Singapore Airlines 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, and our Registered Customer programme. We only use your passport number and other national identification information where this is required by law, or where we need to verify individual identities to a high degree of fidelity to prevent fraudulent claims or transactions. We will only do so where we have assessed that there is no suitable alternative to collecting or using such national identification information, and that a failure to accurately identify an individual to a high degree of fidelity could pose significant safety or security risks, or a risk of significant impact or harm to any individuals or to us. 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 laws). More I nformation

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, our overseas stations, government bodies as required by applicable laws and your authorised representatives. 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, for the legal or business purposes of SIA, or as required by applicable 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 your Customer 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 In formation for no n-EU residents

M ore Infor mation f or E U an d Sw iss residents

Dispute Resolution

If you have any concerns or complaints, please contact us here.

How will we notify you of changes?

We will amend 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. 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.

More Infor mation

1. The types of Customer Data we collect

The types of Customer Data that we collect 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 we collect:

• Personal Data. The data we collect includes but is not limited to:

(i) personal information that can be used to identify an individual, such as name, gender, date of birth, passport or other personal identification numbers;

(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 activity and purchases made through SIA (such as chargeable seats, excess baggage, seat upgrades), our website or mobile application (such as hotel accommodation, car rentals and insurance), and purchases of packages such as the Singapore Stopover Holiday and other linked travel arrangements;

(vi) your customer preferences, such as dietary, seating, entertainment viewed, KrisShop purchases, places that you would like to visit or other service preferences;

(vii) information about your in-flight WiFi usage, such as whether you use in-flight WiFi, what WiFi plan you used, the mode of payment to pay for in-flight WiFi and how much data was utilised for your WiFi sessions;

(viii) information about your in-flight interactions with our staff, such as types of beverages requested or other in-flight requests and preferences;

(ix) 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;

(x) health information, such as doctors’ notes, medical certificates and letters and requests related to medical conditions;

(xi) information we receive from the queries you enter into our chatbot, Kris, on our global Facebook page, website and mobile application;

(xii) information we receive from flight bookings made via our online corporate booking platform;

(xiii) information we receive from other sources e.g. our page on social media websites and our contractual partners; and

(xiv) business contact information, such as the contact details of the employees of our vendors and corporate customers, as well as the contact details collected by our divisions including the Cargo Division and Engineering Division.

• Technical Data. This includes device and technical information you give us when using our website or mobile application, such as IP addresses or other unique identifiers, cookies, mobile carrier, time zone setting, operating system and platform, and information about your customer journey on the website or mobile application. Information on cookies may be found in our cookie policy.

For the 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 our customers’ profile and improve our 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).

For example:

• 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

• 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

We collect Customer Data whenever you use our services, including when you travel with us, when you use our website or mobile application, or when you interact with us via email, social media, our contact centres or any other channels such as our ticketing counters and airport operations.

We also collect Customer Data from your authorised representatives. This includes persons whom you have authorised (e.g. your organisation’s corporate travel manager) and persons who have been validly identified as acting on your behalf pursuant to our security procedures..

In addition, we may receive Customer Data from third parties which are located in various countries. This includes, but is not limited to, travel agents, our retailer KrisShop, our KrisFlyer partners (including, amongst others, airlines and non-airlines such as Hilton, Avis, Hertz, American Express, the Economist and Esso) and other contractual parties, our service providers, and other airlines including our subsidiaries to facilitate travel on code share or multi-airline flights.

Where you make reservations on behalf of another person, you undertake to ensure that the individual whose Customer Data is supplied to us has authorised the disclosure, is informed of, and agrees to the provisions of this Privacy Policy.

2. Is the provision of Customer Data required?

The collection of the following types of Customer Data is mandatory to enable us 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.

• Passenger details, e.g title, first/given name, last/family name, date of birth and meal type (for infants).

• Contact details, e.g. email address, mobile phone number, home number or business number.

• Payment details, e.g. the name on the credit or debit card, the credit or debit card number, expiry date and card verification value on the credit or debit card, and billing address which will be transmitted to our payments processors.

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.

The collection of the following types of Customer Data is mandatory to enable us to administer your account as a Registered Customer: (i) last/family name; (ii) first/given name if you do not have a last/family name; (iii) date of birth; (iv) email address; and (v) whether you are an EU or Swiss resident.

The failure to supply the following types of Customer Data will result in (i) us 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 us:

• Contact Information e.g. email address, telephone number; and

• Country of residence.

3. How we use your Customer Data

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 investigating potential fraudulent transactions);

• notify you about changes to our service, including through flight alert messages via our mobile services facility;

• facilitate airport, internet check-in and self check-in;

• provide airport services such as processing information relating to connecting flights, arrangements at airports and customs and immigration facilities;

• provide baggage related services such as processing of any baggage related queries, including mishandled or missing baggage claims;

• provide in-flight catering and other services (e.g. to provide you with a personalised inflight experience);

• in accordance with our contract with you as a KrisFlyer member or Registered Customer, we will use the Customer Data to:

i. maintain your account;

ii. facilitate your transactions and services;

iii. enable you to log in using your account on any of the platforms hosted byus; and

iv. Send you updates and other account related information.

Further, as a KrisFlyer member, Customer Data will be used to administer your KrisPay programme and mobile application.

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 our website and mobile application and to ensure content from the website and mobile application is presented in the most effective manner for you and your device;

• administer the website and mobile application, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• 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;

• send you surveys by email (including surveys related to our Registered Customer, 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;

• send you service emails, such as reminders when you have not checked out your purchases on our website or mobile application. You can opt-out of receiving service emails at any time by contacting us;

• respond to your enquiries, requests or feedback;

• enforce our terms, conditions and policies;

• allow you to participate in interactive features of the website and mobile application, when you choose to do so;

• customise our products and services to you, including by responding to and catering for your customer preferences;

• personalise the content you see on our website, mobile application and inflight entertainment systems, by enabling you to save your preferences on our inflight entertainment systems and suggesting content for your next flight;

• keep the website and mobile application safe and secure;

• 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 our customers’ profile and improve our service offering;

• to customise our marketing e.g. send you targeted marketing on places you would like to visit, based on your responses to optional questions on our website and mobile application, and your prior travels. 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

• In relation to our KrisFlyer and Registered Customer programmes, we will use your Customer Data to:

i. provide youwith any information including promotions and offers from us and other KrisFlyer programme partners, where applicable (with your consent where required by applicable laws);

ii. contact you regarding product and customer related surveys and market research;

iii. respond to your email and call enquiries;

Further, as a KrisFlyer member, Customer Data will be used to provide services to celebrate special occasions; and send KrisFlyer-related news and KrisFlyer e-statements and associated promotions and offers (with your consent where required by applicable laws)

• 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. maintain the Participating Company’s HighFlyer account;

ii. facilitate Participating Company-related transactions and services;

iii. 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);

iv. contact the CTMs and ACTMs regarding product and customer related surveys and market research;

v. respond to email and call enquiries from the CTMs and ACTMs; and

vi. 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 us, our subsidiaries and affiliated airlines and service partners, as well as our appointed agents, in relation to the Registered Customer, KrisFlyer and HighFlyer programmes; and

• register you for the Registered Customer and KrisFlyer programmes.

You have the right to withdraw your consent at any time by contacting us at saa_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.

4. Disclosure of your Customer Data

We 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 and providers of in-flight entertainment and WiFi (if available), if you elect to use this service), partner airlines, airport management, airport operators;

• our interline, code share and strategic alliance partners so that they can fulfil their contract of carriage for the flights you booked through us 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 and mobile application.

We will share your Customer Data with any entities within our group, which includes Scoot Tigerair Pte. Ltd. (“Scoot”), Tradewinds Tours & Travel Private Limited and KrisShop Pte. Ltd. We share information with them, so they can assist us in providing services to you and to understand more about you. For example, if you have flown with one of the other airlines in the group we may use this information to understand more about the sorts of travel services you are likely to be interested in.

• For the purposes of our contract with you, i.e. to:

i. Fulfill bookings and facilitate flight transfers of passengers;

ii. Manage passengers who travel on flights operated by our subsidiaries and are Registered Customers or members of our KrisFlyer or HighFlyer programmes;

iii. Manage passengers during flight disruptions and provide necessary assistance and services;

• As it is in our legitimate interests to be responsive to you, to provide customised services and marketing, to:

i. Respond to complaints or compliments received by us from passengers who are sharing their flight experience on flights operated by our subsidiaries;

ii. Provide an enhanced customer experience and personalise offers to passengers;

iii. Anticipate the servicing needs of passengers on flights with us;

iv. Understand customers better through analytics and research (including marketing research) to support personalisation;

v. Contact customers about updates, surveys, and offers on and relating to our Registered Customer, KrisFlyer and HighFlyer programmes; 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. We will also use and disclose your Customer Data to persons who have been validly identified as being you or acting on your behalf pursuant to our security procedures, for the purposes 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. We will disclose your Customer Data to law enforcement agencies, public or regulatory authorities, securities commissions or other organisations for security, health, 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 any applicable 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, health, 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, we 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 any applicable legal obligations, processes or requests (such as disclosing Customer Data to executors in response to court orders).

In addition, we 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. We also reserve 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. Further, we will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

5. Transfer of information overseas

6. Non-EU and Non-Swiss Data Subject Rights

7. EU Data and Swiss Subject Rights

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. Mo re Information

• The right of data portability. M ore Information

• The right of rectification. M ore Information

• The right of erasure. M ore Information

• The right to restrict processing. Mo re Information

• The right to object. Mo re 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 saa_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.

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.

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 saa_feedback@singaporeair.com.sg. For Registered Customers and KrisFlyer members, you may correct any Customer Data by logging into your account.

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 saa_feedback@singaporeair.com.sg. For Registered Customers and KrisFlyer members, you may correct any Customer Data by logging into your account.

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 for compliance with applicable laws 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 saa_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.

8. Retention

9. Accuracy

10. Security safeguards

11. Links to other websites

12. Minors

13. Updates to the privacy policy

14. Contact us