25th May 2018
(1) Detailed information regarding what personal data and other information we collect from you, how we collect it, and how it is used;
(2) Further descriptions of the parties with whom and for what purposes your data is shared.
ASIA DMC Group and its affiliates (collectively, “ASIA DMC”, “we”, “our” or “us”) are committed to safeguarding your privacy and want you to be familiar with how we collect, disclose and otherwise use information about you.
- our privacy practices when we communicate with you by offline channels, such as when you provide your information to our offices, or in person (“Offline Services”); and
- the basis on which we will process personal data we collect from you or that you provide to us, and your choices with respect to that data.
Our privacy practices may be more or less limited in certain countries in which we operate to reflect local practices and legal requirements. We will specifically inform you, if this is the case.
1. What Information Does ASIA DMC Collect?
2. When is Your Personal Data Collected?
3. Why is Personal Data Used?
4. When Do We Disclose Your Personal Data?
5. What Cookies and Other Technologies Does ASIA DMC Collect?
6. How Do We Protect Your Personal Data?
7. Third-Party Websites and Services
8. Cross-Border Data Transfers
9. How Long is Your Personal Data Retained?
10. How Can You Manage Your References and Information?
11. What Are Your Rights Regarding Your Personal Data?
12. What Information is Collected From Children?
13. What About Policy Modifications?
14. How to Contact Us?
1. WHAT INFORMATION DOES ASIA DMC COLLECT?
1.1 Personal Data
- Your name, e-mail address, phone number, physical address (billing), company affiliation, title;
- Demographic information and location, and government-issued identifiers;
- Your credit card and/or debit card details;
- Accommodation requests and preferences (including preferred room type or floor, personal preferences including amenities, language preferences, interests, hobbies, ages of children or companions and any other aspects of the Services required.
- Frequent flyer and travel partner program affiliations
- Information, feedback or content you provide regarding your marketing preferences, in surveys on our Services and those of third parties;
- Conversations, including records for quality assurance, account management (B2B) and training purposes, and other communications where permitted by applicable law or based upon consent;
- Any other types of information that you voluntarily choose to provide to us.
1.2 Sensitive Personal Data
Travellers (or our Trade Partners) may provide what is considered ‘sensitive personal information’ under applicable privacy laws (herein referred to as “Sensitive Personal Data”). For example, you may disclose your religious affiliation to us when you travel or attend an event or provide your health information or dietary restrictions.
We shall only process Sensitive Personal Data if and to the extent permitted and required by applicable law or with your express consent. Unless required by law, you are not required to provide us with any Sensitive Personal Data and we shall continue to furnish your travel to our best ability.
1.3 Personal Data from Third Parties
We may collect Personal Data related to you from third party trade partners such as travel agencies, tour operators and online booking services, and other affiliates including public databases, joint marketing partners, third parties who sell products and services under our brands and your social medial sites consistent with your settings on such services.
2. WHEN IS YOUR PERSONAL DATA COLLECTED?
We collect Personal Data about you in a number of ways, including:
When our team have made contact with you or your company in the past through (and not restricted to) tradeshows and any other sales related networking events.
Our Trade Partners who elect to use our Services will be asked to supply specific Personal Data of their clients, as the ‘Required Information’ to secure the reservation. If you plan or host an event with us, we collect meeting and event specifications, such as your name, contact details, date of event, occasion, number of guest rooms required, and length of stay. We also collect information about guests that are a part of your group or event.
When you provide your comments and feedback or communicate with us. We may collect Personal Data that you voluntarily share with us in surveys. We also collect your Personal Data when you communicate with us via text or e-mail or otherwise, like WeChat, WhatApp etc.
When you share photos with consent, we may collect and publish photos and images you voluntarily share with us about your experience with us as your destination management company (DMC), which you may post on our Services.
From social media. We collect information from social media activity such as when you ‘like’ the Website, share content or follow us on social media sites like Facebook, Twitter, Pinterest, Instagram. If you choose to log-in, connect with or link to Services using your social media account certain Personal Data is shared with us consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, as well as Personal Data that may be a part of your profile or friend’s profile.
When you apply for career opportunities. If you choose to apply online with us, how we process your Personal Data internally for the sole purpose of recruitment only.
From other sources. We may receive your Personal Data from other sources, like public databases, joint marketing partners, and other third parties including travel agencies, airline and credit card partners.
3. WHY IS PERSONAL DATA USED?
We use your Personal Data in a number of ways as set forth below.
3.1 Performance of a Contract. We process your Personal Data in order to perform a contract with you, including to complete yours (or client’s) reservation in fulfilling your order.
3.3 To Comply with Legal Obligations. We process your Personal Data where it is necessary to comply with legal obligations to which it may be bound. This includes complying with legal processes, responding to requests from public and government authorities around the world, and pursuing available remedies or limit damage we or other third parties may sustain.
3.4 With Your Consent. We process your Personal Data when we have your valid consent to do so, including to communicate (including by e-mail, telephone and/or SMS) during your travels with us in accordance with your preferences; and to process Sensitive Personal Data you may have provided us in connection with your travel; for example, any dietary restrictions or special accommodations for physical and medical conditions.
3.5 Vital Interest. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to process your Personal Data, including Sensitive Personal Data you provided through our Services, where it is in your vital interest or in the interest of others, for example in the event of a medical emergency.
4. WHEN DO WE DISCLOSE YOUR PERSONAL DATA?
We may disclose or share your Personal Data as follows:
4.1 Hotels and other accommodation providers. The Personal Data you provide to us in connection with making a reservation is shared with the respective hotel or property for purposes of meeting your reservation request. The hotel or other property shall be managed and owned by an independent third-party Owner whom shall also disclose their individual data protection policy with you via their relevant website.
4.2 External Partners. We may share your Personal Data to other partners, consultants and advisors who render services to us, including financial institutions, external auditors, lawyers, and credit card issuers.
4.4 Social Media and Message Boards. If you connect to one of our social media pages, we may disclose your Personal Data to your friends associated with your social medial account, to other website users, and to your social media account provider, in connection with your social sharing settings. We may make reviews, message boards, blogs and other user-generated content available to users on our Services. Any information disclosed in these areas is public information and we encourage caution when deciding to disclose your Personal Data in this context. We are not responsible for the privacy practices of other users including web operators to whom you provide information.
5. WHAT COOKIES AND OTHER TECHNOLOGIES DO WE COLLECT?
5.1 Automatic Data Collection. We may use automatic data collection technologies to collect certain statistical (non-personal) information about your equipment, browsing actions, and patterns, including (a) details of your visits to our Services, including traffic data and location data, date and time of access, frequency and other communication data; (b) information about your computer and internet connection, including your IP address, operating system, host domain, and browser type; and (c) details of referring websites actions, and patterns.
5.2 If you do not want incorporated social networks to gather data about you via our Site, you must log out on the respective domain of the social network before visiting our Site. If you wish to prevent information being exchanged with the above-mentioned social networks during your visit to our Site, you can opt out of cookies through your browser settings and other tools.
6. HOW DO WE PROTECT PERSONAL DATA?
We maintain commercially reasonable security safeguards that are designed to protect the Personal Data we collect against unauthorized use, disclosure, alteration or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee or warrant that your Personal Data is under absolute security with the existing security technology. Additionally, when requesting information or sending information or forms to us by e-mail, please be advised that e-mail communication to and from our Services are not secure unless clearly noted otherwise. This is a risk inherent in the use of e-mail.
7. THIRD-PARTY WEBSITES AND SERVICES:
7.1 Our Services may contain links to, or have features that are hosted by, other third-party websites or services that are not owned or controlled by us. For example, we give you the opportunity to connect, link, or share our Services (and the content you access) via certain social media websites.
8. CROSS-BORDER DATA TRANSFERS:
8.1 The Personal Data and other information that we collect from you will be transferred to, and stored at, a destination outside the EEA. It also may be processed by staff operating outside the EEA who work for us or other entities acting as data processors processing data on our behalf. This includes staff and providers engaged in, among other things, the fulfilment of your request or order and the provision of support services. More information on to whom your data is disclosed can be found in Section 4.
8.2 To comply with applicable data protection law, we have implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for Personal Data transferred to countries outside the EEA where an adequate level of protection is not already guaranteed.
9. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
10. HOW CAN YOU MANAGE YOUR PREFERENCES AND INFORMATION?
10.1 Commercial Emails. You may opt-out of receiving commercial emails from us by following the instructions contained in any of the commercial emails. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at firstname.lastname@example.org. Unsubscribing from one type of communication may not unsubscribe you from another type - if you unsubscribe from marketing related email messages, we may still email you transactional messages related to your account and business activities.
10.2 EEA Users and Commercial E-mails. If you are a user based in the EEA, we only send you commercial emails when we have obtained your explicit prior consent, except where we have obtained your email address in the course networking or negotiations for a sale of our services. Once again, unsubscribe or opt out with any objection.
11. WHAT ARE YOUR RIGHTS REGARDING YOUR DATA?
Under applicable law and regulations, you may, at any time, exercise certain rights, including the following:
11.1 Access. The right to request access to your Personal Data, which includes the right to obtain confirmation from us as to whether Personal Data concerning you is being processed, and where that is the case, access to the Personal Data and information related to how it is processed.
11.2 Rectify or Erase. The right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed.
11.3 Restrict. The right to obtain a restriction of processing concerning your Personal Data, which includes restricting us from continuing to process your Personal Data under certain circumstances (e.g., where you contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the personal data).
11.4 Object. The right to object to the processing of your Personal Data under certain circumstances, including objecting to processing your Personal Data for direct marketing purposes, or objecting to processing your Personal Data when it is done based upon legitimate interests.
11.5 Data Portability. The right to data portability, which includes certain rights to have your Personal Data transmitted from us to you or another controller.
11.6 Consent. Where we process your Personal Data based on your consent, the right to withdraw consent at any time with effect for the future. Any requests related to the above rights may be made by contacting us as set forth in Section 14.
11.7 Complaint. In some jurisdictions, you may also have the right to lodge a complaint with a supervisory authority.
11.8 Privacy Rights for California Residents. Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of personal customer information we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.
12. WHAT INFORMATION IS COLLECTED FROM CHILDREN?
12.1 The Services we provide should not be used by anyone under the age of 16 without adult supervision. If you are under 16, please do not provide Personal Data of any kind whatsoever.
12.2 Should we inadvertently acquire Personal Data or other information from users under the age of 16, we will not knowingly provide this data to any third party for any purpose. If a child does provide us with Personal Data over Services, a parent or guardian of that child may contact us and upon notification, we will delete from our records any information collected from children under the age of 16.
14. HOW TO CONTACT US:
ASIA DMC Group
47 Phan Chu Trinh st Hanoi
Attn: Legal Department