We, Pacific International Lines Private Limited (“PIL”), respect your privacy and are committed to protecting your personal data.
This privacy notice is issued on behalf of the PIL Group, which shall include PIL and its direct and indirect subsidiaries, and any reference to “PIL”, “we”, “us” or “our” in this privacy notice is a reference to the relevant company in the PIL Group responsible for processing your data.
This privacy notice will give you information on how PIL collects and processes your personal data through your use of this website, including any data you may provide through this website or use any of the PIL platforms, apps, and/or online portals (“Platforms”).
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
In using and accessing this website and the Platforms, you confirm and warrant that you are above the age of minority. This website and the Platforms are not authorized for use for minors and we do not knowingly collect data relating to minors.
If you do not agree to this privacy notice or are not authorized to do so, please do not use this website and the Platforms.
Personal data, or personal information, means any means information identifying a data subject or information relating to a data subject that we can identify (directly or indirectly) from that data alone or in combination with other data we possess or can reasonably access.
Depending on how you interact with the website and the Platforms, we may collect, use, store and transfer the following categories of personal data, as described below:
We may collect personal data from and about you, including without limitation, through the following:
We will only use your personal data in accordance with the applicable laws data protection laws, and we will only disclose your personal data to third parties with your consent, unless such disclosure is permitted under the applicable data protection laws.
You may withdraw your consent of disclosure of your personal data to third parties (e.g. in relation to sending third party direct marketing communications to you via email or text message at any time) by contacting our data privacy team.
Purposes of use of your personal data
We have set out below a table on how your personal data may be used, and the bases of use as well as the our legitimate interests.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for a purpose that is compatible with the original purpose.
| Purpose | Basis and Legitimate Interests |
|---|---|
| Provision of Services. To provide our services to you, including to administer the online account you may have registered with us. |
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| Relationship Management. To manage our relationship with you, including updating you of changes to this privacy notice, obtaining feedback and answering queries. |
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| Legal and Operational. To ascertain your identity in connection with fraud detection purposes, to store, host or backup personal data for operational, legal or business reasons, to perform due diligence checks, to share personal data in connection with any proposed purchase, merger or acquisition of any part of our business (provided that we satisfy the requirements of applicable data protection law when disclosing personal data) and to comply with any legal and regulatory requirements. |
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| Marketing and Other Promotions. To provide you with information about our services, and to understand the effectiveness of the marketing we serve to you. |
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| Data Analytics and Market Research. To use data analytics to improve our website and Platforms, and to conduct market research to improve our business. |
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| Other General Purposes. Any other purpose to which your consent has been obtained, in compliance with our obligations under applicable laws |
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Apart from companies in the PIL Group, which may be situated inside or outside of Singapore, we may share your personal data with the following third parties for the purposes set out in the table in section 4 above.
If we disclose your personal data to third parties, they will be subject to obligations of confidentiality, and we will require them to maintain the security of your personal data and comply with all the applicable data protection laws.
With your consent (where required by applicable law), we will transfer the personal information we collect about you to countries outside of your country of residence. Especially if you are located and resident outside of Singapore, please note that your personal information will be transferred to Singapore. To the extent required by applicable law, and where we will be sharing, transferring or storing your personal information outside your country of residence, we will
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, as stated above.
We have put in place appropriate security measures to prevent your personal data from unauthorized access, collection, use, disclosure, processing, copying, loss, disposal, or misuse. We also limit access to your personal data to those employees, agents, contractors and other third parties on a need-to-know basis only, in respect of their purpose.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. You are also advised to exercise caution with respect to the sharing of your personal data and your authentication / security details (such as passwords, credit card details, transaction details) outside of our website and Platforms.
Under the applicable data protection laws, you may:
If you wish to take any of the above actions, please contact our data privacy team.
Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you have a general question about how PIL uses and/or protects your personal data, if you wish to make a complaint about how PIL uses your personal data, if you want to know how to exercise your dats subject right in case of a potential data breach, please contact PIL:
We reserve the right to make changes to this privacy notice at any time. Please check our website frequently to see any updates or changes to our privacy notice.
This website may include links to third-party websites, plug-ins and applications not maintained by PIL. Such third party links are subject to their own data protection and privacy policies, and you are encouraged to read the privacy notice of every website you visit.
In the process of establishing, maintaining, and terminating business relationships with you, we will process your personal information for the following purposes or scenarios.
Typically, we collect your personal information directly through your use of, access to, or submission (e.g., filling out forms) on our Official Website. In certain circumstances, we may obtain your personal information from third parties, such as through our agents, service providers, your colleagues, the entity you represent, or other public channels. In these cases, we will ensure that your personal information comes from legitimate sources. We process your personal information through internal or external information systems, or through other means (e.g., paper-based methods).
1. Relationship Management and Service Provision
To manage our business relationship with you and provide you with corresponding services, including but not limited to communication, negotiation, customer support, handling your inquiries, reporting matters, notifying you of changes to this Privacy Statement, collecting feedback, and answering questions, we need to collect and process your name, email address, phone number, company name, country/region, IP address, URL, terminal access environment information (e.g., browser type and version, browser plug-in type and version, operating system and platform technology, time zone settings), mobile device unique ID, device advertising identifier, relationship with PIL, inquiry subject, comments/reviews, port, inquiry type, reporting area, incident participants, incident details, financial impact, and supporting documents.
2. Marketing and Data Research Analysis
To provide you with service-related information, business consultations, evaluate the effectiveness of our marketing campaigns for you, use data analysis to optimize website and platform functions, and conduct market research to enhance business performance, we need to process your name, email address, phone number, company name, country/region, username, password or security questions and answers, IP address, device advertising identifier, and relationship with PIL.
3.Information Technology and Security Management
To efficiently ensure the security of Official Website access through electronic means, identify account risks, maintain network security, and prevent unauthorized access, we need to process your username, password or security questions and answers, IP address, URL, terminal access environment information (e.g., browser type and version, browser plug-in type and version, operating system and platform technology, time zone settings), mobile device unique ID, and device advertising identifier.
4.Internal Management and Compliance Reporting
To meet our internal management needs, such as investigating reported matters and carrying out compliance work, we need to process your name, email address, phone number, company name, username, relationship with PIL, inquiry subject, comments/reviews, port, inquiry type, reporting area, incident participants, incident details, financial impact, and supporting documents.
5. AI-Assisted Processing (with Human Oversight)
To analyze, optimize, and improve the efficiency and quality of our Official Website services and strengthen risk management, we may process your personal information based on AI analysis technologies (may include automated-decision making methods). Such processing involves the analysis of your submitted inquiry forms and reporting forms, aiming to identify inefficient processes, improve services, and enhance the overall visitor experience. This processing does not involve automated decision-making that produces legal effects or similarly significant impacts on you, nor does it involve profiling of personal data subjects. To achieve the above purposes, we may process your name, email address, phone number, company name, country/region, dialogue and inquiry content submitted to the AI system, AI-generated responses and suggestions, documents submitted for automated processing, data extracted from such documents, records of AI-assisted processing results, username, password or security questions and answers, IP address, URL, terminal access environment information (e.g., browser type and version, browser plug-in type and version, operating system and platform technology, time zone settings), mobile device unique ID, device advertising identifier, relationship with PIL, inquiry subject, comments/reviews, port, inquiry type, reporting area, incident participants, incident details, financial impact, and supporting documents.
1. Joint Processing
If we jointly process your personal information with a third party, we will separately inform you of the controller, processing purposes, processing methods, types of personal information processed, and other relevant information regarding the joint processing of your personal information (hereinafter referred to as the Joint Processing Privacy Policy). The Joint Processing Privacy Policy will take precedence in joint processing scenarios.
2.Entrusted Processing
We may engage third-party service providers to provide certain services for us or for you, and accordingly, we may need to entrust such third-party service providers to process your personal information. We will lawfully agree with the third-party service provider on the purpose, duration, processing methods, types of personal information, protective measures, and the rights and obligations of both parties, and we will supervise the third-party service provider’s personal information processing activities
3.Provision
We may provide your personal information to our affiliated companies in order to offer you better visitor services and improve our operational efficiency. Except as provided by law, we will only provide your personal information to partners after informing you of the recipient’s name or contact information, processing purposes, processing methods, and types of personal information, and obtaining your separate consent. At the same time, we will lawfully agree with the recipient on the purpose, duration, processing methods, types of personal information, protective measures, and the rights and obligations of both parties, and we will supervise the recipient’s personal information processing activities.
| Personal Information Recipient | Types of Personal Information Provided | Processing Purpose | Processing Methods |
|---|---|---|---|
| Our affiliated companies | Personal information listed in Section II | 15 Conducting various internal operations and management of the PIL Group,16 handling inquiries and reporting matters, and carrying out various business activities.17 | Collection, transmission, storage, etc. |
The business and personnel of the PIL Group are distributed globally. To respond to your business inquiries, cooperation contacts, compliance reporting investigations, and other business needs, and subject to compliance with applicable legal requirements and obtaining your separate consent, our PIL Group Official Website directly collects your personal information described in Section II of this Online Privacy Statement China Appendix. The Official Website is deployed outside of China, and the personal information you submit through the Official Website will be directly transferred to our cloud computing infrastructure, automated processing tools, AI support services, and centralized information systems deployed outside of China.
If you wish to learn more about the cross-border provision of your personal information or wish to exercise your relevant rights under the Personal Information Protection Law of the People’s Republic of China, you may contact us or our personal information protection representative in China, namely PIL (China) Co., Ltd., using the contact information in Section VII.
If there are any material changes to the processing methods, processing purposes, or other matters regarding the processing of your personal information during the cross-border provision, we will obtain your separate consent again.
Unless otherwise required by laws and regulations, we will retain your personal information only for the shortest period necessary to achieve the purposes of processing your personal information. For Official Website visitors, personal information is retained during your use of the Official Website. After the processing purposes are achieved or cease to exist, the relevant personal information will be retained for one year, after which it will be deleted or anonymized. We may adopt different retention periods for different categories of personal information and will strictly restrict the use of your personal information. Unless necessary, we will only store it with protective measures. For personal information generated through AI-powered customer service interactions, automated process handling, and AI information risk management, we will retain it for the period necessary to achieve the relevant processing purposes and comply with applicable legal requirements, after which such information will be deleted or anonymized. Specific retention periods for different categories of personal information may vary depending on the nature of the data and applicable legal requirements.
If you wish to learn more about the retention period of your personal information, you may contact us using the contact information in Section VII.
We have adopted managerial and technical protective measures to safeguard the security of personal information. However, networks and other processing environments are not absolutely secure. In the unfortunate event of a personal information security incident, we will immediately take remedial measures and, where necessary, inform you of the relevant circumstances of the security incident. At the same time, we will also report the relevant circumstances of the security incident to the relevant competent authorities in accordance with applicable laws and regulations.
In the process of establishing, maintaining, and terminating business relationships with the entity you represent, we will process your personal information for the following purposes or scenarios. Please note that due to differences in the actual operations of our various legal entities, the personal information processed by different legal entities may only include certain scenarios and fields listed below. Please refer to the actual collection circumstances.
In order to analyze, optimize, and improve our business processes and enhance the quality of services provided to you or the entity you represent, we may utilize process mining tools and artificial intelligence-based analytical technologies (may include automated decision-making methods) to process your personal information. Such processing is limited to the analysis of operational and transactional data for the purposes of identifying process inefficiencies, improving service delivery, and enhancing overall customer experience. For the avoidance of doubt, such processing does not involve automated decision-making that produces legal effects or similarly significant effects on you, nor does it involve the profiling of individual data subjects. We may process the following categories of personal information for the above purposes: your name, company name, email address, phone number, records of business dealings with us, information related to your use of our products and services, service payment dates and times, invoices, purchase orders, and contracts. Where we engage third-party service providers to provide process mining or AI-based analytical tools, such processing shall be conducted in accordance with Section IV of this Business Contact Privacy Statement China Appendix. If you do not agree to our processing of the aforementioned sensitive personal information, we will be unable to achieve the processing purpose, and it may affect your rights. If we process other sensitive personal information not listed above, we will separately seek your individual consent in advance.
1. Joint handling
If we jointly process your personal information with a third party, we will separately inform you of the relevant circumstances regarding the joint processing of your personal information, including the processors, processing purposes, processing methods, and types of personal information processed (hereinafter referred to as the “Joint Processing Privacy Policy”). The Joint Processing Privacy Policy will take precedence in joint processing scenarios.
2. Entrusted Handling
We may engage third-party service providers to provide certain services for us or you, for which we may need to entrust third-party service providers to process your personal information. We will, in accordance with the law, agree with the third-party service providers on the purpose, duration, processing method, types of personal information, protective measures, and the rights and obligations of both parties regarding the entrusted processing, and supervise the personal information processing activities of the third-party service providers
3. Provide
We may engage third-party service providers to provide certain services for us or you, for which we may need to entrust third-party service providers to process your personal information. We will, in accordance with the law, agree with the third-party service providers on the purpose, duration, processing method, types of personal information, protective measures, and the rights and obligations of both parties regarding the entrusted processing, and supervise the personal information processing activities of the third-party service providers
| Recipient of Personal Information | Types of Personal Information Provided | Purpose of Handling | Method of Handling |
|---|---|---|---|
| Our domestic affiliate company | Personal information listed in Section II. | Carry out various internal operational management tasks within the PIL Group, as well as conduct various business activities. | Collect, transmit, and store domestically and abroad, as well as otherwise process. |
The business and personnel of PIL Group are distributed globally. We adopt a globally unified deployment of information systems and process your personal information in accordance with the purposes outlined in Section II. Therefore, subject to compliance with applicable legal requirements, we may provide your personal information described in Section II of this Appendix to the Privacy Statement for Business Contacts in China (excluding personal information related to office premises safety) to our affiliate located outside China, Pacific International Lines (Private) Limited (hereinafter referred to as the “Overseas Recipient”), through the internal office system of Pacific International Lines Group or other reasonable means.
We, together with the overseas recipient, jointly commit to lawfully adopting security protection measures to fully ensure the security of your personal information.
If you wish to learn more about the cross-border provision of your personal information or wish to exercise your relevant rights under the Personal Information Protection Law of the People’s Republic of China, you may contact us or the overseas recipient through the contact information provided in Section VII.If there are any substantial changes in the manner of processing your personal information, the purpose of processing, or other related matters during the cross-border provision of personal information, we will seek your separate consent again.
We have implemented managerial and technical safeguards to protect the security of personal information; however, networks and other processing environments are not absolutely secure. In the unfortunate event of a personal information security incident, we will promptly take remedial measures and, if necessary, inform you of the relevant circumstances of the security incident. Additionally, we will report the relevant circumstances of the security incident to the competent authorities in accordance with applicable laws and regulations.
According to the Personal Information Protection Law of the People’s Republic of China and relevant legal provisions, you have the right to request access, correction, deletion, explanation, withdrawal of your personal information, account cancellation, and other rights, as well as to consult matters related to the processing of your personal information. Please note that once you withdraw your authorization, we will cease processing the corresponding personal information. However, your decision to withdraw consent will not affect the personal information processing activities conducted based on your prior consent. Please understand that, due to regulatory requirements, technical limitations, and cost considerations, we may refuse or charge reasonable fees for requests that lack legal basis, are technically infeasible, or involve excessively high implementation costs.
If you wish to exercise the aforementioned rights or make inquiries, please contact us through the following methods, and we will respond to your request as soon as possible.In addition, with respect to our use of methods of automated decision-making to process your personal information, you have the right to refuse decisions made solely through automated decision-making that significantly affect your rights and interests, or to request an explanation of such decisions. If you wish to exercise the foregoing rights or have any questions regarding our use of methods of automated decision-making to process your personal information, please contact us using the methods set forth below:
To us (regarding all requests or inquiries related to your personal information):
<a href=”mailto:dpo@sgp.pilship.com”>dpo@sgp.pilship.com </a>[HY15.1]
<a href=”mailto:dpo@sgp.pilship.com”>dpo@sgp.pilship.com</a>
To the Overseas Recipient (limited to requests or inquiries related to the outbound transfer of your personal information):
<a href=”mailto:dpo@sgp.pilship.com”>dpo@sgp.pilship.com</a>
<a href=”mailto:dpo@sgp.pilship.com”>dpo@sgp.pilship.com</a>