SilkAir Privacy Policy
Last Updated: 25 May 2018
This is the SilkAir (Singapore) Private Limited (“SilkAir”, “we”, “our”) Privacy Policy.
We are a corporation registered in the Republic of Singapore with company number 197500236D and a registered office at 25 Airline Road, Airline House, Singapore 819829. For the purpose of the General Data Protection Regulation (“GDPR”) and other applicable data protection laws, we are the data controller. Our data protection officer can be contacted at dpo@singaporeair.com.sg. Our representative in the European Union is Singapore Airlines’s (“SIA”) (our parent company) United Kingdom establishment, Singapore Airlines Limited,a branch registered at Building 11, Chiswick Park, 566 Chiswick High Road, London W4 5YS, United Kingdom.
SilkAir collects, uses and discloses Customer Data (as defined below) in order to provide you with a safe, smooth, efficient and customised experience with SilkAir. The collection, use and disclosure of Customer Data enables SilkAir to provide services and products that are most likely to meet your needs and requirements. This Privacy Policy outlines SilkAir’s policy and responsibility in relation to the collection, use and disclosure of Customer Data.
By continuing to use SilkAir’s services, you signify that you have read and understood this Privacy Policy.
What information do we collect about you?
We collect information when you purchase flights or other products on our website, mobile application or when you travel with us, such as your contact details, travel information and credit card details. We also collect information about your preferences from your interactions with our in-flight and ground-based staff, and from specific requests you make. In addition, we collect device and technical information from you when you use our website or mobile application. More Information
How will we use the information about you?
We use your information to fulfil our contract of carriage with you, to administer your membership with our frequent flyer programme, KrisFlyer and/or our corporate travel programme for small and medium enterprises, HighFlyer. We also use your information to maintain our website and mobile application, and to tailor our products and services to your preferences to provide the best service possible. In addition we use your information to market our products and services to you, and those of our group companies, partners and agents (with your consent where required by applicable law). More Information
Who do we share your information with?
We share your data with our third party service providers to the extent necessary for them to provide their services such as payment processors, ground-operating personnel and in-flight entertainment. We use these third parties services solely to process or store your information for the purposes described in this policy. We also share your information with our interline, code share and strategic alliance partners, other carriers who help us provide our services, related group companies and our overseas stations and with government bodies as required by law. More Information
Where do we process your information?
Our servers are located in Singapore, Germany, Japan and the United States. We transfer your information to airports and ground staff in destinations that you are flying to and where we operate. Our staff are located in our offices around the world. More Information
How long do we keep hold of your information?
We retain your information 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. We will usually keep your Customer Data for up to 7 years to ensure that any contractual disputes can be addressed. For EU and Swiss residents, we will endeavour to delete data within 30 days of a request for erasure or contact you if it will take longer. More Information
How can I exercise my rights over my information?
You may have various rights in relation to your data.
More Information for non-EU residents
More Information for EU and Swiss residents
Dispute Resolution
If you have any concerns or complaints, please contact us here.
How will we notify you of changes?
SIA will amend this Privacy Policy from time to time and the updated versions will be posted on SIA’s Website and date stamped so that you are aware of when the Privacy Policy was last updated. Please check back frequently to see any updates or changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice including by banner on our website.
The types of Customer Data that SilkAir 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 SilkAir collects:
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Personal Data. The data we collect includes but is not limited to:
(ii) contact information, such as mailing address, phone number, email address;
(iii) payment information, such as credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
(iv) travel information, such as ticket numbers, destinations, flight information;
(v) information on your other purchases made through SilkAir, such as tracking your purchases of chargeable seats, excess baggage, seat upgrades, purchases of hotels, car rentals and insurance through our website, packages such as the Singapore Stopover Holiday and other linked travel arrangements.
(vi) your customer preferences, such as dietary, seating, KrisShop purchases, places that you would like to visit or other service preferences;
(vii) information about your in-flight interactions with our staff, such as types of beverages requested or other in-flight requests and preferences;
(viii) information about your interactions with our ground staff, such as the details of any complaint cases, incidences of lost baggage, call details, and other information relevant to assist our ground staff to service you;
(ix) health information, such as doctors’ notes, medical certificates and letters requests related to medical conditions;
(x) information we receive from other sources e.g., our page on social media websites and
(xi) business contact information, such as the contact details of the employees of our vendors and corporate customers.
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Technical Data. This includes device and technical information you give us when using our website or mobile application (“Website”) such as IP addresses or other unique identifiers, cookies, mobile carrier, time zone setting, operating system and platform. Information on cookies may be found in our cookie policy.
For purposes of this policy statement, Customer Data means Personal Data and Technical Data.
We also use Customer Data to derive Statistical Data, such as the number of passengers. This is processed and 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 SilkAir's customer profile and improve SilkAir's service offering.
Special categories of information or “sensitive personal data”
Certain categories of Customer Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or “sensitive personal data” under the GDPR.
Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your travel arrangements that reveal or suggest something about you that could be considered “sensitive personal data”, or if you otherwise choose to provide such information to us (or a third party such as the travel agent through which you made your booking).
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if you request a particular type of meal, e.g. halal or kosher meals, this may imply or suggest that you are a member of a particular religion; or
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if you request specific medical assistance from us and/or an airport operator, e.g. the provision of a wheelchair, this may reveal that you have a particular medical condition.
How we collect data from you
SilkAir collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised and/or persons who have been validly identified as being your authorised representative (e.g. your organisation’s corporate travel manager) pursuant to our then-current security procedures).
SilkAir also collects Customer Data from third parties which are located in various countries. This includes, but is not limited to, travel agents including our subsidiary, Tradewinds Tours & Travel Pte Ltd (“Tradewinds”), KrisFlyer partners (which include, but are not limited to airlines and non-airlines such as Hilton, Avis, Hertz, American Express, the Economist and Esso), our service providers, other airlines to facilitate travel on code share or multi-airline flights, or through our Website, mobile services, any posts on our SilkAir-specific pages on social media websites and other channels including our ticketing counters and airport operations.
Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to SilkAir has authorised the disclosure, is informed of and agrees to the provisions of this Privacy Policy.
The collection of the following types of Customer Data is mandatory to enable SIA to fulfil our contract of carriage with you. These types of Customer Data are marked as mandatory on our booking form. If you do not provide this information, we will not be able to provide you with our services and/or products required.
Additional information may be mandatory if you are flying to a specific country, or if you are flying on behalf of a business registered in a specific country, e.g. your gender, nationality, passport number, the country of issue of your passport, the name, GST registration number and address of the business you are flying on behalf of, and your business email address and phone number. These mandatory fields will be clear when you make a booking.
The collection of the following types of Customer Data is mandatory to enable SIA to administer your membership with KrisFlyer: (i) title; (ii) last/family name; (iii) first/given name if you do not have a last/family name; (iv) date of birth; (v) email address; (vi) mobile phone number; (vii) mailing address; (viii) gender; (ix) nationality; and (x) whether you are an EU or Swiss resident.
The collection of the following types of Customer Data is mandatory to enable SIA to administer your membership with HighFlyer: (i) title; (ii) last/family name; (iii) first/given name if you do not have a last/family name; (iv) date of birth; (v) email address; (vi) mobile phone number; (vii) mailing address; (viii) gender; and (ix) nationality.
These types of Customer Data are marked as mandatory on our sign up form. If you do not provide this information, you will not be able to benefit from points accruals and membership tier benefits and we will not be able to provide you with our services and/or products required.
The failure to supply the following types of Customer Data will result in (i) SIA being unable to update you on our latest products and/or launches; and/or (ii) your inability to enter or participate in contests, promotions or redemption activities organised by SIA:
• Contact Information e.g. email address, telephone number; and
• Country of residence.
If you are an EU or Swiss resident, we are required to disclose the legal basis for processing your data under the GDPR and the Swiss Data Protection Act. We will use the Customer Data in the following ways:
In accordance with our contract of carriage with you, we will use the Customer Data to:
- process and assist you with any transactions related to your booking (e.g., making a booking, providing services related to the booking (e.g., seat selection, accommodation, insurance, etc.), fulfilling such booking) and investigation protential fraudulent transactions;
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notify you about changes to our services, including through flight alert messages via SilkAir’s mobile services facility;
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facilitate airport, internet check-in and self check-in;
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provide airport services such as processing information relating to connecting flights, arrangements at airports, and customs and immigration facilities;
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provide baggage related services such as processing of any baggage related queries, including mishandled or missing baggage claims; and
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provide in-flight catering and other services (e.g. to provide you with a personalised inflight experience);
As it is in our legitimate interests to be responsive to you, to provide customised services and marketing and to ensure the proper functioning of our products, services and organisation, we will use your Customer Data to:
- improve the Website and to ensure content from the Website is presented in the most effective manner for you and your device;
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administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
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monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
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send you surveys by email (including surveys related to the our KrisFlyer or HighFlyer programmes, if you are a member, as detailed below). You can opt-out of receiving these surveys at any time by contacting us;
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send you service emails, such as reminders when you have not checked out your purchases on our Website. You can opt-out of receiving service emails at any time by contacting us;
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respond to your enquiries, requests or feedback;
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enforce our terms, conditions and policies;
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allow you to participate in interactive features of the Website, when you choose to do so;
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customise our products and services to you, including by responding to and catering for your customer preferences;
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personalise the content you see on our Website;
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keep the Website safe and secure;
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aggregate Customer Data into anonymised statistical data (such as number of passengers flown on a particular journey), which we will use for statistical analysis so that we can better understand SilkAir's customer profile and improve SilkAir's service offering;
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to customise our marketing e.g. send you promotional offers based on your flight history. If you are an EU or Swiss resident, you can object to this profiling and opt-out of receiving such targeting marketing. For more information on this right, click here; and
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In relation to KrisFlyer:
a. facilitate membership-related transactions and services;
b. enable the member to log in using the KrisFlyer account on any of the platforms hosted by
SilkAir;
c. market and communicate to KrisFlyer members information on SilkAirand KrisFlyer promotions, contests, events and lucky draws, including those conducted by KrisFlyer program partners (with your consent where required by applicable laws);
d. contact KrisFlyer members regarding product and customer related surveys and market research;
e. respond to email and call enquiries from KrisFlyer members; and
f. provide services to celebrate special occasions.
- If you are a participating company under the HighFlyer programme (“Participating Company”) and if you are a Corporate Travel Manager (“CTM”) or Assistant Corporate Travel Manager (“ACTM”), we will use the Customer Data to:
i. facilitate Participating Company-related transactions and services;
ii. market and communicate to the CTMs and ACTMs information on SIA, SilkAir and HighFlyer promotions, contests, events and lucky draws, including those conducted by HighFlyer program partners (with your consent where required by applicable laws);
iii. contact the CTMs and ACTMs regarding product and customer related surveys and market research;
iv. respond to email and call enquiries from the CTMs and ACTMs; and
v. Send the CTMs and ACTMs programme information updates and other account related information.
- If you are a Participating Company under the HighFlyer programme and if you are a Corporate Traveller (“CT”), we will use the Customer Data to:
i. maintain your travel records in the Participating Company’s HighFlyer account;
ii. facilitate Participating Company-related transactions and services;
iii. contact the CTs regarding product and customer related surveys and market research; and
iv. respond to email and call enquiries from the CTs.
- if you are an employee of an entity with a contractual relationship with us:
i. to contact you to perform our services, and in particular, to monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery;
ii. enforce our terms and conditions against your employer; and
iii. communicate with you about products, services, promotions, events and other news and
information we think will be of interest to you.
If you are an EU or Swiss resident, you can object to this profiling and opt-out of receiving such targeted marketing. For more information on this right, click here.
With your consent where required by applicable laws, we will use your Customer Data to:
- send you marketing and promotional materials in relation to products and services offered by SilkAir and service partners, as well as SilkAir’s appointed agents; and including in relation to the KrisFlyer and HighFlyer programmes; and
- register you for KrisFlyer.
You have the right to withdraw your consent at any time by contacting us at MI_feedback@singaporeair.com.sg, by logging on to your KrisFlyer account for KrisFlyer members or by logging on to your HighFlyer account for HighFlyer Participating Companies.
SilkAir will share your Customer Data with selected third parties in the situations set out below:
- our travel and freight service providers or travel-related businesses and service providers (including ground personnel, security personnel, partner airlines, airport management, airport operators);
- our interline and code share partners so that they can fulfil their contract of carriage for the flights you booked through SilkAir and, where applicable, provide you with the relevant benefits of their frequent flyer programme. Where Customer Data is shared with such partners, the Customer Data will be used by that partner in accordance with their respective privacy policy. For a list of such privacy policies, click here;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
- analytics and search engine providers that assist us in the improvement and optimisation of the Website.
SilkAir will share your Customer Data with any member of our group, which means our overseas stations, our parent company and its subsidiaries and our subsidiaries, in order to better customise your preferences when you travel with SilkAir or any of our other group companies, such as SIA, Scoot Tigerair Pte. Ltd. (“Scoot”), and Tradewinds Tours & Travel Private Limited:
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For the purposes of our contact with you, ie. to:
i. fulfill bookings and facilitate flight transfers of passengers;
iii. manage passengers during flight disruptions and provide necessary assistance and services;
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As it is in our legitimate interests to be responsive to you, to provide customised services and marketing, to:
ii. providing an enhanced customer experience and personalising offers to passengers;
iii. anticipating the servicing needs of passengers on flights with us;
iv. understanding customers better through analytics and research (including marketing research) to support personalisation;
v. contacting customers about KrisFlyer and HighFlyer programme related updates, surveys and offers; and
- For the purposes of undertaking targeted direct marketing and other forms of marketing or advertisement, provided we have the consent of the recipient and/or have provided the opportunity to opt-out, in each case where required by applicable law.
SilkAir will 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. In particular, each of the passengers who are grouped under the same Passenger Name Record (“PNR”) number shall be deemed to be authorised representatives of each of the other passengers under the same PNR number.
SilkAir will disclose your Customer Data to law enforcement agencies, public or regulatory authorities, securities commissions or other organisations for security, customs and immigration purposes, if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with legal obligation, process or request;
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property, health or safety of us, our users, a third party or the public as required or permitted by law (including exchanging Customer Data with other companies and organisations for the purposes of fraud protection and credit risk reduction).
For example, SilkAir and other airlines are required by laws in the United States of America, France and other countries to provide border control agencies with access to your booking information or flight itinerary. Accordingly, relevant Customer Data (known as PNR or Advance Passenger Information (“API”) will be disclosed to the appropriate customs and immigration authorities as required by law.
We will also disclose your Customer Data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case Customer Data held by us about our customers will be one of the transferred assets; or
- to comply with legal obligations, processes or requests (such as disclosing Customer Data to executors in response to court orders).
In addition, SilkAir 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. SilkAir 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 SilkAir. Further, SilkAir will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
The SilkAir Head Office is based in Singapore. Customer Data will be transmitted to data storage facilities where SilkAir keeps its central records. Customer Data will be transferred to SilkAir’s offices and appointed agents, including groundhandling agents, sales agents and contact centre agents, in Singapore and around the world in connection with SilkAir’s performance of the contract with you.
This means that Customer Data will be transferred to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA") and Switzerland, and in particular to Singapore, Germany, Japan and USA where we have data centres.
We will transfer Customer Data to airports and ground crew in destinations that you are flying to in and where we operate. The Customer Data is transferred outside the EEA and Switzerland on the basis that it is necessary for the performance of the contract of carriage between you and SilkAir.
We will also transfer Customer Data to our interline and code share partners in West Asia and Africa, North Asia, Southeast Asia, Southwest Pacific for the purposes of performing any contract of carriage. Please click here for a list of our partners.
If you are an EU or Swiss resident, where we transfer Customer Data outside the EEA and Switzerland, this is done either on the basis that it is necessary for the performance of the contract of carriage between you and SilkAir, or that the transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and Decision 2010/87/EU as appropriate.
The Customer Data will also be processed by staff operating outside the EEA and Switzerland who work for us, for our suppliers or our business partners. Such staff are engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
If you are not a resident in the EU (Switzerland excluded), you may have certain rights in relation to the Customer Data we hold about you, which we detail below.
Access.
You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.
Where permitted by law, SilkAir reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, SilkAir reserves the right to deny you access to your Customer Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include (to the extent allowable under applicable law) where:
- an investigating authority or government institution objects to SilkAir complying with a customer’s request;
- the information may, in the exercise of SilkAir’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.
Correction.
You have the right to correct any Customer Data held about you that is inaccurate.
Feedback and complaints
If you have any concerns, feedback or complaints about the use and/or sharing of your Customer Data, we are open to receiving your feedback or complaints.
Exercise of Rights.
To exercise any of your rights, please use the following form: Data Privacy Rights Form and submit it to MI_feedback@singaporeair.com.sg. For KrisFlyer members, you may correct any Customer Data by logging into your KrisFlyer account under the section titled “Profile”.
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 Customer Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include (to the extent allowable under applicable law) where:
Correction.
You have the right to correct any Customer Data held about you that is inaccurate.
Feedback and complaints
If you have any concerns, feedback or complaints about the use and/or sharing of your Customer Data, we are open to receiving your feedback or complaints.
Exercise of Rights.
To exercise any of your rights, please use the following form: Data Privacy Rights Form and submit it to saa_feedback@singaporeair.com.sg. For KrisFlyer members, you may correct any Customer Data by logging into your KrisFlyer account under the section titled “Profile”.
If you are a resident in the EU or Switzerland, you may have certain rights in relation to the Customer Data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.
These rights include:
- The right of access. More Information
- The right of data portability. More Information
- The right of rectification. More Information
- The right of erasure. More Information
- The right to restrict processing. More Information
- The right to object. More Information
Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please use the following form: Data Privacy Rights Form and submit it to MI_feedback@singaporeair.com.sg.
Complaints.
In the event that you wish to make a complaint about how we process your Customer Data, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.
You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.
If you require more than one copy of the Customer Data we hold about you, we may charge an administration fee.
We may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person) or where another exemption applies.
Portability.
You have the right to receive a subset of the Customer Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Customer Data to another party.
The relevant subset of Customer Data is data that you provide us with your consent (please see here for the types of Customer Data we process on the basis of your consent: How we use your Customer Data or for the purposes of performing our contract with you (please see here for the types of Customer Data we process on the basis of our contract with you: How we use your Customer Data.
If you wish for us to transfer the Customer Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Customer Data or its processing once received by the third party. We also may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person).
Correction.
You have the right to correct any Customer Data held about you that is inaccurate. Please note that whilst we assess whether the Customer Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
To exercise any of your rights, please use the following form: Data Privacy Rights Form and submit it to MI_feedback@singaporeair.com.sg. For KrisFlyer members, you may correct any Customer Data by logging into your KrisFlyer account under the section titled “Profile”.
Erasure.
You may request that we erase the Customer Data we hold about you in the following circumstances:
- you believe that it is no longer necessary for us to hold the Customer Data we hold about you;
- we are processing the Customer Data we hold about you on the basis of your consent (please see here for the types of Customer Data we process on the basis of your consent: How we use your Customer Data, and you wish to withdraw your consent and there is no other ground under which we can process the Customer Data;
- we are processing the Customer Data we hold about you on the basis of our legitimate interest and you object to such processing (please see here for the types of Customer Data we process on that basis: How we use your Customer Data. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Customer Data;
- you no longer wish us to use the Customer Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
- you believe the Customer Data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing of the Customer Data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Customer Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
Where you have requested that we erase Customer Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Customer Data or providing links to the Customer Data to erase the Customer Data too.
To exercise any of your rights, please use the following form: Data Privacy Rights Form and submit it to MI_feedback@singaporeair.com.sg. For KrisFlyer members, you may correct any Customer Data by logging into your KrisFlyer account under the section titled “Profile”.
Restriction of Processing to Storage Only.
You have a right to require us to stop processing the Customer Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Customer Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).
You may request we stop processing and just store the Customer Data we hold about you where:
- you believe the Customer Data is not accurate for the period it takes for us to verify whether the Customer Data is accurate;
- we wish to erase the Customer Data as the processing we are doing is unlawful but you want us to just store it instead;
- we wish to erase the Customer Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
- you have objected to us processing Customer Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Customer Data whilst we determine whether there is an overriding interest in us retaining such Customer Data.
Objection.
At any time you have the right to object to our processing of Customer Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Customer Data for that purpose.
You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below by using the following form: Data Privacy Rights Form and submitting it to MI_feedback@singaporeair.com.sg referencing: Data Subject Rights.
You may object where we are processing the Customer Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing (please see here for the types of Customer Data we process on that basis: How we use your Customer Data).
Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Customer Data whilst we make the assessment on an overriding interest by indicating this in our Data Privacy Rights form.
SilkAir 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 SilkAir, or as required by relevant laws. We will usually keep your Customer Data for up to 7 years to ensure that any contractual disputes can be addressed. This includes standing requests which contain sensitive personal data about yourself, e.g. a standing request that you wish to receive a halal meal or a wheelchair at the airport on all flights with SilkAir. You can amend your standing request at any time to change your preferences in the future.
If you opt-out or withdraw your consent to marketing, we will remove you from our marketing database.
SilkAir needs your assistance to ensure that your Customer Data is current, complete and accurate. As such, please inform SilkAir of changes to your Customer Data by contacting SilkAir and submitting your updated particulars to SilkAir in writing (see Section 14).
SilkAir will also request Customer Data updates from you from time to time. As detailed above, your booking information or flight itinerary will be disclosed to the appropriate customs and immigration authorities as required by law. As such, it is important to ensure that the Customer Data contained in your booking information or flight itinerary is current, complete and accurate.
SilkAir will amend this Privacy Policy from time to time, and the updated versions will be posted on SilkAir’s Website and date stamped so that you are aware of when the Privacy Policy was last updated. Please check back frequently to see any updates or changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice including by way of a banner on our website. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language.
If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact SilkAir in writing at the address below referencing ‘Privacy Policy':
Singapore Airlines Group DPO
08D Airline House
25 Airline Road
Singapore 819829
Or email dpo@singaporeair.com.sg referencing: Privacy Policy.
Alternatively for queries specific to KrisFlyer, you may contact:
KrisFlyer Membership Services
PO Box 177
Singapore Post Centre Post Office
Singapore 914006
For queries specific to HighFlyer, you may email HighFlyer_Support@singaporeair.com.sg referencing: Privacy Policy