EAGLEWINGS GROUP PRIVACY POLICY

This privacy policy ("Policy") sets out the manner in which the EagleWings Group of Companies ("Group" or "EagleWings Group") and that of its Entities ("Entities") - comprising EagleWings Yacht Charters Pte Ltd, EagleWings Loft Pte Ltd, EagleWings Gifts Pte Ltd, and EagleWings Cinematics Pte Ltd, (the Group and its Entities collectively, "We"), collects, uses, retains and discloses Personal Data in compliance with the provisions of the Personal Data Protection Act 2012 (amended by the Personal Data Protection (Amendment) Act 2020 ("PDPA")).

"Personal Data" for the purposes of this Policy means data that is capable of identifying an individual, whether on its own or in conjunction with other data accessible to us.

Age of Majority

By using our website(s) and/or platform(s), you represent that you are at least the age of majority in your country of residence, or that you are the age of majority in your state or province of residence, where applicable.

Changes to Policy

By using any of our website(s) and platform(s), whether as a visitor, Member and/or Supplementary Member (collectively, "You"), you accept that we reserve the right to change, update or amend this Policy at any time, and without prior notice, with effect from the date of publication on our website(s).

You are advised to read the Policy every time you visit our website(s) and/or platform(s) to ensure that you understand how your Personal Data is collected, used, retained and/or disclosed. We will not be liable for any loss (including any indirect or consequential loss) or damage incurred by you by reason of you not having read the changes, updates and/or amendments to the Policy or not having been informed of such changes, updates, and/or amendments.

A link to the current Policy will be available on our website(s). By using our website(s) and/or platform(s) after changes, updates and/or amendments have been made to the Policy, you agree to be bound by and are subject to the respective changes, updates, and/or amendments.

Information Collection

We collect Personal Data including names, mailing addresses, e-mail addresses, mobile numbers, etc. when such Personal Data is voluntarily provided or submitted by you as visitors or users to our website(s) and/or platform(s) for such goods and/or services as may be provided by us and/or pursuant to the EagleWings Membership Programme (as stipulated in the EagleWings Membership Programme Terms and Conditions).

By providing or submitting your Personal Data to us or the Personal Data of any third party individual to us, you agree to be bound by the terms of this Policy and to receiving further communications from us.

Purpose Notification

Information will only be used according to the purpose for which it was collected, unless permission had been given to use it for other purposes.

We collect, use or disclose Personal Data for inter alia, the following purposes:

(a) providing any goods and/or services offered by us or performing obligations under contracts entered into with you;

(b) ensuring the content of the website(s) and platform(s) are presented in the best way for a user and the user's computer or mobile device;

(c) providing you with information about products or services that you have requested for or which we consider may be of interest to you;

(d) allowing you to use the various features of the services, website and/or platforms;

(e) improving and/or enhancing the services offered to you and/or developing new goods, services, methods and/or processes for our operations;

(f) disseminating information for marketing, product evaluation and/or statistical purposes;

(g) identifying goods or services that may be suitable for you and/or personalising or customising such goods and/or services;

(h) enabling us to recover any debt owed to us;

(i) using or disclosing information for any investigations and/or proceedings;

(j) entering into, managing and/or terminating an employment relationship or appointment;

(k) transferring information to data intermediaries to facilitate any of the purposes stated above;

(l) for any other purposes for which your consent has been obtained.

Third Party Personal Data

When you provide Personal Data from individuals other than yourself to us either for the purposes of obtaining goods and/or services from us or pursuant to the EagleWings Membership Programme, you warrant that you have explained the purpose for the collection of such Personal Data to the said individuals, and have obtained their consent to the disclosure of such Personal Data to us, and to the use us of such Personal Data in accordance with the terms of this Policy.

Technology Tracking

Our website(s) and platform(s) use cookies and tracking technology, which are useful for gathering information such as browser type and operating system, recording the number of site/platform visitors and understanding how visitors use the site/platform. Cookies can also help adjust the site/platform for visitors. Personal Data cannot be collected through cookies and other tracking technologies. However, if you had previously provided personal identity information, cookies can be connected to that information. The types of cookies aggregated and tracking information may be communicated to third parties.

Some of our cookies may remain on your device after a browsing session. You can disable our cookies by changing the settings on your browser but doing so might mean that you will be unable to use certain features of our website(s) and platform(s).

We also collect information which is sent to us by your web browser. When you browse the website and platforms, we automatically receive your computer's Internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.

Disclosure of Personal Data

We may share information with government agencies and/or other companies that are involved in investigation and/or fraud prevention. Circumstances under which this could occur is inclusive of when: (1) permitted or required by law, or, (2) trying to protect or prevent fraud, or other issues that have the potential to lead to fraud or unauthorised transactions, or, (3) investigating a fraud that had occurred, or is suspected of having taken place. Such information will not be provided to other companies for marketing purposes.

We may also disclose your Personal Data if it is necessary to facilitate any investigation for breach of the terms of any contracts entered into with us or breach of the Membership Programme Terms and Conditions, or to enforce any of our rights thereunder.

Subject to applicable laws including the PDPA, we may also share your Personal Data:

Information about an individual may also be shared where that individual has made that information public by posting or uploading it on or to the public areas of our website(s) and/or platform(s).

Data collected from individuals may be transferred to and stored in destinations [outside Singapore and may be processed by staff operating outside Singapore]. By submitting an individual's Personal Data, you warrant that the individual agrees to the collection, use, transfer and storage of his or her Personal Data in accordance with the terms set out in this Policy.

In general, data intermediaries or other third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to provide such goods and/or perform such services required by us.

However, where applicable, certain data intermediaries or third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these service providers, we recommend that you read their privacy policies in order to understand the manner in which your personal information will be handled by these providers.

Consent to Participate and/or Vote

Wherein an individual provides his personal data to us or consents to participate in membership, promotional, and/or voting campaigns or attends any events organised by us, he or she shall be deemed to have consented to the collection, use and disclosure of Personal Data set out in this Policy ("Consent"). Photographs, videos, voice, likeness and image recording and other recordings ("Media") may be taken by us and/or our organisers at events organised by us. By attending any of these events, whether as a participant, guest, staff or volunteer, you consent to and grant to us and/or our organisers the right to use such Media for our internal record purposes, publicity purposes, commercial advertising and/or distribution to our sponsors and partners.

Consent granted pursuant to any of the foregoing shall remain valid until such a time when a written withdrawal request is made to us. Applying for membership, participating in promotion(s) or events organised by us and/or expressing an intent to vote shall amount to an expressed Consent. Upon withdrawal of Consent, the said individual will permanently cease to enjoy all benefits of membership, including attendance at events or participation in promotions, and voting rights and privileges across the entire Group and/or Entities.

Withdrawal of Consent

Withdrawal of Consent must be made in writing to the Data Protection Officer and sent via e-mail to dpo@eaglewings.group or by post to the address stipulated below. Withdrawal shall take effect no longer than 30 days from the time of the request having been received by us. We shall not be liable for requests that fail to reach our inbox.

Consent to vote may involve the use of mobile number and/or e-mail address as a means for vote casting

Commitment to Data Security

We will put in place reasonable security measures, and will follow industry practices to ensure that your Personal Data is stored in a secure manner.

Only our employees, agents and contractors will have access to your Personal Data. All e-mails and SMSes will include the option to opt out.

However, you should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data transmitted to our website and/or platforms via the internet. You should take steps to keep your data secure by protecting your password and other account credentials for your membership or other accounts with us.

Links To Other Websites

Our website(s), platform(s), and e-mail(s) may contain links to other website(s) and/or platform(s), which data collection and privacy practices may be different. We will not be liable for the content and privacy policies of these other companies. You are advised to consult their privacy policies before using their websites and/or platforms.

Once you exit from our website(s) and/or platform(s) or are redirected to a third-party website or application, you are no longer governed by this Policy or any of our website(s) and/or platform(s) terms and conditions

Access and Correction

If you wish to make an access request for a copy of your personal data or for information about the way in which we use, retain or disclose your personal information or make a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at dpo@eaglewings.group. Please note that a reasonable fee may be charged for the handling and/or processing of an access request, and we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. If we are unable to provide you with any personal data or make a correction requested by you, we will generally inform you of the reasons as to why we are unable to do so.

Accuracy and Retention

In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by writing to our Data Protection Officer at the addresses set out below. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected for use, or as may be required or permitted under applicable laws.

Governing Law

This Policy forms part of the EagleWings Membership Programme Terms and Conditions and shall be governed and construed in accordance with laws of the Republic of Singapore.

Any dispute arising out of or in connection with this privacy policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the courts of Singapore.

Data Protection Officer

You may contact the Group's Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures or if you wish to make an access or correction request by writing in either via email or via post to the following addresses

If by email to dpo@eaglewings.group or if by post, to 9 King Albert Park, #01-30, Singapore 598332.

This Privacy Policy was updated on 21 March 2021