LEGAL

Privacy Policy

Last updated: 15 February 2025

sampanena Pte. Ltd. (" sampanena", "we", "us", or "our") is committed to the responsible handling of personal data. This Privacy Policy describes how we collect, use, store, and protect information provided to us through our website and charter booking process.

This policy applies to all personal data processed by sampanena in connection with our services and applies to users of our website at sampanena.live.

1. Data We Collect

Information You Provide

When you submit an enquiry or book a charter, we may collect:

• Full name
• Email address
• Phone number
• Message content (enquiry details, preferences)
• Charter preferences (group size, dates, dietary requirements)

Automatically Collected Data

When you visit our website, we may automatically collect technical data including your IP address, browser type, pages visited, and time spent on the site. This is collected via cookies and analytics tools described in our Cookie Policy.

2. How We Use Your Data

We use personal data to:

• Respond to your enquiries and process charter bookings
• Send booking confirmations, pre-departure information, and relevant communications
• Improve our website and service based on aggregated usage data
• Comply with applicable legal obligations in Singapore

We do not use your personal data for unsolicited marketing without your consent.

3. Legal Basis for Processing

We process your personal data on the following grounds:

• Consent — for optional communications and analytics cookies
• Contractual necessity — to fulfil a charter booking
• Legitimate interests — to improve our services and communicate with enquirers
• Legal obligation — where required by Singapore law

4. Data Retention

Enquiry data is retained for up to 12 months after last contact. Booking data is retained for a minimum of 5 years for business and tax records. Analytics data is retained in anonymised form as per the relevant analytics provider's retention policy.

5. Sharing Your Data

We do not sell personal data. We may share data with:

• Service providers involved in delivering your charter (e.g. crew coordination)
• Analytics providers (Google Analytics) on an anonymised basis
• Legal or regulatory authorities where required by law

All third parties are required to handle data responsibly and are not permitted to use it for their own purposes.

6. Data Security

We take reasonable technical and organisational steps to protect your personal data against unauthorised access, loss, or misuse. Our website uses HTTPS encryption. Access to personal data is restricted to authorised team members.

In the event of a data breach that is likely to result in risk to individuals, we will notify the Personal Data Protection Commission (PDPC) and affected individuals in accordance with Singapore's mandatory breach notification requirements.

7. Cookies

We use cookies to improve website functionality and understand how visitors use our site. Please read our Cookie Policy for full details on the types of cookies used and how to manage your preferences.

8. Your Rights Under Singapore PDPA

Under Singapore's Personal Data Protection Act 2012 (PDPA), you have the right to:

• Access personal data we hold about you
• Correct inaccurate or incomplete personal data
• Withdraw consent for processing (where processing is consent-based)
• Request information on how your data has been or may have been used in the past year
• Lodge a complaint with the Personal Data Protection Commission at pdpc.gov.sg

To exercise any of these rights, contact us at [email protected].

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

10. Children's Privacy

Our website is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us so we can take appropriate action.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised "last updated" date. Continued use of our site following changes constitutes acceptance of the updated policy.

12. Contact

For privacy-related questions or to exercise your rights, contact us at:

• Email: [email protected]
• Address: 31 Ocean Way, Quayside Isle, Singapore 098375
• Phone: +65 6734 8291