website.

17. Governing Law

    1. This Privacy Policy shall be governed in all respects by the laws of Singapore.

18. Disclaimers

    1. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE IN ANY EVENT FOR ANY SPECIAL, EXEMPLARY, PUNITIVE, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES OF ANY KIND OR FOR ANY LOSS OF REPUTATION OR GOODWILL, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), EQUITY, STRICT LIABILITY, STATUTE OR OTHERWISE, SUFFERED AS A RESULT OF UNAUTHORISED OR UNINTENDED USE, ACCESS OR DISCLOSURE OF YOUR INFORMATION (INCLUDING ANY PERSONALLY IDENTIFIABLE INFORMATION).

Effective Date: XX August 2021