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PRIVACY POLICY

This Privacy Policy (“Policy”) sets out the basis which Kestrel Aero Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Policy will provide you with a notice and overview on how your personal data is collected, intended to be used, transferred to, stored and accessed. It also covers how we amend and protect your data provided to us.

 

Here at Kestrel Aero, we take just as much pride in providing you with data protection as we do in providing you with our core products and services. We will continuously update and review our adherence to changes in the PDPA as well as the steps taken to provide security and protection to your data.

 

PERSONAL DATA 

 

  1. As used in this Policy:

 

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

 

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

 

  1. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information and financial information. 

 

  1. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

                                                     

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

 

  1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

 

  1. We may collect and use your personal data for any or all of the following purposes:

 

  1. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

  2. verifying your identity;

  3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

  4. managing your relationship with us;

  5. processing payment or credit transactions;

  6. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

  7. any other purposes for which you have provided the information;

  8. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

  9. any other incidental business purposes related to or in connection with the above;

  10. Providing you with regular or ad-hoc updates and/or information on/or required for your policies and financial instrument and/or applications

  11. Website visitor traffic and informatics via cookies stored on our website https://www.kestrelaero.com

 

  1. We may disclose your personal data:

 

  1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;

  2. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes; or

  3. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.

 

  1. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

 

 

 

WITHDRAWING YOUR CONSENT

 

  1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

 

  1. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.

 

  1. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

 

  1. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

 

ACCESS TO AND CORRECTION OF PERSONAL DATA

 

  1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided at the end of this policy.

 

  1. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

 

  1. We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to your request within thirty (14) days after receiving your request, we will inform you in writing within thirty (14) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

 

PROTECTION OF PERSONAL DATA

 

  1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, security review and testing performed regularly, credential exposure checks, and device vulnerability assessments and security hardening.

 

  1. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

 

 

ACCURACY OF PERSONAL DATA

 

  1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

 

RETENTION OF PERSONAL DATA

 

  1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

 

  1. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

 

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

 

  1. The services we provide may require us to transfer your personal data to countries outside of Singapore on a case-to-case basis. These transfers are meant to fulfil the services that you have contracted us for and includes but is not limited to: Medical Air/Land Evacuation, Visa & Immigration related applications, medical arrangements for hospitals and service providers and legal and statutory requirements by host and destination countries vis Ministries/Embassies/Law Enforcement and Medical Flight related authorities. Kestrel Aero has taken measures to ensure that the transfer of your data is carried out using secured encryption tools and delivery methods such as ProtonMail. Additionally, within reasonably expected - to ensure that the destination country poses a reasonable or comparable compliance to data protection vis the PDPA in Singapore.

  2. generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. This is for the purpose of services that you have contracted with Kestrel Aero to provide such as, but not limited to: Medical Evacuation, Visa & Immigration related application, medical arrangements with medical facilities, arrangements with insurance entities and compliance to international regulations and requirements by countries to/from launch to destination.

 

DATA PROTECTION OFFICER

 

  1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

 

Name: Mr. Dave Gurbani

Email: dpo@cybersafe.sg

Contact: +65 87259789

 

EFFECT OF POLICY AND CHANGES TO POLICY

 

  1. This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

 

  1. We may revise this Policy from time to time without any prior Policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

 

WEBSITE

 

  1. Our website, https://www.kestrelaero.com may contain links to other sites; These sites do not operate under the Policy set forth for our company and website. You are advised to review the policies displayed in those websites before use.

 

  1. Our website does contain cookies[1]. These cookies improve the overall experience you have visiting our site and provides us with informatics on how we can better serve you and improve your user experience.

 

  1. We retain the copyrights to the material including logo, photographs and content found on this site. No part of this website may be copied, performed in public, utilized and/or adapted without our written consent.

 

 

1.1    Effective date      :                 02/03/2020
1.2    Last updated       :                 29/05/2023

 

[1]HTTP cookie (also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data stored on the users’ computer by the browser while browsing on a specific site.

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