Privacy Policy
Desaru Link Ferry Services Pte Ltd (DLFS) values the information that our partners and customers share with us. We commit to protecting that information and ensure that such is only used for relevant purposes, the primary purpose of which is for enhancing your experience and enjoyment of our website and services offered.
By using the DLFS website, you agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully before transacting with us, visiting or using our website, or otherwise providing us with any of your personal data. Unless you opt out and instruct us otherwise, we do and will continue to retain and data that we collect from you with other DLFS subsidiaries, partners, and affiliates, including that outside of Singapore, as permitted under applicable local laws and the Singapore Personal Data Protection Act (“PDPA”).
This Privacy Policy outlines DLFS policy and responsibility in relation to the collection, processing, and disclosure of your data. This document describes DLFS’s general policy and also addresses visitor data issues specific to the usage of the DLFS website and related mobile services facility.
GENERAL DATA PRIVACY POLICY STATEMENT
TYPES OF USER/ GUEST/PARTNER DATA (“PERSONAL DATA”)
The types of information that DLFS collects depend on the circumstances of collection and on the nature of the service requested or transaction undertaken. There are two broad categories of Personal Data that we collect at DLFS:
Personal Data which is personal information that links back to an individual e.g., name, address, phone number, and email address;
Statistical Data e.g., the number of hits to the website, etc. This is stored purely for analytical purposes and is entirely anonymous. This information will not be stored in your personal record and will only be aggregated for statistical analysis so that we can better understand the DLFS website visitor profile and improve our service offerings.
PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE
Collection
Generally, DLFS collects Personal Data in order to fulfill the following purposes:
Providing services to you such as memberships, newsletter subscriptions, processing a transaction e.g. making a booking, registration for membership or events, providing membership-related alert messages through our online and mobile services facility, and internet check-in.
Marketing and communicating with you in relation to products and services offered by DLFS, our affiliates and service partners, as well as our appointed agents; and safety, security, statutory and legal compliance.
Processing and Disclosure
DLFS may process and disclose your Personal Data, as applicable, to third parties, such as our Guests, partners, transportation service providers or travel-related businesses, partners, terminal and airport/seaport management, security personnel, and other carriers for the purpose of processing your travel arrangements. DLFS shall use its best endeavors to ensure that its employees, officers, agents, consultants, contractors, and such other third parties mentioned above who are involved in the collection, processing, and disclosure of Personal Data will observe and adhere to the terms of this Privacy Policy.
DLFS may disclose your Personal Data to law enforcement agencies and the government for security, customs, and immigration purposes. For example, Batamfast, DLFS’ appointed ferry operator, and other carriers are required by laws in Singapore and other countries to provide Immigration and Checkpoints Authority (ICA) with access to your booking information or trip itinerary. Accordingly, relevant Personal Data (known as Passenger Name Record (PNR) or Advance Passenger Information (API)) may be disclosed to the appropriate customs and immigration authorities as required by law. Please be informed that the initial recipients of such information may share your PNR and API data with other government agencies or enforcement authorities.
In addition, DLFS may disclose Personal Data to our lawyers and legal advisors for establishing, exercising, or defending our legal rights, or as otherwise authorized or required by law. DLFS will also reserve the right to share your Personal Data as is necessary to prevent a threat to the life, health, or security of an individual or a corporate entity. Furthermore, DLFS may disclose Personal Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement, or privacy.
TRANSFER OF INFORMATION OVERSEAS
DLFS Head Office is based in Singapore. Personal Data may be transmitted to data storage facilities where we keep our central records. Your Personal Data is transferred for DLFS to perform our contract with you (if any). The Personal Data may also be transferred to our offices and appointed agents in other countries in connection with our performance of the contract with you.
CONSENT
Generally, in the course of DLFS service functions such as membership registration or newsletter sign-ups. In such instances, consent will necessarily be implied from the users of the platform that they are agreeable to providing Personal Data in order for DLFS to provide the requested or necessary service and/or product to them. However, where required by law, DLFS will adopt an ‘opt-in’ policy for attaining customer consent, in which event, express written consent will be sought from you when collecting your Personal Data e.g., signing a form or checking a box.
In addition, you are able to withdraw your express consent at any time by contacting DLFS or amending your Personal Data by logging on to your website account. (Note: this service only applies to registered membership accounts through our website).
DLFS will not seek consent for Statistical Data as this is not linked to a personal record.
ACCESS
Upon logging in to your system account, DLFS allows you to view and update your stored Personal Data. We reserve the right to charge a reasonable administrative fee for this service if required. In exceptional circumstances, DLFS reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include where:
an investigating authority or government institution objects to DLFS complying with a customer’s request,
the information may, in the exercise of DLFS reasonable discretion and/or assessment, affect the life or security of an individual, and
data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
RETENTION
DLFS will retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required by relevant laws.
If you have ceased to be a member or cancelled your subscription, DLFS will not send you marketing materials or share your personal data with unrelated third parties. However, DLFS may still retain your records and use your information for legal and/or business purposes, including for compliance with the PDPA or other laws.
If you do not want your personal data to be shared among affiliates or partners of DLFS, you may opt-out of such information-sharing by sending us the appropriate withdrawal of consent form in the following link: PDPA-Consent-Withdrawal-From.pdf Please note that if you withdraw your consent for a limited purpose, such as for marketing, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such personal data may still be shared, as permitted under the PDPA and other applicable law. If you do not wish to receive any further information from us regarding DLFS products, offers, promotions, or special events via email, you may unsubscribe by clicking the unsubscribe link included in our email correspondence.
ACCURACY
DLFS needs your assistance to ensure that your Personal Data is current, complete, and accurate. As such, please inform DLFS of changes to your Personal Data by contacting DLFS and submitting your updated particulars to DLFS in writing. If you are a member or a registered website user, or a newsletter subscriber, you may log onto your website account. DLFS may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Processing and Disclosure” sub-section, your membership information or newsletter subscription may be disclosed to the appropriate authorities as required by law. As such, it is important to ensure that the Personal Data contained in your membership or newsletter subscription should also be current, complete and accurate.
SECURITY SAFEGUARDS
DLFS takes the security and protection of your Personal Data very seriously. As such, DLFS uses procedural and technical safeguards to protect your Personal Data against loss or theft as well as unauthorized access and undue disclosure.
Examples of technical safeguards include encryption, “firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Personal Data collected through our websites and our mobile services facility are set out in the next section below.
If, however, you do not take reasonable care to ensure the continued confidentiality and accuracy of your Personal Data, DLFS will not be liable for any consequential misuse and/or fraud.
UPDATES TO THE PRIVACY POLICY
DLFS reserves the right to amend or change this Privacy Policy from time to time and the updated versions will be posted on our website and date stamped so that you are aware of when the Privacy Policy was last updated. If we make material changes to the Privacy Policy, we will post any changes on this page. We encourage you to review this page periodically to understand our policy regarding the collection and use of your personal data.
Subject to applicable laws, the prevailing language of the Privacy Policy will be English. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.
Your continued use of our website and acceptance of our services at DLFS after any changes to this Privacy Policy constitutes your consent to any such changes; to the extent such consent is not otherwise provided.
PRIVACY POLICY FOR PERSONAL DATA COLLECTED THROUGH OUR WEBSITE AND OUR MOBILE SERVICES FACILITY
SECURITY SAFEGUARDS
DLFS takes the protection of your Personal Data on our website and through our mobile services facility very seriously. All Personal Data collected through our websites, e.g., http://www.desaruferries.com, and through our mobile services facilities are protected by a secure server. In addition, data encryption ensures secure transmission of data from the internet to our systems. For example, when you transmit sensitive information such as credit card details through our website, such information will be automatically converted into codes before being securely dispatched over the internet. To further secure the integrity of your internet transactions on our websites, DLFS also employs relevant software programs to monitor network traffic with a view to identifying unauthorized attempts to upload or change Personal Data, perpetuating fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies.
To give you secure access to our online services, arising from your utilization of our mobile services facility, and your membership account, you can register with us, and we will give you a membership number/ User ID with a PIN that is unique and personal to you. You should not share your membership number/User ID or PIN, and should always log off once you have finished your session on the websites as well as take the recommended precautions that ensure the safe and secure provision of our mobile services facility. As an additional security feature, DLFS has implemented a time stamp showing the time you have been on our websites and the last time you logged out. If you detect any anomalies you should inform DLFS immediately. DLFS has also provided a lock out feature in the event you fail to log in successfully after a number of attempts. Also, if you leave our Website idle for a period of time, we will give you a ‘warning’ dialogue box giving you the option to end your session.
COOKIES
Most websites like ours use cookies to enhance your online experience. Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive from your web browser to recognise your preferences and to tailor content to you. The cookies do not contain your Personal Data (unless you specifically chose our “Remember Me” feature) but only Statistical Data which is entirely anonymous. Please refer to your browsers documentation to check if cookies have been enabled on your computer or to request not to receive cookies.
Information and procedures regarding cookie handling are provided by the respective browsers documentation within the browser itself by clicking on ‘help’ and performing a search on ‘cookies’.
CLICKSTREAM DATA
In order to improve your online experience, DLFS may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.
LINKS TO OTHER WEBSITES
DLFS provides you with links to other websites for your convenience and information. Whilst DLFS will protect your Personal Data on DLFS websites, cannot DLFS control the policies of other sites we may link to, or the use of any Personal Data you may share with them. Please note that DLFS Privacy Policy does not cover these other websites, and would DLFS recommend that you are apprised of their specific policies.
MINORS
DLFS cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided DLFS with Personal Data without parental or guardian consent, the parent or guardian should contact DLFS to remove the relevant Personal Data and unsubscribe them
FEEDBACKS AND TESTIMONIALS
As a mechanism for continuous quality improvement, DLFS provides a platform for Guests and Hosts to share and receive testimonials and comments regarding their experiences on their travel experiences. We may publish such information from time to time at our sole discretion. By submitting such testimonials and comments, you allow us to publish such content. Please note that any Personal Data, Property Data, or other information you submit through our website can be read, collected ,or utilized by visitors and users of this site and you could receive unsolicited emails. We are not responsible for the Personal Data, Property Data ,or other information which you decide to allow for testimonials.
OTHER LIMITATIONS
DLFS takes reasonable and best practices to protect and to prevent unauthorized access to your data. However, we are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express or implied, that we will prevent unauthorized access to your private information.
We shall not be liable for any damages, be it consequential, direct, incidental, indirect, punitive, or otherwise – in connection with a third party’s unauthorized access to your personal data, the property data, or any other user-provided information. This is regardless of the basis of such damages – whether contractual, strict liability, tort, or other theories of liability, and also notwithstanding even if DLFS was given actual/constructive notice on the possibility of damages.