INFORMATION REGARDING COOKIES
2. Who is the controller of your data?
When this policy mentions “Company”, “we,” “us,” “our” or “Data Controller”, it refers to:
We, being an entity located in Singapore, are subject to Singapore’s legal system regarding the protection of personal data. For that reason, we undertake to comply with the obligations imposed by the Singapore Personal Data Protection Act 2012 (PDPA).
3. What are cookies?
Cookies are small files which are stored on your computer, they hold a modest amount of data specific to you and allows a server to deliver a page tailored to you on your computer, hard drive, smartphone or tablet (hereinafter referred to as, “Device”). Later on, if you return to our Website, it can read and recognize the cookies. Primarily, they are used to operate or improve the way our Website works as well as to provide business and marketing information to the Website owner.
5. What categories of your data do we collect and use?
When you visit the Website and use our Comparison Service (you as a “User”) we collect the categories of personal data.
We also collect information about you when either you or your organization provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Account and Profile Information
We collect information about you that we reasonably need for our business functions and activities and which is required by law. We use the information you provide to us to book and manage travel, accommodation, car rental, group events such as conferences and meetings, and other related products and services on your behalf and as your agent. We use your personal preferences and requirements when coordinating timetables and availability, and your financial and contact details to purchase, deliver and provide notifications of reservations and other communications related to these services. We may collect personal information about you such as:
While you travel we will use your contact and itinerary information to facilitate your journey and deal with third-party suppliers on your behalf, and afterwards the relevant detail of your journey or event feeds into our billing processes. Where you have booked through a business we may provide your journey data and other associated reporting to the assigned business contact for management information.
For business or corporate customers, your access to the Services is provided via a contract between us and your employer, therefore our legal basis for processing your personal data under the GDPR is ‘Performance of Contract’.
Content you provide through our software products and applications:
Our Services include software products and applications including but not limited to online booking systems, customer portals, APIs and mobile applications. As part of providing these Services, we collect and store content that you provide to us. This content may include any information about yourself that you choose to provide, records of your activity while using the Services, any messages you send, and any feedback you provide to us. This content also includes any files or links you upload to any of our Services.
We also collect content using analytics techniques that hash, filter or otherwise de-identify the information to exclude information that might identify you or your organization; and we collect clickstream data about how you interact with and use features within the Services so that we may improve our customer experience.
Information you provide through our support channels:
The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
We collect certain payment and billing information when you register for certain paid Services. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
Device and connection information:
We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources:
We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.
Please see the following clause of this Policy for further information on the purposes for which we collect and use this information.
6. Types of cookies used on our Website
6.1. Types of cookies according to the managing entity
Depending on what entity manages the computer or domain from which the cookies are sent and processed, there exist the following types of cookies:
6.2. Types of cookies according to the length of time you stay connected:
Depending on the amount of time you remain active on your Device, these are the following types of cookies:
6.3. Types of cookies according to their purpose
Cookies can be grouped as follows:
With your consent:
We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
7. How we share Information we collect
We take pride in providing you with our Services, and we want them to work well for you. This sometimes means sharing information with certain third parties. We share information we collect about you in the ways discussed below in order to provide the Services, but we are not in the business of selling information about you to advertisers or other third parties.
Sharing with third party service providers:
We share information with third party Service Providers that help us operate, provide, support and market our Services. We only provide enough information to fulfill our obligations to provide you with the Services and will not share any information without a legitimate and legal purpose.
Service Providers include travel providers such as tour operators and property (resort) but may also include platforms such as BlitzOMS.io that provide inventory and reservation services to travel agencies and property (resorts).
Sharing with third party technology providers:
We work with third-party technology providers to provide website and application development, hosting, maintenance, backup, storage, infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
Links to third party websites:
Third party widgets:
Compliance with enforcement requests and applicable laws; Enforcement of our rights:
In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect AFS, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Sharing with affiliated companies:
8. List of cookies used on this Website
To see the list of cookies used on this Website, click here.
The information contained in the above list of cookies has been provided by the other companies which generate them. These companies have their own privacy policies in which they set forth both their own declarations as well as applicable disabling systems.
9. Why do we collect your data?
|Why?||On which legal basis?|
|A. To create and maintain the contractual relation established for the provision of the Service requested by you in all its phases and by way of any possible integration and modification.||To provide a requested service|
|B. To meet the legal, regulatory and compliance requirements and to respond to requests by government or law enforcement authorities conducting an investigation.||To comply with the law|
|C. To carry out anonymous, aggregative statistical analyses so that we can see how our Website, products and services are being used and how our business is performing.||To pursue our legitimate interest(i.e. improving our Website, its features and our products and services)|
D. To tailor and personalise online marketing notifications and advertising for you based on the information on your use of our Website, products and services and other sites collected through cookies.
|Where you give your consent (i.e. through the cookie banner or by your browser/’s settings)|
10. How long do we retain your data?
We retain your personal data for as long as is required to achieve the purposes and fulfil the activities as set out in this Cookies Policy, otherwise communicated to you or for as long as is permitted by applicable law. Further information about the retention period is available here:
|Data collected via tag||Retention period||Starting date|
|Technical cookies||Max 3 years||From the date of browsing on our websites|
|Non-technical cookies||Max 1 year||From the date of browsing on our websites|
How long we keep information:
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
We retain your account information for as long we continue to deal with you, and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal and tax obligations, to resolve commercial disputes, to enforce contractual agreements, to support general business operations, and to continue to develop and improve our Services.
Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services in general, not to specifically analyze personal characteristics about you.
If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or made a booking with us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
11. Cookie management
You must keep in mind that if your Device does not have cookies enabled, your experience on the Website may be limited, thereby impeding the navigation and use of our services.
11.1.- How do I disable/enable cookies?
There are a number of ways to manage cookies. By modifying your browser settings, you can opt to disable cookies or receive a notification before accepting them. You can also erase all cookies installed in your browser’s cookie folder. Keep in mind that each browser has a different procedure for managing and configuring cookies. Here’s how you manage cookies in the various major browsers:
If you use another browser, please read its help menu for more information.
If you would like information about managing cookies on your tablet or smartphone, please read the related documentation or help archives online.
11.2.- How are third party cookies enabled/disabled?
12. What are your data protection rights and how can you exercise them?
You can exercise the rights provided by the Regulation EU 2016/679 (Articles 15-22), including the right to:
|Name of the right||Content|
|Right of access||To receive confirmation of the existence of your personal data, access its content and obtain a copy.|
|Right of rectification||To update, rectify and/or correct your personal data.|
|Right to erasure/right to be forgotten and right to restriction||To request the erasure of your data or restriction of your data which has been processed in violation of the law, including whose storage is not necessary in relation to the purposes for which the data was collected or otherwise processed; where we have made your personal data public, you have also the right to request the erasure of your personal data and to take reasonable steps, including technical measures, to inform other data controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.|
|Right to data portability||To receive a copy of your personal data you provided to us for a contract or with your consent in a structured, commonly used and machine-readable format (e.g. data relating to your purchases) and to ask us to transfer that personal data to another data controller.|
|Right to withdraw your consent||Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes.|
|Right to object, at any time||You have the right to object at any time to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using your data for direct marketing.|
You can exercise the above rights at any time by:
Your rights in relation to your personal data might be limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process your personal data which you have asked us to delete.
You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Data Protection Supervisory Authority.
13. Contact details of the data controller
The contact details of the Data Controller of the data processing described hereinabove are:
VGlobal Trading Pte Ltd, is a Singaporean company, Company Registration: 2011115602R. Office Address: 1557 Keppel Rd, #03-16A, Singapore, 089066.
14. Contact details of our data protection officer (DPO)
Our Data Protection Officer (or “DPO”) is available at:
15. Other important privacy Information
Notice to end users:
Some of our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the Controller of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organisation’s policies. We are not responsible for the privacy or security practices of an administrator’s organisation, which may be different than this policy.
Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens. Please contact your organization or refer to your organizational policies for more information.
Our policy towards children:
The Services are not specifically directed to individuals under 16. We do not knowingly collect personal information directly from children under 16. We may collect information about children provided with the express consent of their parent or guardian (for example in the case of a family travel booking). If we become aware that a child under 16 has provided us with personal information without such consent, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.