1. Types of Customer Data
The types of Customer Data that SIA collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.
There are two broad categories of Customer Data that SIA collects:
- Personal Data, which includes but is not limited to -
(i) personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;
(ii) contact information e.g., address, phone number, email address;
(iii) payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
(iv) travel information e.g., flight information, dietary and seating or other service preferences;
(v) health information e.g., medical records or requests;
(vi) technical information e.g., IP address; and
- Statistical Data e.g., number of passengers flown, hits to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand SIA's customer profile and improve SIA's service offering.
For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.
The provision of Customer Data (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for SIA to carry out its services to you.
The failure to supply such Customer Data may result in (i) SIA being unable to provide you with the services and/or products requested; (ii) SIA being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by SIA.#160;
- Personal Data, which includes but is not limited to -
2. Purposes for Collection, Use and Disclosure
Generally, SIA collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., your travel agent or our service provider), or from publicly available sources, through our website, mobile services, and other channels including our ticketing counters and airport operations, in order to fulfil the following purposes, which include but are not limited to:
- Providing services to you such as processing a transaction (e.g., making a booking), providing technical assistance, assisting you in the transaction, providing flight alert messages through SIA’s mobile services facility, facilitating internet check-in and registering for SIA’s frequent flyer programme;
- Providing in-flight catering and other services that best meet your preferences and needs (which we may collect during our interactions with you);
- Marketing and communicating with you in relation to products and services offered by SIA, SIA’s airline and service partners, as well as SIA’s appointed agents;
- Contacting you for product or customer satisfaction surveys and market research; and
- Safety, security and legal compliance.
SIA may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above.
In connection with the above, we may disclose your Customer Data to third parties, such as our travel and freight service providers or travel-related businesses, partner airlines, airport management, security personnel, and other carriers.
SIA may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.
SIA may disclose your Customer Data to law enforcement agencies and government for security, customs and immigration purposes. For example, SIA and other airlines are required by laws in the United States of America and other countries to provide border control agencies with access to your booking information or flight itinerary. Accordingly, relevant Customer 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, SIA may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. SIA also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entities such as SIA. Further, SIA may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.#160;
3. Transfer of information overseas
The SIA Head Office is based in Singapore. Customer Data may be transmitted to data storage facilities where SIA keeps its central records. Customer Data may be transferred to SIA’s offices and appointed agents in Singapore or other countries in connection with SIA’s performance of the contract with you.#160;
You may submit a request to withdraw your consent at any time by contacting SIA (see Section 10) or by logging on to your website account with SIA (if you are a KrisFlyer frequent flyer member or a non-KrisFlyer member registered as a user of SIA’s websites).
Statistical Data is not linked to a customer record and SIA does not need to seek consent for the collection, use or disclosure of Statistical Data. For more information on the collection and usage of Customer Data obtained from SIA’s websites and through SIA’s mobile services facility, please refer to Part B.#160;
SIA will, upon your written request to our Customer Affairs Department (see Section 10), allow you to view your stored Personal Data. Where permitted by law, SIA reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, SIA 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 SIA complying with a customer’s request,
- The information may, in the exercise of SIA’s 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.
To submit a written request to Customer Affairs Department to access your Personal Data, please use the following form:
Request for Report of Personal Data form#160;
SIA will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of SIA, or as required by relevant laws.
When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.#160;
SIA needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform SIA of changes to your Personal Data by contacting SIA and submitting your updated particulars to SIA in writing (see Section 10). If you are a KrisFlyer frequent flyer member or a registered website user, you may update your Personal Data at any time by logging on to your website account with SIA.
SIA may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Purposes for Collection, Use and Disclosure” sub-section, your booking information or flight itinerary may be disclosed to the appropriate customs and immigration authorities as required by law. As such, it is important to ensure that the Personal Data contained in your booking information or flight itinerary is current, complete and accurate.#160;
8. Security safeguards
SIA takes the security and protection of your Customer Data very seriously. As such, SIA makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure.
As an example of a procedural safeguard, SIA has implemented various authentication procedures internally and with our external service providers that may involve SIA requesting various personal particulars from you in order to verify your identity (or that of your duly authorised agent) before SIA processes your request for a particular service, product or transaction.
Examples of technical safeguards include encryption, “firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through SIA’s websites and SIA’s mobile services facility are set out at Part B below.
If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, SIA will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact SIA (see Section 10).#160;
10. Contact us
Customer Affairs Manager
Singapore Airlines Customer Affairs Department
07A Airline House
25 Airline Road
Alternatively for queries specific to KrisFlyer, you may contact:
KrisFlyer Membership Services
PO Box 177
Singapore Post Centre Post Office
1. Security safeguards
SIA takes the protection of your Customer Data collected on SIA’s websites and through SIA’s mobile services facility very seriously. All Customer Data collected through SIA’s websites, e.g., http://www.singaporeair.com and through SIA’s mobile services facility are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems.
For example, when you transmit sensitive information such as credit card details through SIA’s websites, such information will be encrypted before being dispatched over the internet.
To further strengthen the integrity of your internet transactions on our websites, SIA also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate 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 without notice to you.
To give you secure access to our online services, arising from your utilisation of SIA’s mobile services facility, and your frequent flyer 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 SIA’s mobile services facility.
As an additional security feature, SIA has implemented a time stamp showing the time you have been on SIA’s websites and the last time you logged out. If you detect any anomalies you should inform SIA immediately (see Section 10 of Part A). SIA 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 SIA’s website idle for a period of time, we may give you a ‘warning' dialogue box giving you the option to end your session.#160;
Cookies are small files placed on your computer by websites that you visit or certain emails you open.
Online behavioural advertising
Purposes of cookie collection and use
To enable the efficient working of the SIA websites, including but not limited to:
a) balancing website traffic to ensure all users receive consistent and reliable service;
b) limiting traffic to key parts of the website in order to maintain performance levels; and
• Ease of use
Cookies are used to make navigation easier for you, including but not limited to:
a) remembering your language and country selections and presenting relevant content;
b) keeping track of your KrisFlyer membership number when you have logged in; and
c) providing the most relevant departure airport for your location when you are booking a flight.
Cookies are used to gather statistics on how you navigate and transact on our websites, including but not limited to:
a) gathering feedback on your satisfaction through a survey; and
b) gaining insight into how you navigate and transact on our websites so that improvements can be made to its usability.
Cookies are used to enable SIA to present appropriate messages to you, including but not limited to:
a) allowing our websites to serve up different versions of a page for marketing purposes;
b) allowing third parties to display appropriate advertising and to track its effectiveness; and
c) displaying of relevant messages, which offer a selection of products based on your viewing behaviour on our websites and other selected websites.
Partnership with Adara
SIA partners advertising network, Adara (adara.com), to capture non-personally identifiable data from you through third-party cookies. This enables Adara to display targeted and relevant messages from selected third-party websites, based on your viewing behavior on the SIA websites and other selected websites.
There are two ways for you to opt-out of cookie use:
• By visiting http://adara.com/privacy-promise/opt-out and clicking ‘Submit’; or
• Through the Network Advertising Initiative (NAI) or the Digital Advertising Alliance’s (DAA) Self-Regulatory Program for Online Behavioral Advertising, of which Adara is a member. Each of these programmes provides an opt-out page where you can exercise control over members’/participants’ cookies from a central location. To opt-out of NAI members’ or DAA participants’ cookies, visit:
o NAI: http://www.networkadvertising.org/managing/opt_out.asp
o DAA: http://www.aboutads.info/choices/#160;
3. Clickstream data
In order to improve your online experience, SIA 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.#160;
4. Links to other websites
SIA cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided SIA with Customer Data without parental or guardian consent, the parent or guardian should contact SIA (see Section 10 of Part A) to remove the relevant Customer Data and unsubscribe the minor.#160;
6. Google Analytics