Privacy Policy
Last Updated: December 2024
Introduction
cryospheron ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard information obtained from visitors and clients of our winter tourism services.
This policy applies to all information collected through our website, email communications, phone conversations, and in-person interactions related to our travel services.
Information We Collect
Contact Information
When you inquire about or book our services, we collect:
- Full name
- Email address
- Phone number
- Mailing address
- Emergency contact details
Travel Information
For travel arrangements and safety purposes, we collect:
- Passport information
- Date of birth
- Nationality
- Dietary requirements and restrictions
- Medical information relevant to travel safety
- Travel insurance details
Financial Information
For payment processing:
- Billing address
- Payment method details (processed through secure third-party providers)
- Transaction history
Usage Data
When you visit our website, we automatically collect:
- IP address
- Browser type and version
- Pages visited and time spent
- Referring website
- Device information
Communication Records
We maintain records of:
- Email correspondence
- Phone conversation notes
- Feedback and survey responses
- Service inquiries and responses
How We Collect Information
We collect information through:
- Direct Interactions: Information you provide when contacting us, making bookings, or communicating about our services
- Website Forms: Contact forms, inquiry forms, and booking request forms on our website
- Automated Technologies: Cookies and similar tracking technologies when you browse our website
- Third Parties: Information from payment processors, travel insurance providers, and travel partners with your consent
Legal Basis for Processing
We process your personal data based on:
- Consent: You have given explicit consent for specific purposes
- Contract Fulfillment: Processing is necessary to fulfill our travel service agreements with you
- Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., improving services, marketing) while respecting your privacy rights
- Legal Obligations: Compliance with Singapore's Personal Data Protection Act (PDPA) and other applicable laws
How We Use Your Information
We use collected information to:
Service Provision
- Process bookings and travel arrangements
- Communicate about your trip details
- Coordinate with local guides and accommodation providers
- Ensure safety during travel
- Handle special requirements and requests
Communication
- Respond to inquiries and requests
- Send booking confirmations and updates
- Provide pre-trip information and preparation guidance
- Share relevant travel advisories or changes
Service Improvement
- Analyze website usage patterns
- Gather feedback on travel experiences
- Improve service quality and offerings
- Develop new travel programs
Marketing (with consent)
- Send information about new destinations
- Share travel tips and insights
- Offer relevant travel opportunities
Legal Compliance
- Meet regulatory requirements
- Respond to legal requests
- Protect our legal rights
- Prevent fraud or security incidents
Data Retention
We retain personal data for different periods depending on purpose:
- Booking Information: 7 years after travel completion (for financial and legal compliance)
- Marketing Consent: Until you withdraw consent or we cease operations
- Website Analytics: 26 months from collection
- Communication Records: 3 years after last interaction
- Financial Records: 7 years (Singapore regulatory requirement)
After retention periods expire, we securely delete or anonymize data unless longer retention is required by law.
Data Protection and Security
We implement appropriate technical and organizational measures to protect your data:
- Secure server infrastructure with encryption
- Access controls limiting data access to authorized personnel only
- Regular security assessments and updates
- Staff training on data protection practices
- Secure communication channels for sensitive information
- Regular backups with encryption
While we strive to protect your data, no method of electronic storage or transmission is completely secure. We cannot guarantee absolute security but maintain industry-standard protections.
Data Sharing and Disclosure
We share your information only when necessary:
Service Providers
We share relevant information with:
- Local guides and tour operators
- Accommodation providers
- Transportation companies
- Travel insurance providers (with your consent)
- Payment processors
Legal Requirements
We may disclose information to:
- Comply with legal obligations
- Respond to valid legal requests from authorities
- Protect our rights and safety
- Protect the rights and safety of travelers and third parties
Business Transfers
In the event of merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
Your Rights Under Singapore PDPA
Under Singapore's Personal Data Protection Act, you have the right to:
- Access: Request copies of personal data we hold about you
- Correction: Request correction of inaccurate or incomplete data
- Withdrawal of Consent: Withdraw consent for marketing communications or other processing based on consent
- Data Portability: Request transfer of your data to another service provider where technically feasible
- Object to Processing: Object to processing based on legitimate interests
To exercise these rights, contact us at [email protected]. We will respond within 30 days. Some rights may be limited by legal obligations or legitimate business needs.
International Data Transfers
As we arrange travel to destinations outside Singapore, your personal data may be transferred to:
- Estonia (European Union)
- Italy (European Union)
- Russia
When transferring data internationally, we ensure appropriate safeguards including:
- Contractual obligations requiring data protection
- Verification that destination countries have adequate data protection laws
- Limiting data shared to what is necessary for service provision
Third-Party Services
Our website and services may use third-party services including:
- Google Analytics: For website usage analysis (see Cookie Policy)
- Payment Processors: For secure payment handling
- Email Service Providers: For communication management
Each third-party service has its own privacy policy governing how they handle data. We recommend reviewing their policies:
- Google Privacy Policy: https://policies.google.com/privacy
Cookies and Tracking
We use cookies and similar technologies to enhance website functionality and analyze usage. For detailed information about our cookie practices, please see our Cookie Policy.
Children's Privacy
Our services are not directed to individuals under 18. We do not knowingly collect data from children. If traveling with minors, parents or guardians provide necessary information and consent on their behalf.
If we become aware we have collected data from a child without proper parental consent, we will delete that information promptly.
Changes to This Policy
We may update this privacy policy to reflect changes in our practices or legal requirements. Material changes will be communicated through:
- Email notification to registered users
- Prominent notice on our website
- Updated "Last Modified" date at the top of this policy
Continued use of our services after policy changes constitutes acceptance of the updated policy.
Contact Us
For questions, concerns, or to exercise your privacy rights, contact:
Privacy Officer
cryospheron
250 North Bridge Road, #16-04
Raffles City Tower
Singapore 179101
Email: [email protected]
Phone: +65 6573 4128
Complaints
If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with:
Personal Data Protection Commission Singapore
10 Pasir Panjang Road
#03-01 Mapletree Business City
Singapore 117438
Website: https://www.pdpc.gov.sg