User: “User”, “you” or “your” refers to anyone accessing or using the services for the purpose of sharing, displaying, hosting, publishing, transacting, uploading information or viewing pictures and includes other persons jointly participating in using the services.
User Account: “User Account” is a separate part of the website, containing user information required by Passage Asia during registration.
Content: “Content” includes images, photos, audio, video, location data, ‘nearby places’, and all other forms of information or data.
Passage Asia qualifies as a Data Controller under the Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 (General Data Protection Regulation (the “GDPR”)). As such, we aim to comply with all legal obligations which the GDPR implies on Data Controllers.
1. INFORMATION COLLECTION
We collect data that is essential to our operations and enables us to provide users with better user experience. The information, through which the person may be identified, may include data that the user voluntarily enters, uses or provides when using our services or submits when creating a user account. We may also use certain performance tracking tools, such as Google Analytics. We collect two types of information from and about our users, including information by which you may be personally identified and information about your internet connection, the equipment you use to access our services, and your usage details.
The information we collect on or through our services may include:
- User account information, such as your full name, address, and phone number;
- Contact information, such as email address and other ways of communication;
- Preferences and settings, such as time zone and language;
- Searches and other activities, including the search terms you have looked up and results you selected;
- Browsing information, such as how long you used our services and which features you used;
- Communications between you and Passage Asia support staff regarding the services;
- Transactional information, including payments or purchases made through our services;
- Information from third parties, such as user ID associated with any social media account that you use to sign into the services or connect with or use with the services;
- Location data, if you have instructed your mobile device or computer to send such information.
2. HOW WE GATHER INFORMATION
We collect and store information depending on the pages you are visiting, the activities in which you elect to participate, and the services provided. You may be asked to provide information when you register for access to certain portions of our website, create a user account, request certain features, or when you make a payment. We also collect information automatically and through the use of electronic tools that may be transparent to our visitors.
3. WHAT WE DO WITH THE INFORMATION WE COLLECT?
Like other Websites, we collect information to enhance your visit and deliver more individualised content. We respect your privacy and do not share your information with anyone, except in cases when that proves necessary.
We will retain the information we collect from you for a period of maximum of 5 /five/ years, or less if it is no longer necessary for the provision of the Passage Asia services to you. After the expiry of this period we undertake to delete any information we have collected from you.
We strive to always protect your personal payment information. Payment transactions may be made via PayPal. We accept payments with all major credit and debit card providers, such as VISA, MasterCard and others. We do not hold your payment card details on the Passage Asia server.
We may use personal information we collect from you, such as age, gender, interests, activities etc. in order to better understand your behaviour and provide you with the most relevant content and advertisements. We use this information to serve you with more relevant advertisements, a process also known as remarketing.
For example, you may see certain advertisements on this website or other websites due to the fact that we contract with Google and other similar third parties, to target our advertisements based on the information we or they have collected, including but not limited through automated means, such as cookies.
You may opt out of the automated collection of information by changing your preferences at http://www.google.com/settings/ads.
Passage Asia won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you. We may share your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (4) when we have a good faith belief that doing so will help prevent imminent harm to someone. If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others. We will object to requests for information about users of our services that we believe are improper. Certain third parties who provide technical support for the operation of our Website – our Web hosting service for example – may have access to such information.
5. RIGHT OF CONSENT WITHDRAWAL
You may withdraw your consent for collecting your personal information at any time. To do so, please contact us at firstname.lastname@example.org.
6. CHANGE OR REVIEW OF INFORMATION
If you would like to review, change or delete personal data we have collected from you or you had submitted or permanently delete your account, please contact us.
7. ACCESSING & CORRECTING YOUR PERSONAL INFORMATION.
We take reasonable steps to accurately record the personal information that you provide to us, as well as any subsequent updates.
We encourage you to review, update, and correct the personal information that we maintain about you. You may request that we delete personal data about you that is inaccurate, incomplete, and irrelevant for legitimate purposes, or is being processed in a way which infringes any applicable legal requirements.
8. SECURITY: HOW WE PROTECT YOUR INFORMATION?
Passage Asia is registered as a Personal Data Controller pursuant to European Union law.
We have implemented appropriate measures in the form of various technical, physical and other means, including, but not limited to measures regarding the security of our electronic systems and databases. These means aim at improving the integrity and security of the personal information that we collect and maintain. However, please be advised that even the best security measures cannot guarantee the full elimination of all risks. If we learn of any violation, breach or danger to our security systems breach, then we will attempt to notify you electronically so that timely and appropriate protective steps can be taken. Apart from informing you via e-mail, we may post a notice through the Website if a security breach occurs.
Your personal data safety is of utmost importance to us. We review and strive to improve our security measures on a regular basis.
If we detect a breach of our security measures, which has the potential of harming you as individual we will notify you without undue delay.
9. CONTROLLING YOUR PERSONAL DATA
Other Users may be able to identify you, or associate you with your account, if you include your personal information in any content you post or make publicly available.
For more information on how you can control your data shared with us, please see section 4, 5 and 6 of the present agreement.
If you have any questions regarding the ways you can control your personal data, please contact us at email@example.com.
As mentioned, you may at any time review or change the personal information we maintain about you by contacting Passage Asia. Upon your request, we will delete your contact information and personal data from our active databases.
11. CHILDREN’S PRIVACY
Passage Asia does not knowingly collect personal information from children under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our servers. Passage Asia encourages parents to go online with their kids.
12. CHANGES TO THIS POLICY
13. GOVERNING LAW
The copyrights of our Website are the property of Passage Asia.
Texts, graphics, photographs, animations, videos and clips, visible on the Website are the object of copyright and are part of the intellectual property of Passage Asia. Those may not be reproduced, used, presented or represented without an explicit written permission by Passage Asia. Any distribution of files, obtained by the Users under the Terms and Conditions of the Website, or of parts of such files, constitutes a violation of the relevant intellectual property protection laws and is prosecuted by the law.
Nothing contained on this Website may be interpreted as granting a license or right of use as a trademark without the prior explicit written consent of Passage Asia.
Passage Asia is controlled, operated and administered entirely within Malaysia.
If you are accessing the Passage Asia Website from another jurisdiction, please be advised that you are transferring your personal information to Passage Asia in Malaysia and, by using the Website, you consent to that transfer and to abide by the applicable laws concerning your use of the Website and your agreements with us.