Privacy and Cookie Policy

Introduction

This privacy and cookie policy (together with our Terms of Use APP Terms of use  applies to your use of:

  • TripPal-Instant messaging version 3.0.0 (which was last updated on 31/07/2023 mobile application software (App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

  • Any of the services accessible through the App (Services).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

THIS APP IS FOR COMPANY EMPLOYEES (OR SIMILAR) FOR USE FOR BUSINESS PURPOSES.

Important information and who we are

Trip.com Travel Singapore Pte. Ltd., a limited liability company with its address at 1 Harbourfront Ave, #03-12/13, Keppel Bay Tower, Singapore (098632) is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).  You can contact us at dp@trip.com.

Our data protection representative in the European Union is Travix Netherland BV. You can reach them by email at dpo@travix.com.

You have the right to make a complaint at any time to the relevant data protection authority in your country of residence.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 31/07/2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Contact Data: email address and telephone numbers.

  •  Device Data: includes Android/IOS, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or IDFA), mobile network information, IP address, your mobile operating system, mobile manufacturer, time zone setting and language.

  •  Usage Data: includes details of your use of the App including, but not limited to, traffic data and other communication data when using the App and the resources that you access.

  •  Communications Data: includes communication records (the App is only available for employees (or similar) for business purposes).

  • Location Data: includes your current location disclosed by GPS technology, WLAN positioning and base station positioning.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Contact) you consent to giving us about you on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register the App, search for the App and when you report a problem with the App. If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your Device. Each time you use the Apps we will automatically collect personal data including Device, and Usage Data. We collect this data using cookies and other similar technologies.

  • Location Data. We also use GPS technology or WLAN positioning and base station positioning to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

Cookies

We use cookies to distinguish you from other users of the App or the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App.

We use the following cookies:

Essential cookies

These are cookies that our App cannot operate without. They include, for e.g., cookies that enable you to log into secure areas of our App.

Non-essential cookies

Functionality cookies: These are used to recognise you when you return to our App. This enables us to personalise our content for you and remember your preferences (for e.g., your choice of language, region).

Analytical and performance cookies: These allow us to count the number of visitors to our App and to see how they move around it. This helps us improve the way our App works.

Targeting cookies: These cookies record your visit to our App, the pages you have visited and the internal links you have followed.

We use session and persistent cookies. Session cookies are deleted when you close App. Persistent cookies remain on your device and are activated the next time you visit our App.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.

  • Where we need to perform a contract we are about to enter or have entered with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Contact

Device

Your consent

Performance of a contract with you

To deliver our App Services  

Contact

Device

Usage Data

Communications

Location

(including data collected via non-essential cookies as described above, on the basis of our legitimate business interests as the App is only available for Company employees (or similar) and only for business use)

Your consent

Performance of a contract with you

Necessary for our legitimate interests

To administer and protect our business and this App including troubleshooting, data analysis and system testing

 Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

Disclosures of your personal data

We may share your personal data with affiliate companies within our corporate family and third parties, such as the partners detailed below, to ensure the successful provision of Services to you. Our partners include the following types:

  •  Suppliers: including but not limited to software service providers.

  • Business partners: including but not limited to cloud service providers.

  •  Affiliated companies within our corporate family: We may share your personal information with our affiliated companies so that we best provide you with the requested service. All parts of our company provide similar protection measures for your personal information that are no less stringent than this policy.

International transfers

Many of our external third parties are based outside the United Kingdom (UK) and/or the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and/or the EEA.

Whenever we transfer your personal data out of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  •  We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  •  Where we use certain service providers, we may use specific contracts approved by the UK and/or the EEA which give personal data the same protection it has in the UK and/or the EEA.

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We use advanced techniques (e.g. SSO, IAM) and conduct regular audit to restrict unauthorized access to your data.

We will collect and store personal data on your Device using [application data caches and browser web storage (including HTML5).

Ensure when using messenger features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Where we process your personal information as allowed by law or with your consent, we will store your personal information i) only for as long as is required to fulfil the purposes mentioned previously, ii) until you object to our use of your personal information (where we have a legitimate interest in using your personal data), or iii) until you withdraw your consent, whichever is applicable. However, if we are required to retain your personal information by law or in order to address legal claims, we will retain your personal information until the end of the legally required period or until the claims in question have been settled.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    1. if you want us to establish the data's accuracy;

    2. where our use of the data is unlawful but you do not want us to erase it;

    3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

    4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting us at dp@trip.com.