The Spa Nomad Pte. Ltd. (“our”, “us”, or “we”) takes its responsibilities under applicable privacy laws and regulations seriously and is committed to respecting the privacy rights and concerns of all users of our website (“Website”) and the services we provide as described on our Website (the “Services”). We recognise the importance of the personal data you have entrusted to us, and believe that it is our responsibility to properly manage, protect and process your Personal Data (as defined below).
“Personal Data” is defined in the Personal Data Protection Act 2012 as 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 organisation has or is likely to have access.
By visiting this Website and using our Services, you acknowledge and agree that you accept the practices described in this Policy, and you hereby consent to the collection, use, disclosure, transfer and/or processing of your information and Personal Data by us as set out in this Policy. If you do not consent to the use, disclosure, transfer and/or processing of your Personal Data as described in this Policy, please do not use our Website or Services.
You should be aware that the Internet is not a fully reliable transmission medium. Third parties may unlawfully intercept or access Personal Data transmitted to or contained on the Website, technologies may malfunction or not work as anticipated, or third parties may access, abuse or misuse information through no fault of ours. We shall not be liable for any data transmission errors such as data loss or damage or alteration of any kind, including but not limited to any direct, indirect or consequential damage, arising out of your use of this Website.
Information We Collect
We may collect Personal Data about you which you provide to us when using this Website, or when sent to us through other means, such as via telephone, mobile messaging applications or e-mail. Such information may include but is not limited to:-
- your name;
- date of birth;
- telephone number;
- e-mail address;
- bank account and payment information;
- information sent by or associated with the device(s) used to access our Website or Services;
- any other information about you when you use our Website or Services and information related to how you use our Website or Services; and
- aggregate data on the content you engage with.
It is important that the Personal Data we hold about you is accurate and current. You agree not to submit any information to us which is inaccurate or misleading, and you agree to keep us informed if your Personal Data changes during your relationship with us. We reserve the right to require you to provide such further documentation as may be required to verify the information you provide.
If you would like to opt out or withdraw your consent for us collecting, using and/or processing your Personal Data, please notify us via e- mail at: email@example.com with attention to our Data Protection Officer. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship you have with us.
We may also collect other information which may be connected to your Personal Data, including without limitation your device’s Internet Protocol (IP) address, geographic data, browsing patterns including the pages you visit on our Website, search preferences as well as other generic Internet usage related data. Such information may be collected automatically through “cookies”, pixel tags and web beacons as you navigate through the Website.
We may from time to time implement “cookies” or other features to allow us or third parties to collect or share information that will help us improve our Website or help us offer new services and features. “Cookies” are identifiers transferred to your device that will allow us to recognise your device and tell us how and when the Website is being used or visited and to track activity within the Website. We may link such “cookie” information to Personal Data. You may opt out of the use of “cookies” by selecting the appropriate settings on the browser on your device, though this may have an impact on the functionality of our Website.
When We Collect Such Information
We may collect such Personal Data and other information about you, including without limitation:-
- when you submit any form, including but not limited to, booking forms, enquiry forms, analysis forms and any other forms relating to any of our products and Services;
- when you enter into any agreement or provide any information in connection with your interactions with us, or when you use our Services;
- when you interact with us in any manner whatsoever, including but not limited to telephone calls, letters, face-to-face meetings, social media platforms, mobile messaging applications and e-mails;
- when you carry out transactions in connection with our Services;
- when you provide us with feedback or complaints; or
- when you submit your Personal Data to us for any reason.
Usage and Disclosure of Information
We may collect, use, disclose and/or process your Personal Data and other information collected for one or more of the following purposes:-
- for identification and verification;
- to consider, respond to and/or process your booking requests for Services;
- to deal with or facilitate customer service, including responding to your queries (or any queries purported to be made by you);
- to contact you or communicate with you via telephone, mobile messaging applications, e-mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, including but not limited to communicating administrative information to you relating to our Services;
- to manage, operate and/or administer your use of and/or access to our Website and your relationship with us;
- to enforce our Terms and Conditions of Sale;
- to conduct research, analysis and development activities including but not limited to data analytics, surveys, product and service development and/or profiling;
- to analyse how you use our Website;
- to improve our Services or products;
- to improve or enhance your customer experience;
- to estimate or validate audience size, composition and usage patterns;
- to produce statistics and research for internal and statutory reporting requirements;
- to send you by various modes of communication marketing and promotional information and materials relating to our products and/or Services, unless you inform us otherwise;
- to carry out due diligence in accordance with legal or regulatory obligations or our risk management procedures as required by law or our internal policies;
- to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements;
- to prevent or investigate any unlawful activity whether relating to your use of our Services or any other matter arising from your relationship with us;
- to store, host, back up your Personal Data whether for disaster recovery or otherwise;
- to deal with and/or facilitate a purchase, sale, lease, merger, amalgamation or any other acquisition or disposal involving us or any of our business assets; and/or
- any other purposes which we may notify you of at the time of obtaining your consent,
(collectively, the “Purposes”).
In conducting our business, we may be required to disclose your Personal Data to certain third parties, whether located in or outside of Singapore, for one or more of the Purposes. Such third parties will be processing your Personal Data either on our behalf or otherwise for one or more of the Purposes, and include without limitation:-
- our employees, representatives and agents;
- our subsidiaries, affiliates and related companies;
- service providers, contractors and other third parties supporting our business;
- a buyer or other successor in the event of a merger, divesture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of our business assets; and
- such other third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.
All such parties will be under an obligation to maintain the security and confidentiality of such Personal Data and process the Personal Data only in accordance with our instructions.
We may disclose aggregate information about users without restriction. This may include the sharing of statistical and demographical information about our users and their use of the Services with suppliers of advertisements and programming, but will not include anything that may be used to identify you specifically or to discover individual information about you.
Save as mentioned above or as required or permitted under applicable law, we will not disclose your Personal Data to any other third parties without your consent.
Protection and Retention of Personal Data
We have put in place reasonable security measures in order to prevent unauthorised access, disclosure, use, copying, modification, accidental loss or destruction of your Personal Data, and in particular, we limit access to your Personal Data to those selected employees, agents, contractors and other third parties who have a business need to know.
We will only retain Personal Data in accordance with applicable law for as long as it is reasonably necessary to fulfil the purpose for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will destroy or anonymise your Personal Data when we have reasonably determined that: (a) the purpose for which that Personal Data was collected is no longer being served by the retention of the same; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant the further retention of such Personal Data. Subject to applicable law, we may securely dispose of your Personal Data without prior notice to you.
Access to and Correction of Personal Data
Under applicable law, you may be entitled to request access to your Personal Data under our possession, enquire about the ways your Personal Data has been used over the past year, or submit a complaint with regards to our use of your Personal Data. To protect your privacy and security, we will take appropriate measures to verify your identity before granting access or making changes to your Personal Data.
Any such requests or complaints should be made via e-mail to: firstname.lastname@example.org with attention to our Data Protection Officer. We may charge you a reasonable fee for the handling and processing of your requests, and will provide you with a written estimate of the said fee where applicable.
We keep our Policy under regular review, and may revise this Policy to reflect changes in the law or our Personal Data processing practices. The date this Policy was last revised is set out at the end of the Policy. You will be deemed to have consented to any amendment to the Policy when you use this website on and from the effective date of the last revision.
You agree that this Policy and any disputes relating to this Policy shall be governed by the laws of Singapore. Any dispute arising out of or in connection with this Policy or any such access or use will be subject to the exclusive jurisdiction of the Singapore courts.
Last updated: 6 August 2019
Any actual or attempted tampering with any part of this website or conduct of fraudulent activities on or through this website is strictly prohibited. You agree that you will not breach or violate the security of this website or attempt to do so, and that you will not misuse our website by knowingly introducing bugs, viruses or other malicious material. You further agree that you will not attempt to gain unauthorised access to our website, the server on which our website is stored or any server, computer or database connected to our website.
We are the owner or the licensee of all intellectual property rights in this website and in the material published in it, including but not limited to all text, information, analyses, reports, graphics, software, video and audio files, photos, trademarks and service marks (“Website Content”). The Website Content is intended for the personal, non-commercial use of its users, and is protected by local and international copyright, trademark and/or other intellectual property or proprietary rights laws.
Any downloading or other copying of Website Content does not vest any title in you, and we reserve the right to terminate at any time your right to make personal or non-commercial copies. Except to the extent permitted by law, you may not reproduce, transmit, modify, adapt, distribute, reverse engineer or in any way exploit any of the Website Content without our prior written approval.
We may, at our discretion, modify or discontinue any or all of the Website Content or any portion thereof at any time with or without notice.
Where this website contains links to other websites and resources provided by third parties, these links are provided for your information only and should not be interpreted to imply an endorsement, recommendation, or a representation or warranty of any kind, by us with respect to the third party website, its operator, content or related services. We do not review or monitor any linked third party websites and expressly disclaim any responsibility or liability for your access to or use of such other sites.
We do not guarantee that our website site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.
No Warranties and Exclusion of Liability
While we use reasonable efforts to ensure the accuracy of information on this website, the Website Content is provided on an “as is” basis with no warranties of any kind. We do not warrant that the information on the website is accurate, reliable, up-to-date or correct or that this website will be secure or free from bugs, viruses or other malicious material. Your use of this website and use or reliance upon any of the Website Content is solely at your own risk.
We hereby exclude all implied conditions, warranties, representations or other terms that may apply to our website or any content on it, and we will not be liable for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with the access, use or inability to use this website or any Website Content, and in particular, we will not be liable for any indirect or consequential loss or damage ( “Losses”). Notwithstanding the foregoing, we do not exclude or limit in any way our liability to you where it would be unlawful to do so.
As consideration for your access to and use of this website, you agree to indemnify and hold us and our its affiliates, licensors, and service providers and its and their respective officers, directors, employees, contractors, agents, successors, and assigns (“Related Persons“) harmless from and against any and all Losses, including without limitation those related to any action by any third party against you, us or any of the Related Persons arising out of or in connection with your access to or use of this website or of any of the Website Content or your non-compliance with these Terms.
Nothing in these Terms is intended to modify or amend any other written agreement you may now or in the future have with us. In the event of any inconsistency between these Terms and any such other written agreement, the terms of the written agreement will prevail.
No failure or delay on our part to act with respect to any breach of these Terms by you or any other person constitutes a waiver or limits our rights with respect to such breach or any subsequent breach.
Headings are used in these Terms for convenience of reference only and do not affect the meaning of these terms. If any provision of these Terms is found to be invalid or unenforceable in any jurisdiction, neither the validity and enforceability of any other provision nor the validity and enforceability of the affected provision in any other jurisdiction will be affected.
These Terms constitute the sole and entire agreement between us with respect to this website and the Website Content and supersede all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, with respect to this website.
You agree that these Terms and any disputes relating to these Terms shall be governed by the laws of Singapore. Any dispute arising out of or in connection with this Policy or any such access or use will be subject to the exclusive jurisdiction of the Singapore courts.
Last updated: 23 July 2019