Privacy Policy
Privacy and online
safety are important to Seletar Flying Club. We offer a software platform and
services for helping run an internet business. We collect data about businesses
and their customers (“Data”) when they use the platform, the services,
and our websites (collectively, “Services”). This privacy
policy describes how we collect, use and disclose Data.
In this privacy
policy, we sometimes refer to “You”. “You” may be a visitor to
one of our websites, a user of one or more of our Services (“User”), or a customer of a User (“Customer”). We’ll do our best
to clarify who we are referring to at various points in the policy. This policy
does not apply to third-party websites, products, or services even if they link
to our Services, and You should consider the privacy practices of those
third-parties carefully. If You disagree with the practices described in this
policy, You should (a) take the necessary steps to remove cookies from Your
computer after leaving our website, and (b) discontinue Your use of our
Services. Finally, we have also put together a Cookie Policy that describes in detail how we use cookies and similar
technologies.
1. Overview
The Data we collect depends
on how our Services are used. Sometimes we receive Data directly, such as when
a Seletar Flying Club account is created, test transactions are submitted
through our website, the Seletar
Flying Club Checkout form is used, or
we receive an email. Other times, we get Data by recording interactions with
our Services by, for example, using technologies like cookies and web beacons.
We also get Data from third parties, like our financial partners or identity
verification services.
The collection and use
of data from a variety of sources is essential to our ability to provide our
Services – and to help keep the Services safe. Data is critical in helping us
to increase the safety of Your online payments, and reduce the risk of fraud,
money laundering and other harmful activity.
2. Data We Collect
a. Personal Data. We call Data that identifies, or that
could reasonably be used to identify, You as an individual “Personal Data”. We collect Personal Data in different ways. For example, we
collect Personal Data when a business registers for a Seletar Flying Club
account, a Customer makes payments or conducts transactions through a User’s
website or application, a person responds to Seletar Flying Club emails or
surveys, or when a Customer uses the “Remember Me” feature of Seletar Flying
Club Checkout. We also receive Personal Data from other sources, such as our
partners, financial service providers, identity verification services, and
publicly available sources. Personal Data does not include Data that has been
aggregated or made anonymous such that it can no longer be reasonably
associated with a specific person. The Personal Data that we may collect
includes:
· Contact details, such as name, postal address, telephone number, email address;
· Financial and transaction Data, such as credit or debit card number, and
bank account information; and
· Other Personal Data, such as date of birth, SSN or EIN.
b. Other Data. We call Data other than Personal
Data “Other Data”. We collect Other Data through a variety of
sources. One of our sources for Other Data is cookies and other technologies
that record Data about the use of our websites, websites that implement our
Services, and the use of our Services generally. Other Data that we may collect
include:
· Browser and device data, such as IP address, device type, operating
system and Internet browser type, screen resolution, operating system name and
version, device manufacturer and model, language, plug-ins, add-ons and the
version of the Services You are using;
· Transaction data, such as purchases, purchase amount, date of purchase, and
payment method;
· Cookie and tracking technology data, such as time spent on the Services, pages
visited, language preferences, and other anonymous traffic data; and
· Company data, such as a company’s legal structure, product and service
offerings, jurisdiction, company records, and information submitted through
the Seletar Flying Club
Atlas service.
3. How We Use Data
a. Personal Data. We and our service providers use
Personal Data to: (i) provide the Services; (ii) detect and prevent fraud;
(iii) mitigate financial loss or other harm to Users, Customers, and Seletar
Flying Club; and (iv) promote, analyze and improve our products, systems, and
tools. Examples of how we may use Personal Data include:
· To verify an identity for compliance purposes;
· To evaluate an application to use our
Services;
· To conduct manual or systematic monitoring for
fraud and other harmful activity;
· To respond to inquiries, send service notices
and provide customer support;
· To process a payment with Seletar Flying Club
Checkout, communicate regarding a payment, and provide related customer
service;
· For audits, regulatory purposes, and
compliance with industry standards;
· To develop new products;
· To send marketing communications;
· To improve or modify our Services; and
· To conduct aggregate analysis and develop
business intelligence that enable us to operate, protect, make informed
decisions, and report on the performance of, our business.
b. Other Data. We may use Other Data for a range of
different purposes, provided we comply with applicable law and our contractual
commitments. In some countries (for example, European Economic Area countries),
local legal regimes may require us to treat some or all of Other Data as
“personal data” under applicable data protection laws. Where this is the case,
we will process Other Data only for the same purposes as Personal Data under
this privacy policy.
4. How We Disclose
Data.
Seletar Flying Club
does not sell or rent Personal Data to marketers or unaffiliated third parties.
We share Your Personal Data with trusted third parties, including:
a. To Seletar Flying
Club Affiliates. We share Data
with entities worldwide that we control, are controlled by us, or are under our
common control, to provide our Services. Seletar Flying Club, Inc. is the party
responsible for overall management and use of the Data by these affiliated
parties;
b. To Seletar Flying
Club Service Providers. We share Data
with service providers who help us provide the Services. Service providers help
us with things like payment processing (i.e., banks, credit bureaus, payment
method providers), website hosting, data analysis, information technology and
related infrastructure, customer service, email delivery, Seletar Flying Club
Atlas, and auditing;
c. To Our Users. We share Data with Users (such as
merchants and application providers) as necessary to process payments or
provide the Services. For example, we share Data with Users about purchases
made by their Customers through the Seletar Flying Club payment processing
services;
d. To Authorized Third
Parties. We share data
with parties directly authorized by a User to receive Data, such as when a User
authorizes a third party application provider to access the User’s Seletar
Flying Club account using Seletar
Flying Club Connect. The use of Data by
an authorized third party is subject to the third party’s privacy policy;
e. To Third Parties. We will share Data with third parties in
the event of any reorganization, merger, sale, joint venture, assignment,
transfer or other disposition of all or any portion of our business, assets or
stock (including in connection with any bankruptcy or similar proceedings); and
f. Safety, Legal
Purposes and Law Enforcement. We
use and disclose Data as we believe necessary: (i) under applicable law, or
payment method rules; (ii) to enforce our terms and conditions; (iii) to
protect our rights, privacy, safety or property, and/or that of our affiliates,
You or others; and (iv) to respond to requests from courts, law enforcement
agencies, regulatory agencies, and other public and government authorities,
which may include authorities outside Your country of residence.
5. Security.
We use reasonable
organizational, technical and administrative measures to protect Personal Data
within our organization. Unfortunately, no data transmission or storage system
can be guaranteed to be 100% secure. If You have reason to believe that Your
interaction with us is no longer secure (for example, if You feel that the
security of Your account has been compromised), please contact us immediately.
6. Advertising.
We may use third-party
advertising companies to serve advertisements regarding goods and services that
may be of interest to You when You access our websites, based on Data relating
to Your access to and use of our websites on any of Your devices, as well as
Data received from third parties. To do so, these companies may place or
recognize a unique cookie, or similar tracking technology, on Your browser
(including the use of pixel tags). They may also use these technologies, along
with data they collect about Your online use, to recognize You across the
devices You use, such as a mobile phone and a laptop, and to make decisions
about the advertisements You see. If You would like more information about this
practice, and to learn how to opt out of behavioral advertising delivered by
Network Advertising Initiative member companies in desktop and mobile browsers
on the particular device on which You are accessing this Privacy Policy, please
visit the Network Advertising
Initative and Digital Advertising Alliance.
You may download
the AppChoices app to opt out in mobile apps. In order to
understand and improve the effectiveness of our advertising, we may also use
web beacons, cookies, and other technologies to identify the fact that You have
visited our website or seen one of our advertisements, and we may provide that
Data to one or more third party advertising networks. The Data we provide may
include the time and date of Your visit to our website, pages viewed, links
clicked and other information that does not disclose your ‘real world’
identity. Those advertising networks may recognize the web beacon or cookie
associated with Your visit to our website when You visit other websites on
which they serve advertising, and they may make decisions about the
advertisements You see based on it. We may choose to work with Google AdWords,
Doubleclick, AdRoll or other advertising networks. Each of these companies has
its own privacy policy, which we encourage You to review. For more information
about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out”
of the behavioral advertising delivered by member companies. To learn more
about the cookies that may be served through our Services, and how you can
control our use of cookies, please see our Cookie Policy.
At present, there is no industry standard for recognizing Do Not Track browser
signals, so we do not respond to them.
7. Choice and Access.
You have choices
regarding our use and disclosure of Your Personal Data:
a. Opting out of
receiving electronic communications from us. If You no longer want to receive marketing-related emails
from us on a going-forward basis, You may opt-out via the unsubscribe link
included in such emails. We will try to comply with Your request(s) as soon as
reasonably practicable. Please note that if You opt-out of receiving
marketing-related emails from us, we may still send You important
administrative messages that are required to provide You with our Services.
b. How You can access
or change Your Personal Data. If
You would like to review, correct, or update Personal Data that You have
previously disclosed to us, You may do so by signing in to Your Seletar Flying
Club account or by contacting us.
If emailing us Your
request, please make clear in the email what Personal Data You would like to
have changed. For Your protection, we may only implement requests with respect
to the Personal Data associated with the particular email address that You use
to send us Your request, and we may need to verify Your identity before
implementing Your request. We will try to comply with Your request as soon as
reasonably practicable.