1. Who is responsible for your data
This page is operated by Flyco Business Pte. Ltd. (UEN [UEN]), registered at [registered office address, Singapore]. Retreats are operated together with I Quadrant Travel Pte. Ltd. under Travel Licence No. TA03759. In this notice, "we" and "us" mean Flyco Business Pte. Ltd.
As required by the Accountability Obligation under the PDPA, we have appointed a Data Protection Officer. You can reach them at [dpo@flyco.sg] ([name of the appointed Data Protection Officer]), or by writing to the registered address above marked for the attention of the Data Protection Officer.
2. What we collect
Information you give us
The enquiry form on this page asks for:
- your full name;
- your company;
- your work email address;
- your WhatsApp or telephone number; and
- whatever you choose to write in the free-text field describing your campaign.
Please do not enter anything sensitive in the free-text field. It reaches an ordinary business inbox and is not the right place for financial details, identification numbers or anyone else's personal data.
Information collected automatically with your enquiry
When you submit the form, we also capture technical context that helps us understand where the enquiry came from: the page address you submitted from, the website that referred you, and any campaign parameters present in the link you arrived on: utm_source, utm_medium, utm_campaign, utm_content, utm_term, gclid (Google Ads) and fbclid (Meta). We also record whether you ticked the consent box.
Information collected as you browse
Unless you have turned cookies off: our analytics and advertising tags collect device and browser information, the pages and sections you view, and an approximate location derived from your IP address. None of it is sensitive personal data. In the European Economic Area and the United Kingdom those tags stay in a denied state and write nothing to the device until someone accepts on the banner; elsewhere they run from the first visit and the opt-out is always one click away. Our host records your IP address and request details in server logs regardless, which is an ordinary part of serving a website securely. What the tags are and how to change your answer is set out in our Cookie Notice.
3. Why we use it, and on what basis
We use your personal data to:
- reply to your enquiry and ask the questions we need to scope a proposal;
- prepare and send you a costed proposal and a creator shortlist;
- administer a retreat or campaign if you go ahead;
- measure which advertising and campaigns produce enquiries, so we do not waste spend on the ones that do not; and
- meet our record-keeping and legal obligations, including those under the Travel Agents Act 1975.
Under the PDPA we rely on your consent, given when you tick the box on the enquiry form, and on deemed consent for the straightforward act of replying to an enquiry you chose to send us. Where the PDPA allows us to collect, use or disclose personal data without consent, for example to manage an existing business relationship, or where the law requires disclosure, we may rely on that instead.
4. Marketing messages, and the Do Not Call Registry
Ticking the consent box lets us contact you about your enquiry by email, telephone and WhatsApp. We treat that as clear and unambiguous consent in evidential form for the purposes of Part 9 of the PDPA, which is what allows us to send you messages about this enquiry without first checking the Do Not Call Registry.
That consent covers your enquiry. We will check the Do Not Call Registry before sending unrelated marketing to a Singapore telephone number unless you have separately agreed to receive it. Any bulk commercial email or SMS we send will carry an unsubscribe facility and otherwise comply with the Spam Control Act 2007.
You may withdraw consent at any time by emailing [dpo@flyco.sg]. We will act on it within a reasonable period, and will tell you if withdrawing it means we can no longer progress your enquiry.
5. Who we share it with
We do not sell your personal data. We share it with the service providers we need to run this page and respond to you:
| Recipient | What they do | What they receive | Where |
|---|---|---|---|
| Web3Forms | Relays the enquiry form to our inboxes | Everything you type into the enquiry form, plus the campaign parameters listed in the privacy notice | Outside Singapore |
| Google (Tag Manager, Analytics 4, Google Ads) | Measures how the page is used and attributes advertising | Device and browser information, pages viewed, approximate location derived from IP address, and advertising identifiers | Outside Singapore |
| Vercel | Hosts this website and serves it to your browser | Your IP address and request metadata, in server logs | Outside Singapore |
We may also disclose personal data to our professional advisers, and to authorities or courts where we are required or permitted by law to do so.
6. Transfers out of Singapore
The providers above process data outside Singapore. Under the Transfer Limitation Obligation we take steps to satisfy ourselves that your personal data will be given a standard of protection comparable to the PDPA, through the contractual terms we accept with each of them.
7. How long we keep it
We keep enquiry records for as long as needed for the purpose they were collected for, and then for as long as we need them for legal, accounting or dispute-resolution reasons. In practice that means enquiries that do not proceed are reviewed and deleted once they are no longer of any business use, and records connected to a retreat we actually ran are kept for the periods required of a licensed travel operator. When personal data no longer serves any business or legal purpose, we cease to retain it.
8. How we protect it
This site is served over HTTPS, the enquiry form is transmitted over an encrypted connection, and access to enquiry inboxes is limited to the people who need it. No transmission over the internet is ever completely secure, so we cannot guarantee absolute security, but we take reasonable steps proportionate to the sensitivity of the data.
If a data breach occurs that is likely to result in significant harm to you, or is of significant scale, we will assess it promptly, notify the Personal Data Protection Commission within 3 calendar days of determining that it is notifiable, and notify you where the PDPA requires it.
9. Your rights
Under the PDPA you may ask us to:
- Access the personal data we hold about you, and tell you how it has been used or disclosed in the past year;
- Correct anything inaccurate or incomplete; and
- Withdraw consent to our continued use or disclosure of it.
Send requests to [dpo@flyco.sg]. We will respond as soon as reasonably possible, and will tell you if we need longer. We may charge a reasonable fee for an access request, and will give you a written estimate before doing any chargeable work. Some requests we may be unable to meet in full, for example where the data is also someone else's personal data or where an exception in the PDPA applies; we will explain if that is the case.
If you are not satisfied with how we have handled your personal data, you may complain to the Personal Data Protection Commission at pdpc.gov.sg.
10. Children
This is a business-to-business page and is not directed at children. We do not knowingly collect personal data from anyone under 13. If you believe a child has sent us personal data, write to us and we will delete it.
11. If you are outside Singapore
This notice is written to Singapore law. If you are in a jurisdiction with additional rights, for example the UK or the European Economic Area, we will honour a request that those laws give you where it applies to us. Write to [dpo@flyco.sg] and tell us where you are.
12. Changes
We may update this notice as the page or our providers change. The date at the top shows when it was last revised. Material changes affecting how we use data you have already given us will be notified to you directly where the PDPA requires it.
13. Contact
Data Protection Officer, Flyco Business Pte. Ltd., [registered office address, Singapore]. Email [dpo@flyco.sg]. For anything not related to personal data, write to skylim@flyco.sg.