Privacy Policy

Accomy SG Pte. Ltd. and its subsidiaries, affiliates and/or related companies (“Accomy”, “we”, “our” or “us”) is fully committed to safeguarding your privacy online or otherwise and the success of our business depends upon our ability to maintain the trust of our clients.

This privacy policy (“Privacy Policy”) aims to provide a summary of the type of personal information that we collect from users (“Users” or “you”) from our website, https://runwaytravel.io (or such other web address as may be established, maintained and/or updated by Accomy from time to time) (“Site” or “Runway”), our mobile application (“App”), and the services we provide through the Site or the Apps (collectively, the “services”), how such information is used, transferred/disclosed and stored.

Any capitalized terms not defined herein are defined in our Terms of Use located at https://runwaytravel.io/terms.html. Please read the Privacy Policy carefully to understand our practices regarding your Personal Data and how we will treat it.

What is personal data? “Personal Data” means any information relating to an identified or identifiable natural person, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data? We need certain Personal Data for several purposes described below, such as to deliver the services to you.

1. Types of Personal Data We Collect

We collect and process Personal Data about you or your devices from various sources described below. Where applicable, we indicate whether and why you must provide us with your personal data, as well as the consequences of failing to do so at the time the data is collected.

1.1 Personal Data You Provide to Us

(a)

Account information. We collect Personal Data from you, such as your first and last name, e-mail address, phone number, and password when you create a Member or Personal Account or otherwise register as a User of the services.

(b)

Booking history. Depending on the booking that you complete through the services, we collect the name(s) of (the) traveler(s), email address, phone number, and any travel or accommodation preferences (such as accessibility requirements).

(c)

Region and language. When you use our services, we may ask you to select your region and language to provide you with the relevant services.

(d)

Payments and billing information. To allow you to purchase a booking via our services, we may additionally ask you to provide postal and billing address, phone number, and VAT number (in order to apply VAT discounts). We will not collect or store the credit or debit card or other payment information that you provide to complete a booking via the services. These payments are facilitated by a third-party payment services provider. You will be providing credit or debit card information directly to the payment service provider which operates a secure server to process payment details, encrypting your credit or debit card information and authorizing payment. We use payment processor(s) to process all payments through the services. Accomy does not store your credit card details. Please consult the applicable payment service provider’s privacy policy to learn about the processing of your Personal Data in that context.

(e)

Communications. If you provide us feedback or contact us via e-mail or phone call, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

(f)

User Testimonials. If you submit a testimonial about our services, we may use and disclose it with your first, last name, picture, and job title subject to your consent.

(g)

Newsletter. If you sign up to receive emails or information about our services, then we will collect Personal Data from you, such as email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our services.

(h)

Careers. If you decide to apply for a job with us, you may submit your contact information and your resume to us via our services. We will collect the Personal Data you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform (such as LinkedIn), we will collect the Personal Data you make available to us through such third-party platform.

(i)

Other Collections. We ask that you not send or disclose to us any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the services.

1.2 Personal Data We Collect When You Use Our Services

(a)

IP Address. To make our services more useful to you, our servers (which may be hosted by a third-party service provider) collect Personal Data from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We may associate your IP address with your account and your other Personal Data.

(b)

Precise Location. While the App is in use, it may collect your precise location using GPS on your mobile device and possibly through other signals such as nearby wi-fi access points, or Bluetooth-enabled devices. We may use this Personal Data to, for example, determine whether there are Hotels near you.

(c)

Log Files. As is true of most websites, we gather certain Personal Data automatically and store it in log files. This Personal Data includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this Personal Data to analyze trends, administer the services, track users’ movements around the Site or the App, gather demographic information about our user base as a whole, and better tailor our services to our users’ needs. For example, some of the Personal Data may be collected so that when you visit the Site or use the App again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.

(d)

Cookies. Like many online services, we use Cookies to collect Personal Data. A cookie is a text file made up of letters and numbers that allow us to distinguish your browser/device from another user’s browser/device. This text file is stored on your computer’s hard disk for the purpose of keeping records when you visit a website. We make use of cookies to help manage the site and your user experience. These cookies may be used to collect analytics of non-personal user activity outlines, manage personal preferences, provide relevant or timely information to you or offer focused advertisements. Cookies set across our site, which include third party cookies, can be in the form of session or persistent cookies, and may use different technologies, such as JavaScript or Flash.

Our services also use the following types of Cookies for the purposes set out below:

(i)

Essential Cookies. These Cookies are essential to provide you with our services and to enable you to use some of the features. For example, they help the content of the pages you request load quickly. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services. We use the following essential Cookies:

(A)

Login Information: This reduces the number of times you are required to login to the Service.

(B)

Chat: This allows you to use our chat functionality in order to communicate about the service.

(C)

Opt In/Out Consent: Prevent the cookie banner from re-appearing after you’ve chosen your preferences.

(ii)

Functional Cookies. These Cookies allow our services to remember choices you make when you use our services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our services which you can customize. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our services.

(iii)

Analytics and Performance Cookies. These Cookies are used to collect information about traffic to our services and how users use our services. The information is aggregated. It includes the number of visitors to our services, the websites that referred them to our services, the pages they visited on our services, what time of day they visited our services, whether they have visited our services before, and other similar information. We use this Personal Data to help operate our services more efficiently, to gather broad demographic information and to monitor the level of activity on our services. We may use third-party analytics providers (like Google Analytics) to help analyze how users use the services. These analytics providers use Cookies and other technologies to collect information such as how often users use the services, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from these providers only to improve the services.

(iv)

Targeted and advertising Cookies. These Cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These Cookies use information about your browsing history to group you with other users who have similar interests. Based on that Personal Data, and with our permission, third party advertisers can place Cookies to enable them to show ads which may be relevant to your interests while you are on third party websites.

If you would like to ‘opt out’ of the cookies set by our site, this can be accomplished on a cookie-by-cookie basis subject to your browser settings. In doing so, you may find that it may limit site operation or functionality. Please visit aboutcookies.org for more information and instructions on how to manage cookies. Accomy does not use cookies to retrieve information which was not originally sent in a cookie. We do not use information transferred through cookies for any direct promotional or marketing purposes without your consent.

1.3 Personal Data Collected From Other Sources

(a)

Invitation from Administrators. If you are a User who has been invited to use the services by an Administrator, your Administrator may provide us with your name and email address to facilitate such invitation.

(b)

Third-Party services. You may also post photos, comments, or reviews on our pages available through third-party platforms, including Facebook, Twitter, or LinkedIn. If you do so, we and other users on those third-party platforms may be able to view the Personal Data you make available through these third-party platforms.

(c)

Social Media Cookies. These Cookies are used when you share information using a social media sharing button or “like” button on services or you link your account or engage with our content on or through a social networking website such as Facebook and Twitter. The social network will record that you have done this.

2. Use of Your Personal Data

2.1 To provide the services.

We collect Personal Data to provide the services to you, enable your use of the services, respond to requests that you make, or to aid us in serving you better, including but not limited to:

(a)

facilitating the creation of and securing your Member or Personal Account;

(b)

completing Confirmed Bookings you make through the services;

(c)

managing pending and Confirmed Bookings and planning future bookings or benefitting from other features only available to account holders, such as incentives or other benefits;

(d)

identifying you as a User in our system;

(e)

providing the services you request, including customer support and troubleshooting;

(f)

sending you a welcome e-mail to verify ownership of the e-mail address provided when your Member or Personal Account was created;

(g)

sending you administrative e-mail notifications, such as security or support and maintenance advisories;

(h)

ensuring our services are safe and secure, such as to protect against and prevent fraud and cyber threats, unauthorized transactions, claims and other liabilities, and maintain the integrity of our services;

(i)

marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you. If you send us a testimonial about our services, we may use and disclose it (including your first and last name) to promote our services. However, we will obtain your consent prior to posting your full name along with the testimonial;

(j)

personalizing your experience on our services such as presenting tailored content. For example, we may use your email address and your interaction with our Site to analyze your preferences and provide you with tailored content and the most relevant offers, recommendations, and email communications;

(k)

understanding and analyzing how you use our services and develop new products, services, and features;

(l)

adherence with legal compliance purposes, including for example, conducting due diligence procedures for opening of accounts and ongoing monitoring purposes, monitoring and compliance procedures in line with our internal risk management procedures, audit/financial accounting and for management reporting purposes, enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;

(m)

responding to, handling, and processing queries, requests, applications, complaints and feedback from you;

(n)

for other purposes for which we provide specific notice at the time the Personal Data is collected; and

(o)

any other incidental business purposes related to or in connection with the above.

3. Legal Bases for Processing European Personal Data

If you are located in the European Economic Area (“EEA”) or the United Kingdom, we only process your Personal Data when we have a valid “legal basis,” including as set forth below:

(a)

Consent. You have consented to the use of your Personal Data. For example, we may process your Personal Data to send you marketing communications or to use Cookies where you have consented to such use.

(b)

Contractual Necessity. We need your Personal Data to provide you with our services. For example, we may need to process your Personal Data to complete bookings, process payments and respond to your inquiries or requests.

(c)

Compliance with a Legal Obligation. We have a legal obligation to use your Personal Data. For example, we may process your Personal Data to comply with tax, labor and accounting obligations.

(d)

Legitimate Interests. We or a third party have a legitimate interest in using your Personal Data. Specifically, we have a legitimate interest in using your Personal Data for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our services.

4. Processing and Disclosure of Your Personal Data

Please note that we may share, process and disclose Personal Data where (i) such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you, or (ii) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed above; for instance:

(a)

Third-Party Service Providers. We may share your Personal Data with third- party service providers, for example: to Suppliers in connection with your Confirmed Booking of Hotels through the Site, directly to Hotels in connection with your Confirmed Booking, to otherwise provide you with the services; to conduct quality assurance testing; to facilitate creation of Member or Personal Accounts; and to provide technical support. Accomy may use third parties to verify your bank account and confirm your bank account balance prior to approving an ACH transaction. Accomy only shares your Personal Data with such third parties in accordance with this Privacy Policy. Information shared with such third parties are only provided on a need-to-know basis who would be bound by confidentiality obligations and/or are subject to personal data protection laws that are comparable to that under the Personal Data Protection Act 2012 (“PDPA”) and to the extent as set out in the respective privacy policies or otherwise permitted by law;

(b)

Corporate Customers. If your Member or Personal Account is associated with a Corporate Customer, we may share your Personal Data with such Corporate Customer for billing and administrative purposes. Your Personal Data may also be shared with any Administrator who has been granted access to your Member or Personal Account either by the related Corporate Customer or through your acceptance of an invitation to the services from such Administrator;

(c)

Affiliates. We may share some or all of your Personal Data with our subsidiaries, joint ventures, or other companies under a common control, in which case we will require our such affiliates to honour this Privacy Policy;

(d)

Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our shares, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy;

(e)

Professional Consultants. We may be required to share some or all of your Personal Data to our legal counsels (for example, to protect or defend the rights or property of Accomy or users of the services), accountants, auditors and any other professional consultants on a need-to-know basis;

(f)

Regulatory Authorities. We may be required to share some of all of your Personal Data as required by law and/or any applicable legal requirement(s) (including towards the prevention of any fraudulent, illegal or unlawful transaction, claim or liability) to governmental, regulatory and/or law enforcement agencies and/or in compliance with any judicial process and assistance rendered for any legal and/or regulatory investigations; and

(g)

Consent. We may also disclose Personal Data from or about you or your devices with your permission.

5. International Transfers

To the extent that we may need to transfer Personal Data outside of Accomy’s servers or Singapore (such as for data storage, data management and/or consolidation purposes), whether to our subsidiaries, group companies, business partners, affiliates or third party service providers or to data storage facilities, we shall do so in accordance with the PDPA and ensure that the standard of protection provided to Personal Data so transferred is comparable to the protection required under the PDPA.

6. Retention

Accomy shall cease to retain Personal Data or remove the means by which Personal Data can be associated with you, as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer valid and retention is no longer necessary for legal or business purposes.

7. Your Rights

Depending on local laws, you may have the right or choice to:

(a)

opt-out of some collection or uses of your Personal Data, including from receiving direct marketing communications and the anonymization of your Personal Data for data analyses. Please note that your use of some of the services may be ineffective upon opt-out. Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy;

(b)

access the Personal Data we hold about you or obtain a copy of it (e.g., via your Member or Personal Account);

(c)

update or correct any inaccuracies in your Personal Data;

(d)

receive the Personal Data you provided to us to transmit it to other service providers as you wish;

(e)

request deletion, destruction, or anonymization of your Personal Data in certain situations;

(f)

request for us to restrict the processing of your Personal Data;

(g)

withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent; and/or

(h)

lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

Note that the above list may not be exhaustive, which means that you may have additional or more limited rights in accordance with local laws. If you would like to exercise any of the rights in relation to your Personal Data, please contact us at privacy@accomy.com. In your request, please make clear: (i) what Personal Data is concerned; and (ii) which of the rights you would like to exercise.

Your request will be acknowledged and acted upon generally within thirty (30) days of receipt of such request. If for any reason, we are unable to accede to your request, you will be notified accordingly. For your protection, we may need to verify your identity before implementing your request.

Please note that Accomy may charge an administrative fee for processing your request for which you will be advised of prior to us acting upon the request. Such a fee depends on the nature and complexity of your request. Further, we may need to retain certain Personal Data information for record keeping purposes (such as to complete any transactions that you began prior to requesting such change or deletion). If we fall short of your expectations in processing your Personal Data or you wish to raise a concern or complaint about our privacy practices, please tell us because it gives us an opportunity to address the problem.

8. Security

Accomy is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure.

We also require you to enter a password to access your Member or Personal Account information. Please do not disclose your password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Accomy uses reasonable efforts to protect your Personal Data, Accomy cannot guarantee its security.

9. Effect of and Updates to Privacy Policy

This Privacy Policy 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.

This Privacy Policy is amended from time to time or as and when it is required. Such changes to our Privacy Policy shall apply from the time that the same is posted on our Site. Your continued use of Site or services will be taken as acceptance of the updated Privacy Policy, but we will seek your fresh consent before we collect more Personal Data from you or if we wish to use or disclose your Personal Data for new purposes.

10. Governing Law

This Privacy Policy has been drafted solely in accordance with the laws of the Republic of Singapore. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Privacy Policy as such.

11. Contact

If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any security concerns to us, please contact us at privacy@accomy.com

12. Disclaimer

Our Site and/or our communications with you may contain links to other websites. Please note that the Privacy Policy does not cover any external third-party websites that may be accessed through links provided on our website and/or through our communications with you. We are not responsible for the privacy practices of such other websites and advise you to read the privacy statements of each website you visit which collects Personal Data.