A. Introduction
This Privacy Policy (this “Policy”) describes how Accumulus Pte. Ltd., its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively referred to as “Accumulus”, “we”, “us” or “our”) collect, use and disclose your User Data (as defined below), in connection with your use of any database, software, mobile applications, content, data, materials, documentation, information, services or websites created, published or owned by Accumulus, its subsidiaries, affiliates, associate companies, jointly controlled entities or its licensors, including the Atlas by Accumulus software platform and associated applications and websites created by Accumulus for use by airlines and air cargo carriers and their respective employees (collectively the “Services” and each a “Service”).
Your access or use of any Service shall constitute your acceptance of this Policy, to the fullest extent permitted by law. Please also read our User Agreement, which sets out the terms governing your access and use of the Services.
B. Information We Collect
We may collect two types of information when you access or use any Service:
1. “Personal Data”, which is any information about you, including information that directly or indirectly identifies you, or from which you are identifiable; and
2. “Non-Identifiable Data”, which is any information that is not associated with an identifiable individual, which may include any information which would otherwise be Personal Data but which has been de-identified or aggregated.
Personal Data and Non-Identifiable Data shall be referred to hereafter as “User Data”.
C. Collection of User Data
The User Data we collect falls into three categories: information you provide to us, information we collect automatically when you use our Services, and information we collect from other sources or means.
The User Data that we collect includes but is not limited to the following:
2. Information we collect automatically when you use our Services:
3. Information collected from other sources or means:
D. Use and disclosure of User Data
We use and disclose your User Data for various purposes, including but not limited to the provision, maintenance, support, development and improvement of our existing and new features, functionality and Services for you and other users, to fulfil contractual or legal obligations, in the assertion or defence of Accumulus’ legitimate interests, and to detect, prevent, mitigate and investigate fraudulent or illegal activity.
Some ways in which we may use your User Data include the following:
1. Provision and improvement of our Services: We use User Data in the provision and improvement of various existing and new functionalities, features and Services to you. Please note that the processing of User Data is essential for certain functionalities, features, or Services. Therefore, should you decline to grant any particular permission (for example the permission to access your location data) to any User Data, we will not be able to provide such functionality, feature or Services for which such permission is essential, notwithstanding the fact that a subscription has been paid for that includes such functionality, feature or Service. Any User Data may also be combined, connected or associated with data obtained from other sources for the same purpose.
2. Our interaction with you: We use your contact information to communicate with you, including to provide updates on existing, upcoming or new Services (including to investigate, respond to or resolve service issues), for customer service or research purposes, or to contact you in relation to your account, profile or any action, interaction or transaction related to your account on any Service. We may also send you reminders, suggestions, and promotional messages from us or our partners. We may also use your User Data in the enforcement of this Policy, the User Agreement and any other policies, agreements or rules which may apply to you through your use of any Service.
3. Facilitate discovery and connections: We use your User Data (such as your profile and profiles you have viewed to help others find your profile, and to help suggest other users that you should follow or connect with.
4. Interaction with other users: We enable interaction and communications between you and other users through our Services, such as the viewing of profiles and related information, and the sending and receiving of requests and messages between users. Given the social nature of some of our Services, do note that other users may have access to some of your User Data (including your activity as a user of any relevant Service) through their valid use of such Services, and they use or retain such User Data, or disclose such User Data to other third parties (e.g. if you engage in a business transaction with another user that is a company or a professional, they may need to (for their legal or professional compliance purposes) record or archive their communications with you). Please also be mindful of this when considering your activity on our Services. We may also review or check messages to protect our legitimate interests, such as to protect against activities that may be fraudulent, suspicious, or in violation of the User Agreement, any other policies, agreements or rules which may apply to you through your use of any Service, or any relevant law.
5. Security and fraud prevention: We may use your User Data for security purposes (e.g. to detect, prevent or investigate possible fraud or any other prohibited or illegal activity, anything that could harm you, us or any other person/entity), detect, prevent or investigate any violation or threatened violation of the User Agreement, any other policies, agreements or rules which may apply to you through your use of any Service, or any relevant law, or to assert or defend the legitimate interests of Accumulus or third parties (e.g. your employer or agency). We may also use or disclose your User Data with our legal advisors, law enforcement officials, government authorities or other third parties for the purposes of complying with any law or legal obligation to which we may be subject, including fulfilling any valid information requests from third parties based on any legal requirement (e.g. in the event of any potential intellectual property infringement by a user, or where it is necessary to respond to an emergency that threatens the life, health or safety of a person).
6. Publicity and community: As part of our community building and promotional efforts, we may publicise or promote certain relevant User Data, such as your listings or profile page, to other users and potential users of our Services.
7. Disclosure to service providers and business partners: We may also use, process or disclose your User Data in pursuit of the legitimate interests of us or a third party, to the extent permitted by applicable laws, such as for the analysis, enhancement or development of existing and new Services, or the offering of shared content and services with our affiliates or partners. Third parties we may disclose User Data to include:
8. Disclosure to your employer: Your data may be shared with your employer if they offer you access to our enterprise services.
9. International data transfer: Your User Data may be stored and processed in your region or in any other country where Accumulus or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. If we provide any of your User Data about you to any such entities, we will take appropriate measures to ensure such entities protect your information adequately in accordance with this Policy and applicable law.
10. Merger or sale: In the event that Accumulus, or some or all assets related to the Services are acquired by, merged with or otherwise transferred to a third party entity in connection with a contemplated change of ownership or other corporate transaction, we reserve the right, in any of these circumstances, to transfer or assign any User Data that we have collected from users as part of that merger, acquisition, sale, or other change of control event (including any action in preparation of such event).
E. Cookies
Accumulus, as well as third party service providers or partners that we work with, may use cookies, pixel tags, web beacons or similar technologies (“Cookies”) in connection with your use of the Services. These Cookies serve various functions, including enabling us to provide you with Services, to help us optimise our Services or to improve your user experience.
Cookies may have unique identifiers, and reside, among other places, on your device, in emails we send to you, and on our web pages. Cookies may transmit User Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
In certain cases, third parties (e.g. social networks that you connect your Accumulus account to) may use Cookies in our Services to collect User Data and non-personally identifiable data, and they may be able to associate the User Data they collect with other User Data they have about you from other sources. In general, we do not have access to or control over the Cookies they use, or what they do with the User Data.
Depending on the device and operating software that you are using, you may be granted the option to disable our use of certain Cookies.
F. Retention of your User Data
Accumulus retains your User Data for as long as it is required to fulfill the relevant purposes described in this Policy, for as long as may be required (or permitted) by law such as for tax and accounting purposes or for our legal or business obligations or requirements, or as otherwise communicated to you. When this is no longer the case, we will delete your User Data or take steps to properly render any or all of your User Data anonymous.
G. Protection of your User Data
We will use a variety of reasonable legal, organisational, technical, administrative and physical measures to protect the integrity and security of your User Data, which will vary depending on the sensitivity of the respective User Data. We regularly review our security practices to consider appropriate new technology and methods.
However, we seek your understanding that no security measures are perfect or impenetrable, the transmission of any information over the internet is not completely secure, and that there is no guarantee that any data may not be accessed, disclosed, used, altered, or destroyed by any breach of any of the measures we employ. Therefore, we cannot ensure or guarantee the security of any User Data transmitted through any means, and any such transmission is at your own risk.
H. Use, retention and protection of your User Data by third parties
This Policy only governs your User Data that is in our possession. Our Services may link to third party websites or services, which may receive or collect User Data from you, and the privacy practices of these third parties in respect to your User Data in their possession are not governed by this Policy. We encourage you to review the privacy policies or notices of these third parties to understand their practices.
For example, if you link your Accumulus account or otherwise connect to a third party service, you are authorising and directing us to share with or grant access to such third party service your User Data and other relevant information that we have, on your behalf.
I. Your rights with respect to your User Data
In accordance with applicable laws and regulations, you may be entitled to various rights with respect to your User Data.
You may decline to share certain User Data with us, but please note that this might affect our ability to provide any or all of our Services to you. You may also update the User Data you share with us through our Services (depending on the Service) from time to time.
To the extent where we have to rely on your consent to use any particular User Data, you have the right to decline such consent. If you had provided your consent but later choose to withdraw it, we will respect that choice in accordance with our legal rights and obligations.
You may also request that we delete some or all of your User Data, although please note that there may still be certain cases in which we may need to continue processing your information (e.g. where there are legitimate interests to uphold, or if we need to comply with other legal obligations). To make a User Data deletion request, please contact [email protected]. Please note that, to protect your privacy and the security of your User Data, we may take steps to verify your identity before proceeding with the deletion of your User Data.
Please be reminded that your choice to not share User Data, grant us consent (or to withdraw your consent) regarding the use of any particular User Data, or to request the deletion of your User Data may prevent us from the provision (or continued provision) of certain Services to you.
J. Your responsibilities with the User Data of others
When you interact with another user through our Services, we may provide you with the other user’s User Data to varying levels of detail, depending on the type of interaction with such other user.
When you receive another user’s User Data through our Services, you are the controller of such data and therefore solely and independently responsible for any subsequent use, processing or disclosure of such data that you may perform, in accordance with not only this Policy, the User Agreement, as well as any relevant law (e.g. local data protection law) that may apply to you. You are hereby reminded that any User Data of another user that you may receive through any Service shall only be used for the purposes of any interaction with such other user through any of the Services, and for purposes expressly consented by such other user. Using User Data of any other user for any other purpose shall constitute a violation of our User Agreement.
Accordingly, regardless of how you are using our Service, you should always take such measures that are necessary for you to protect or to prevent compromising any User Data of other users that may be in your possession.
If you are using our Services as part of your business (whether or not as an individual, as an organisation or as an officer, employee, representative, contractor or agent of an organisation) we recommend that you notify other users of how you may use their User Data through your own privacy notice.
If you provide us with User Data relating to another person (e.g. any employee or contractor engaged by you), you must obtain the consent of such person, or you must ensure that the use and disclosure of such User Data is otherwise legally permissible. It is your sole responsibility to inform such other person of how we will use their User Data in accordance with this Policy.
K. Amendments
Accumulus reserves the right to modify this Policy at any time and for any reason in its sole discretion without prior notice, and such modifications shall take effect immediately when posted on https://accumulus.sg/privacy-policy. To notify you of when this Policy was last modified, please refer to the date stated at the beginning of this Policy. Please review this Policy periodically for the latest modifications. Your continued access or use of any Service thereafter shall represent that you have read, understood and accepted such modifications, and that you agree to continue to be bound by and comply with the Policy as modified. If the modified Policy is not acceptable to you, your only recourse is to cease using the Services.
L. Enquiries
Please contact us at [email protected] if you have any questions or issues regarding this Policy.
We will endeavour to respond to your inquiry as soon as practicable, and we seek your understanding that our response time may be affected by the nature of your inquiry.
Depending on the nature of your inquiry, we may require you to provide us with supporting information necessary to confirm your identity and/or verify your authority before responding to your request.