“Ets Holidays” refers to Ets Holidays Sdn Bhd, including all its group companies, affiliates and subsidiaries from time to time (also referred to as “we”, “us”, or “our”). Brands of Ets Holidays are listed in https://etsholidays.com/. You acknowledge and agree that your personal data collected may be used in accordance with this Policy by and for one or more Ets Holidays group companies, which will be regarded, individually or jointly, as data controllers in respect of such data.
This Policy applies to personal data collected in connection with products and services offered by Ets Holidays or from other interactions with us where a link or other appropriate reference of incorporation to this Policy is made, for example, in connection with our products, websites, applications and other types of services offered by Ets Holidays typically in electronic form, as well as other services such as customer care and warranty services, customer events, or promotions and campaigns.
We may provide additional privacy related terms in connection with a particular Ets Holidays product or service. Such product or service specific terms prevail over this Policy to the extent of any conflict. Our products or services may also contain links to other companies’ websites and other third party services that have privacy policies of their own. We recommend that you carefully read the privacy policies of such services Ets Holidays is not responsible for the privacy practices or contents of any such third party services.
Where a consent from you to the processing of personal data described in this Policy is required under the applicable law, such consent will be obtained by appropriate mechanism such as ticking a box stating your consent, choosing technical settings for a service or website, or other statement or conduct clearly indicating your acceptance to the processing, depending on the product, website, service or application you are using.
We collect your personal data typically when you purchase our products or services, use or register into our services, enter into a sales promotion or a campaign, or otherwise interact with us. Below are examples of the categories of the data we collect on you.
We may also collect other information you provide, such as your consents, preferences and feedback, information relating to your devices and other such information you provide us with. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. Some of our services may allow you to submit information about other people, for example, if you make an order for a product that you wish us to send directly to another recipient.
Your transactions with us. We collect or request information relating to your purchase or use of our products or services as well as your other interactions with us. Such information may include, for example, details of the queries or requests you have made, the products and services provided (including delivery details), purchasing details (including payments made, credit card details, billing address, credit checks and other such financial information), details of agreements between you and Direct Print, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other similar contact points.
Location data. Certain services may involve the use of your location data. Use of your location data is, however, subject to your prior consent for each service.
Data obtained from third parties. In addition to the personal data we obtain from you, we may obtain, in accordance with applicable laws, certain personal data from list rental companies and other publicly available sources. This may include personal data such as credit information and address information updates.
THE PURPOSES OF PROCESSING
Ets Holidays processes your personal data for the purposes described in this Policy and/or any additional service specific privacy information. Please note that one or more purposes may apply simultaneously.
Provision of products and services. We may process and use your personal data to provide you the product or service you have requested, fulfill your other requests, process your order or as otherwise may be necessary to perform or enforce the contract between you and Ets Holidays. We may also process and use your personal data to ensure the functionality and security of our products and services, to identify you, and to prevent and detect fraud and other misuses.
Development of products and services. We may process and use your personal data to develop our products and/or services. However, for the most part we only use aggregate and statistical information in the development of our products and services, and not data directly identifiable to you. We may also process and use your personal data to personalize our offerings and to provide you with service more relevant to you, for example, to make recommendations and to display customized content and advertising. We may combine personal data collected in connection with your use of a particular Ets Holidays product and/or service with other personal data we may hold about you, except where such personal data was collected for a different purpose.
Communicating with you and marketing. We may process and use your personal data to communicate with you, for example, to provide information relating to our products and/or services you are using or to contact you for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalized marketing or research purposes in accordance with applicable laws, for example, to conduct market research and to communicate our products, services or promotions to you via our own or third parties’ electronic or other services.
In addition, some of our products and services may be used to promote products and services of other companies. However, Ets Holidays does not disclose your personal data to such companies for their marketing purposes without your prior consent.
Profiling. We may process and use your personal data for profiling for such purposes as targeted direct marketing and improvement of our products or services. We may also create aggregate and statistical information based on your personal data. Profiling includes automated processing of your personal data for evaluating, analyzing or predicting your personal preferences or interests in order to, for example, send you marketing messages concerning products or services best suitable for you.
TRANSFERS OF YOUR PERSONAL DATA
We may disclose your personal data to third parties solely as stated below in this Policy, or as obligated by mandatory law.
Ets Holidays group companies. You acknowledge and agree that we may share your personal data within Ets Holidays group companies, and may transfer your personal data for the use of other Ets Holidays group companies.
Service providers and other authorized third parties. We may transfer your personal data to authorized third parties who process personal data on behalf of Ets Holidays for the purposes described in this Policy, such as e.g., technical, logistics and other service providers Such parties are not permitted to use your personal data for any other purposes than for what your personal data was collected, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data.
We may also transfer your personal data, including heart rate data, biometrical data or other health related data, to a service partner, if you use such services where a third party company needs to process such data for the provision of the respective service or where you separately agree that a third party company may process your data in connection with the services or products of Ets Holidays.
Other disclosures. We may disclose and otherwise process your personal data in accordance with applicable laws to defend Ets Holidays legitimate interests, for example, in civil or criminal legal proceedings.
Mergers and Acquisitions. If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers, for the purposes of such transactions.
DATA CONCERNING MINORS
Ets Holidays does not seek to collect any information from or engage in any transactions with persons under the legal age in their respective country. Our databases may nevertheless contain personal data of children due to the fact that it is not always possible to determine precisely the age of the user. We reserve the right to block the service from any person who is or whom we reasonably suspect of being a minor.
Ets Holidays policy is to request that minors do not make purchases or engage in other legal acts on our products and services without the consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have your legal guardian’s consent, you must be able to prove that such consent exists upon request.
DATA QUALITY AND RETENTION
We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data.
Certain Ets Holidays products and services may allow you to manage your profile and the information in such profile. We encourage you to access your personal data via your profile from time to time to ensure that it is correct and up-to-date. Please remember that for such electronic services where you may manage your profile, it is your responsibility to provide us with correct details as well as to update the personal data you have provided us with in case of any changes.
We store your personal data only for a period necessary for the purpose in question or as long as required by applicable laws.
Ets Holidays implements appropriate technical and organizational security measures to prevent and minimize risks associated with providing and processing personal data.
Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors, sufficient training of Ets Holidays personnel involved in the processing, and other necessary measures to provide appropriate protection for your personal data against unauthorized use or disclosure. Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction of your personal data. If a particular part of an Ets Holidays website supports on-line transactions, we will use an industry standard security measure, such as the one available through “Secure Sockets Layer” (“SSL”), to protect the confidentiality and security of online transactions.
Some of Ets Holidays websites may also use other kinds of local storage technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. You may prevent Flash cookies from being stored by following the instructions provided by Adobe at https://helpx.adobe.com/flash-player/. Ets Holidays may use so called web beacons (or “pixel tags”) in connection with some websites. However, we do not use them to identify individual users personally. Web beacons are typically graphic images that are placed on a website and they are used to count visitors to a website and/or to access certain cookies. This information is used to improve our services. Web beacons do not typically collect any other information than what your browser provides us with as a standard part of any internet communication. If you turn off cookies, the web beacon will no longer be able to track your specific activity. The web beacon may, however, continue to collect information of visits from your IP-address, but such information will no longer be personally identifiable.
If you wish to disable cookies, or want to be notified before they are placed, you may do this in your browser settings. For example, if you are using Internet Explorer, you may disable and manage cookies by following the instructions. However, we may not be able to provide certain services or you may not be able to view certain parts of this site if you have disabled cookies.
You acknowledge and agree to the storage of cookies, other local storage technologies, beacons and other information on your devices and to the access of such cookies, local storage technologies, beacons and information by us and by the third parties mentioned above.
You have the right to request information and access to the personal data we have collected from and of you. You also have the right to request that we replenish, rectify, anonymize or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws. You have the right to request and receive the personal data we have collected on you in a commonly used and machine-readable form. In case you consider your personal data collected by us to be inaccurate, you do not wish your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.
You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it.
Please note that Ets Holidays may need to identify you and to ask for additional information in order to be able to fulfill your above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.