Privacy Policy, Cookies & Data Protection Notice

This Privacy Policy, Cookies & Data Protection Notice (“Notice”) sets out the basis which CONNECTETSU PTE. LTD (Unique Entity Number: 202541182N) a company incorporated under the laws of Singapore with its registered office address at 90 EU TONG SENG STREET, #03-02B, SINGAPORE 059811, collects personal data from you, and how we process such data, in accordance with the Personal Data Protection Act (“PDPA”).

This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

By visiting our website www.connectetsu.com (Our “Site”), you accept and consent to the practices set out below:

PERSONAL DATA

1. As used in this Notice:

   “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, created an account on the Site to find out more about 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.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you on our Site includes name, email address and profile photo.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We collect personal data that you voluntarily provide to us when you:
   • (a) create an account on the Site;
   • (b) use our services;
   • (c) submit forms relating to any of our products or services;
   • (d) contact us with enquiries or feedback; or
   • (e) submit an application for employment.
5. We may collect and use your personal data for any or all of the following purposes:
   • (a) to perform or administer services to our customers;
   • (b) to process your applications for our products and services;
   • (c) to manage your relationship with us;
   • (d) to respond to your enquiries, feedback and complaints;
   • (e) to process payment transactions;
   • (f) to send you important updates or announcements;
   • (g) to comply 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;
   • (h) any other purposes for which you have provided the information;
   • (i) 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; and
   • (j) any other incidental business purposes related to or in connection with the above.
6. We may disclose your personal data:
   • (a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
   • (b) to our partners (i.e. to secure accommodation, or services such as tours/activities) when you make a booking/reservation.
   • (c) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, without limitation, a period to enable us to enforce our rights under any contract with you).

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

8. We may collect, use and/or disclose your personal data without your consent for the purposes of performing our business functions and operations that are legitimate in nature, including the following:
   • (a) detecting and preventing fraud, illegal behaviour and other undesirable activities;
   • (b) protecting and enforcing our contractual and legal rights and obligations;
   • (c) administering, operating, managing and improving our business; and
   • (d) managing and enhancing the security of our services and premises.
9. In relying on the legitimate interests exception, we will assess the benefits to us of having your personal data outweighing the potential risks to your rights and interests, and that the risk is not unduly excessive.

COOKIES

10. Our website uses cookies. A cookie is a piece of data stored on your device that tracks information about your use of our website.
11. Cookies are used to improve the services we offer you, for example, by storing your preferences, and tracking your usage of our website. This allows us to collect data on the pages visited, time spent on the website, number of unique visitors, the average duration of the visit, and similar data.
12. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of our website.

PROTECTION OF PERSONAL DATA

13. 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:
    • (a) implementing least privilege to personal data on a need-to-know basis;
    • (b) using secure cloud storage providers such as Amazon Web Services (AWS) or Google Cloud Platform (GCP) for data storage; and
    • (c) having a strong password policy and two-factor authentication for data access.
14. 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

15. 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 at the email address provided below.

ACCESS TO AND CORRECTION OF PERSONAL DATA

16. 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 below.
17. 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.
18. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we may 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).

WITHDRAWAL OF CONSENT

19. 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 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.
20. 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 ten (10) business days of receiving it.
21. Please note that the withdrawal of consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is required or permitted under applicable laws.

RETENTION OF PERSONAL DATA

22. 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.
23. 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

24. In the course of providing our service to our customer, we may have to transfer your personal data to Japan. (i.e. for reservation of tours, accommodation, etc). However, 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.

DATA PROTECTION OFFICER

25. 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 of DPO : Bryan Ryuta Knight

    Contact No. : +81-90-3906-8373

    Email Address: info@connectetsu.com

EFFECT OF NOTICE AND CHANGES TO NOTICE

26. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
27. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.