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Privacy Policy

This Privacy Policy applies to all users who access the SATS website (as defined below) and/or use the Services (as defined below), and to all customers (including prospective customers) of SATS (as defined below).

For the purpose of EU General Data Protection Regulation (“GDPR”) and applicable data protection laws, the data controller responsible for the collection, processing and use of your personal data in connection with the provision of the Services and/or your access to the SATS website is SATS Ltd of 20 Airport Boulevard, Singapore 819659.

 

How to contact us or make a complaint?

For any queries regarding this Privacy Policy, please contact the SATS Data Protection Officer at the following:

SATS Ltd

20 Airport Boulevard

Singapore 819659

Attention: The Data Protection Officer

Email: dpo@sats.com.sg

 

If you would like to unsubscribe from receiving our mailings or do not want us to share your email address with other parties, please email us at satscom@sats.com.sg.

​​Key Terms

It would be helpful to start by explaining some key terms used in this Privacy Policy:

Personal data” means information that identifies you such as name, photo or contact details or data that can be linked with such information in order to identify you. It does not include data where your identity has been removed, known as anonymous data.

 

“SATS website" and "Site" refer to:-

·         The website www.sats.com.sg in its entirety including all its individual web pages, and

·         Any other websites in their entirety including all their individual web pages, operated by SATS from time to time, now or in future (including without limitation www.satscargo.com).

 

"Services" mean any services that SATS may provide or require on the SATS website from time to time (including without limitation SATS Cargo's Track and Trace facility). 

"User" and "you" refer to any individual, firm, corporation, organisation or entity who accesses the SATS website or uses the Services. 

"we", "us" and "SATS" refer to SATS Ltd., and its subsidiaries and associated companies, or any of them.

For users who access the SATS website and/or use the Services

By accessing / using the SATS website and/or the Services, you agree to this Privacy Policy and where you have provided your opt-in consent as appropriate, consent to the collection and use by SATS of certain personal data from or about you, in accordance with the terms of this Privacy Policy.

We have the right to amend, revise or change this Privacy Policy (or any part thereof) from time to time and when we do so, we will notify you by posting a notice on this website.

By accessing the SATS website and/or using the Services, you agree to be legally bound by any such amended, revised and/or changed Privacy Policy. It is therefore your responsibility to read this page prior to any future access to and use of the SATS website. If you do not agree to the amended, revised and/or changed Privacy Policy, kindly cease accessing the SATS website and/or using the Services immediately.

As we cannot distinguish the age of persons who access and/or use the SATS website, a blanket Privacy Policy is applied. If a child or a person below the age of 18 has provided us with personal data without parental or guardian consent, the parent or guardian should email the Data Protection Officer immediately to remove the information and unsubscribe the user. SATS does not intend to receive information from persons below the age of 18.

Quick guide to contents

·         What personal data do we collect?

·         How is personal data collected?

·         How and why do we use personal data?

·         Who do we share personal data with?

·         How long do we keep personal data for?

·         Do we transfer personal data overseas?

·         Do we make automated decisions?

·         What are your rights?


Personal data we collect from you

We collect or may collect the following types of information about you:

  • General statistical information about users for general reporting and to improve future content. Such information may include service provider, browser type, pages accessed on the SATS website, which website you may originate from or visit, and which pages you visited within the SATS website;
  • Personal data about you to provide you with a range of personalised services, depending on how you use the SATS website;
  • Records of any email or other correspondence that you send via the SATS website; and
  • Your IP address, name, mailing address and email address, and cookie information.

We do not typically collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we typically collect any information about criminal convictions and offences.

How is personal data collected?

Our SATS website and Services may use cookies and other tracking technologies.

A cookie is a small string of information that a website transfers to your browser for identification purposes.

Cookies perform many functions, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that advertising that you see online is more relevant to you and your interests.

Your use of our website indicates your consent to the cookies described in this policy.

Type of cookie

What does it do?

Strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like room bookings or e-payment, cannot be provided.

Performance cookies

These cookies collect information about how you use our website, for instance which pages you go to most often, and if you receive error messages from certain web pages. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the website works. By using our website, you agree that we can place these types of cookies on your device.

Functionality cookies

These cookies allow the website to remember choices you make (such as your language of choice or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of the web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on websites operated by third parties. By using our website, you agree that we can place these types of cookies on your device.

Targeting or advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of our advertising campaigns. They also remember when you have visited the website before.  Sometimes we share anonymised information about your browsing activity with our advertising and creative partners.  They may use this information to advertise products, which  may interest you, on other websites or to assist us develop  future advertising campaigns.

Our advertisers may also set cookies separately in your computer, over which we have no control.

If you prefer not to receive cookies, you can configure your Internet browser to reject them or to notify you if they are being used. You may also delete existing cookies through your browser. Please note that rejecting cookies may limit the functionality of the SATS website.

Generally, you can visit most parts of the SATS website without telling us who you are, revealing any information about yourself and/or allowing the use of cookies; however, some services may not be accessible unless your personal data is supplied and allowing the use of the abovementioned cookies.

How and why do we use personal data?

We will only use your personal data when the law allows us to. If you are located in the European Economic Area (“EEA”) or Switzerland, we are required to disclose the legal basis for processing your personal data under applicable laws.

SATS may use and disclose the information collected from you through the SATS website for the following purposes and on the following legal bases:

  • For the purpose(s) for which the personal data was requested, and related purposes to allow us to perform our contractual obligations to you;

·         For the legitimate interest of SATS, SATS' affiliates or other third parties (such as governmental bodies or courts), in particular:

o    performing the contract under which you are a beneficiary;

o    conducting research, analysis and audits to understand your interest for marketing information and updates, cross-selling or cross-promotion of goods and/or services in relation to SATS or other individuals, firms, corporations, organisations or entities that have an agreement or understanding with SATS, other direct marketing and customer relationship activities, and customising our content for you to better meet your needs as a customer, provided this is in line with your marketing choices;

o    evaluating and implementing  potential merger and acquisition activities; and

o    enforce contractual and legal rights and obligations and/or to prosecute or defend legal actions or other proceedings,

except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data;

·         To comply with applicable law, regulation, the requests of governmental and regulatory authorities, or orders of court that SATS is subject to;

  • For any other purpose for which we have obtained your prior informed consent.

For customers (including prospective customers) of SATS

We have the right to amend, revise or change this Privacy Policy (or any part thereof) from time to time without prior notice or subsequent notification to you.

We collect or may collect the following types of information from you:

  • Personal data about you to provide you with a range of personalised services;
  • Records of any email or other correspondence that you send to SATS; and
  • Your name, passport details, billing information, travel arrangements, mailing address and email address.

SATS may use and disclose the information collected from you for the following purposes:

  • For the purpose(s) for which the personal data was requested, and related purposes;
  • For billing, baggage operations, checking in and account opening;
  • For SATS’ requirements and purposes such as research, audit and analysis and to help us improve our goods and services, content and advertising;
  • To respond to your queries and requests and to communicate with you;
  • To send you information, updates, promotions, and marketing and advertising materials in relation to SATS and its goods, products and/or services (including without limitation, customising the content for you, and to contact you on updates), or those of any individual, firm, corporation, organisation or entity having an agreement or understanding with SATS with respect to the cross-selling or cross-promotion of goods and/or services;
  • To comply with applicable law, regulation, the requests of governmental and regulatory authorities, or orders of court;
  • To enforce contractual and legal rights and obligations and/or to prosecute or defend legal actions or other proceedings; and/or
  • For any other purpose for which we have obtained your consent.

Who do we share personal data with?​

We only share your personal data in compliance with applicable law. We do not share if for any other purpose. We may disclose the personal data collected from you to:

·         a member of the SATS group of companies, including subsidiaries and affiliates, in order to enable you to access the SATS website, request the Services, to process your payments, understand your preferences, send you information about products and Services that may be of interest to you and conduct the other activities described in this Privacy Policy; and

 

·         service providers engaged by SATS to provide marketing, advertising, communications, IT services, to personalise and optimise our website and Services, to analyse and enhance data (including data about users' interactions with our Services), and to provide legal, accounting, insurance, audit and other professional services. These service providers are contractually bound only to use personal data to perform the services that we engage them to provide.

We may also be required to share or transfer your personal data to third parties permitted by applicable law in order to comply with a legal or regulatory obligation that we are subject to and/or to enforce our legal rights (e.g. police or judicial authorities).

When SATS appoints service providers to perform any services on its behalf, we will use reasonable endeavours to ensure that such service providers abide by this Privacy Policy, e.g. by imposing contractual obligations on them to ensure they can only use your personal data to provide services to us and you.

We do not sell your name or other personal data relating to you to third parties.

There could be situations where SATS may decide to sell, buy, consolidate or restructure its business due to any strategic or other business reasons. Such transactions may involve the sharing or transfer of your personal data to prospective or actual buyers. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties. Any transfer of personal data is only done to the extent permitted by applicable law.

Your personal data will at all times be held securely and handled with the utmost care in accordance with applicable law.

How long do we keep personal data for?

We will only keep your personal data for as long as is necessary for us to use your personal data as described above or as permitted under applicable law. This means that we may also retain your personal data where it is in our legitimate interest, or to comply with our legal obligations. However, please be advised that we may retain some of your personal data after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including: 

·         our contractual obligations and rights in relation to the information involved;

·         legal obligation(s) under applicable law to retain data for a certain period of time;

·         our legitimate interest where we have carried out a balancing test;

·         statute of limitations under applicable law(s);

·         (potential) disputes;

·         if you have made a request to have your information deleted; and

·         guidelines issued by relevant data protection authorities.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Do we transfer personal data overseas?

Yes. We may need to transfer information to other SATS group companies, service providers or business partners in countries outside of your country.

·         From within the EEA to outside the EEA

We may need to transfer personal data outside of the EEA, including to Singapore.

If we send your information to a country that is not in the EEA, we will make sure that your information is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer. If a country is not considered to have laws that are equivalent to EU data protection standards, we will ask the third party service provider to enter into a legal agreement that reflects those standards.    

·         From within another country (not in the EEA) to outside of that country

If we send your information from a country (not in the EEA) outside of that country, then we will make sure that your information is protected to at least the same standard as that which is required in the originating country. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.

Do we make automated decisions?

We do not envisage that any decisions will be made about you using automated means. However, we will notify you if this position changes.

What are your rights?

By law, you have a number of rights when it comes to your personal data. Please contact us using the contact details of our SATS Data Protection Officer set out below to exercise any of your rights.

If you are located in the EEA or Switzerland, your rights include the following:

Rights

What does this mean?

1.              The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

2.              The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.

3.              The right of access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this privacy policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

4.              The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.

5.              The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions – for example, this does not apply if processing of data is necessary for SATS to comply with legal obligations or handle legal claims.

6.              The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

7.              The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

8.              The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

9.              The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

 ​

If you would like to exercise any of your rights, please contact our Data Protection Officer at the following:

SATS Ltd

20 Airport Boulevard

Singapore 819659

Attention: The Data Protection Officer

Email: dpo@sats.com.sg

In exceptional circumstances, and to the extent permitted by law, we may refuse such requests. Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

Keeping your personal data secure

SATS has put in place appropriate security measures to protect the personal data you share with us and to prevent it from being lost, used or accessed in an unauthorised way, altered or disclosed. On your part, if you become aware of any security breach, please let us know as soon as possible.

Others

Please do not share any user identification, password, personal identification number or other authentication information, if any, used by you on the SATS website, with anyone. SATS will not be responsible or held liable for lapses in security caused by unauthorised third party access arising directly or indirectly out of your failure to keep such information confidential.

The SATS website may contain links to third party websites whose data protection and privacy policies may differ from ours. We are not responsible for the content and privacy practices of these other websites and you should check and consult the privacy policies/notices of those websites before accessing them and/or providing any personal data to them.

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