Privacy Policy

TruTrip values your privacy. In this Privacy Policy, we describe the information that we collect about you when you visit the Platform and use the Services, and how we use and disclose that information.

This Privacy Policy is incorporated into and is subject to TruTrip’s Terms of Use, which can be accessed at https://trutrip.co/. Your use of the Platform and any personal information you provide on the Platform is subject to this Privacy Policy and the Terms of Use. By using the Platform and/or providing your personal information to us, you hereby consent to our collection, use and disclosure of your personal information for the purposes described in this Privacy Policy.

If you have any questions or comments about this Privacy Policy, please contact Sus Banerjee, interim Data Protection Officer via [email protected] or +65 3129 2139 highlighting you wish to speak about our Privacy Policy.  You may also write to us via our registered address 80 Robinson Road, #02-00, Singapore, 068898.

Unless otherwise specified, the capitalised terms in this Privacy Policy shall bear the same meanings as that in the Terms of Use.

1. Collection of Personal Data

   Collection of Personal Information

   1. We collect personal information from Organisations, Users, Travellers and persons who visit the Platform but do not register as either Organisation, User or Traveller (“Visitors”). Organisations are required to create an account (an “Account”), and Users will be able to access and participate in certain parts, features and functions of the Platform through sub-accounts linked to such Account (“Sub-Accounts”). Visitors do not need to provide any personal information in browsing some parts of the Platform but may provide certain personal information in requesting a response or other follow-up from TruTrip. The type of personal information that we collect from Organisations, Users, Travellers and Visitors varies based on their interaction with our Platform.
      1. Visitors. In browsing the Platform, Visitors may have queries or otherwise request a response or other follow-up from TruTrip. In such cases, Visitors may voluntarily provide their name, e-mail address and telephone number in order to enable TruTrip to respond or follow-up accordingly.
      2. Organisations. During the Account registration process and before the Organisation subscribes for specific functions on the Platform, we will collect information such as registration number, e-mail address, business address, telephone number, credit history reports and payment information (e.g. credit card information). The exact information collected will vary depending on the functions subscribed to by the Organisation.
      3. Users. During the Sub-Account registration process and at times throughout the use of the Services, we will collect and store information such as your preferred name, business e-mail address and business telephone number.
      4. Travellers. During the Sub-Account registration process and at times throughout the use of the Services, we will collect and store information such information as may be relevant for any Booking made or Services requested from time to time. Such information may include (as the case may be) the Travellers’ full name, date of birth, gender, religion (for visa processing in some countries), previous names, passport information, address, credit card and payment related information, travel preference (e.g. meals), e-mail address(s), phone number(s), photo, emergency contact details as well as historical travel information and locations. Some of this information may be necessary and must be provided in order for the Travellers to obtain the Booking or Services. Other information may be optional, and Users and/or Travellers may provide such information for greater convenience if so desired. Such information may be collected from the relevant employer Organisation or Users, as the case may be.
   2. By providing us information regarding any other individuals (e.g., the Travellers), Organisations and Users hereby represent and warrant that they have obtained such individual’s consent to our collection, use and disclosure of their personal information in accordance with this Privacy Policy.  We shall be entitled to rely on such representation and warranty and shall be entitled to process such individuals’ personal data accordingly.
   3. We and our third party service providers (including advertising networks) use cookies, web beacons, and other tracking technologies to collect information about your use of the Platform and the Services, such as your browser type, your Internet Service Provider (ISP) or operating system, your domain name, your access time, the Uniform Resource Locator (URL) of the previous platform you visited, your page views, your Internet Protocol (IP) address, and the type of device that you use.
   4. We also track how frequently you visit the Platform and use the Services. We use this information (including the information collected by our third party service providers) for Platform analytics (including to determine which parts, features and functions of our Platform are used most frequently, what our users like and do not like), to assist us in determining relevant advertising (both on and off our Platform), to evaluate the success of our advertising campaigns, and as otherwise described in this Privacy Policy.
   5. We and our third party service providers collect information from you by using cookies. A cookie is a small file stored on your computer hard drive containing information about you. The cookie helps us analyse web traffic or informs you about your use of a particular Platform. Cookies allow web applications to respond to you as an individual, tailoring its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. When you visit the Platform, we may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to your computer that identifies your browser.
   6. Some of these cookies may be connected to third party companies, websites, programmes or applications. The terms of use of such cookies are governed by this Privacy Policy and the privacy policy of the relevant third party company.
   7. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Platform. The Platform may not function properly if the ability to accept cookies is disabled.
2. How TruTrip uses and discloses the information collected

   How Personal Information is Used

   1. We collect your personal information and aggregate information about the use of our Platform and Services to better understand your needs and to provide you with a better Platform experience. Specifically (but without limitation to the generality of the foregoing), we may use your personal information for any of the following reasons:
      1. to provide our Services to you, including registering you for our Services, verifying your identity and authority to use our Services, facilitating Bookings and to otherwise enable you to use our Platform and our Services;
      2. for customer support and to respond to your inquiries;
      3. for internal record-keeping purposes;
      4. to process billing and payment, including sharing with third party payment gateways, in connection with Platform;
      5. to improve and maintain our Platform;
      6. to periodically send promotional emails to the email address you provide regarding new services from TruTrip, special offers from TruTrip or other information about TruTrip that we think you may find interesting;
      7. to contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information you have requested;
      8. for TruTrip’s market research purposes, including, but not limited to, the customisation of the Platform according to your interests;
      9. to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes;
      10. to resolve disputes (where necessary), to protect ourselves and other users of the Platform and to enforce our Terms of Use;
      11. to verify the accuracy of the personal information we collect from you by comparing it with personal information collected from third parties; and
      12. to combine aggregate data with the personal information we collect.
   2. We may share the information that we collect about Organisations, Users and/or Travellers, including their personal information, as stated in this Clause 2.2:
      1. Information Disclosed to Suppliers. We will pass on Travellers’ personal information to the relevant Supplier for the Supplier’s fulfilment of a Booking or provision of the Services.
      2. Information Disclosed to Protect Us and Others. We may disclose your personal information to prevent an emergency, protect or enforce our rights, conduct due diligence and/or fraud checks on any Organisation, Traveller or User, enforce the Terms of Use and/or to protect the safety of users of our Platform or our Services or protect or enforce the rights of a third party, or as required by law. For example, we may disclose information we collect about Organisations, Users and/or Travellers to third party service providers assisting us in the conduct of due diligence and/or fraud checks in relation to a credit card or individual.
      3. Information Disclosed to Third Party Service Providers and Business Partners. We may contract with third parties for the provision and maintenance of the Platform, Services and our business operations. We may also need to share your personal information and data generated by cookies and aggregate information with these third parties. For example, we may provide your information to Stripe or other payment service providers to process your payment. The third parties will not receive any right to use your personal information beyond what is necessary to perform their obligations to provide the Services to you.
      4. Information Disclosed to Law Enforcement or Government Officials. We will disclose your information, including, without limitation, your name, address, telephone number, e-mail address, user identification history, transaction history and fraud complaints, to law enforcement or other government officials if, in our opinion, we are required to do so by law, regulation or any government authority or otherwise in co-operation with an investigation of a governmental authority.
      5. Change of Control or Liquidation of TruTrip
         1. In the event that TruTrip undergoes a change in control, including, without limitation, a merger or sale of all or substantially all of TruTrip’s assets to which the Platform relates or other corporate reorganisation in which TruTrip participates, and is thus merged with or acquired by a third party entity (a “Successor”), we hereby reserve the right to transfer the information we have collected from you to the Successor.
         2. In the event of TruTrip’s bankruptcy, reorganisation, receivership, or assignment for the benefit of creditors, or the application or laws or equitable principles affecting creditors’ rights generally, TruTrip may not be able to control how your information is transferred, used, or treated. We reserve the right to transfer the information we have collected from you to non-affiliated third parties in such an event.
      6. Information Disclosed at Your Request. We may share your personal information with other parties upon your request. We may also share your personal information with other parties if you explicitly consent to such disclosure.
3. Newsletters, Invitations, Polls and Survey

   TruTrip may at its sole discretion offer any of the following free services on the Platform, which you may select to use or receive at your option. Certain of the following services may require you to provide additional personal information as detailed below:

   1. Electronic Newsletters. We may offer a free electronic newsletter to Organisations and/or Users. We will gather the e-mail addresses of those who sign up to the mailing list for this newsletter. Organisations and Users may remove themselves from this mailing list by opting out of receiving newsletters during the registration process or by changing their preferences in the relevant profile settings page on the Platform.
   2. “Send To…”. We may install a feature that allows Users to voluntarily choose to electronically forward a link, page, or document to someone else by clicking “send to…”. To do so, the User must provide their e-mail address or phone number, as well as the e-mail address or phone number of the recipient. The User’s e-mail address and phone number is used only in the case of transmission errors and to let the recipient know who the sender of the e-mail is. The information is not used for any other purpose.
   3. Polling. We may offer interactive polls to Users so they can easily share their opinions with other Users and see what our audience thinks about important issues, and/or the Platform. Opinions or other responses to polls are aggregated and are not identifiable to any particular User. We may use a system to “tag” Users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual Users.
   4. Surveys. We may conduct user surveys from time to time to better target our content to Users and Organisations. We will not share individual responses from these surveys with any third party. We may share aggregate data with third party service providers, partners, and other third parties. We may also post aggregate data containing survey responses on our Platform. This data may be viewed and downloaded by other users of our Platform.
4. Security
   1. Your password is the key to your Account or Sub-Account (as applicable). When creating your password you should use unique numbers, letters, special characters, and combinations thereof. Do not disclose your password to anyone. If you do share your password or your personal information with others, you are solely responsible for all actions taken by your Account or Sub-Account (as applicable). If you lose control of your password, you may lose substantial control over your personal information and be subject to legally binding actions taken on your behalf. Do immediately notify TruTrip to change your password if your password has been compromised for any reason.
   2. We employ procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorised access or disclosure. TruTrip may use encryption, passwords, and physical security measures to help protect your personal information against unauthorised access and disclosure.
   3. No security measures are 100% complete. We do not promise and cannot guarantee, and you should not expect, that your personal information or private communications will not be collected and/or used by others. You should take steps to protect against unauthorised access to your password, phone, and computer.
   4. TruTrip is not responsible for the unauthorised use of your information or for any lost, stolen or compromised passwords. TruTrip is also not responsible for any activity on your Account or Sub-Account (as applicable) even if such activity is undertaken without your authority.
5. Updating, deleting and correcting your personal information
   1. You can review, correct and delete your personal information by logging into the Platform and navigating to your profile preferences page.
   2. You must promptly update your personal information if it changes or is inaccurate. We will not manually alter your personal information. We will upon your request close your Account or Sub-Account (as applicable) and remove your personal information from view as soon as reasonably possible, based on your Account or Sub-Account (as applicable) activity and in accordance with applicable law.
   3. We will retain information from terminated Accounts or Sub-Account (as applicable) in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and take any other action permitted by law that we deem necessary in our sole and absolute discretion.
6. Your rights regarding our use of your personal information
   1. We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your Account or Sub-Account (as applicable) or any Services you have requested or received from us.
   2. You may request for us to provide you with any personal information we hold about you and the ways in which your personal information has been of may have been used or disclosed for a period of not more than one year before the date of your request. The provision of such information will be subject to you supplying appropriate evidence of your identity.
7. Third party advertising networks

   We may from time to time participate in third party advertising networks that may display advertisements on other platforms based on your visits to the Platform as well as other platforms. This enables us and these third parties to target advertisements by displaying advertisements for products and services in which you might be interested. Third party advertisement network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalise advertising content to you. These third party cookies and other technologies are governed by each third party’s privacy policy. We may provide these third party advertisers with information about your usage of the Platform and the Services, as well as aggregate or non-personally identifiable information about visitors and users of the Platform.

8. Links to external platforms

   The Platform may contain links to other platforms or resources over which TruTrip does not have any control. Such links do not constitute an endorsement by TruTrip of those external platforms. You agree that TruTrip is not responsible for the content of such external platforms. We are not responsible for the protection and privacy of any information which you provide while visiting such external platforms and such sites are not governed by this Privacy Policy. Your use of any external platform is subject to the terms of use and privacy policy applicable to the external platform.

9. Privacy policy updates

   TruTrip may, in its sole and absolute discretion, change this Privacy Policy from time to time by updating this document. TruTrip will post its updated Privacy Policy on the Platform on this page. TruTrip encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Platform and/or continued provision of personal information to us will be subject to the terms of the Privacy Policy currently in effect.