Privacy Policy

Last updated: 1 May 2025

1. About This Privacy Policy

This Privacy Policy explains how JOEL MICO CONSTRUCTION LIMITED ("we", "us", "our" or "the Company") collects, uses, discloses and protects personal information provided by visitors and users of the TropicSG Escapes website located at bodafernandoynancy.com (the "Website").

JOEL MICO CONSTRUCTION LIMITED is registered in England and Wales under Company Number 17213466, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX. We act as the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We are committed to protecting your personal data and processing it in a fair, lawful and transparent manner in accordance with applicable data protection legislation. Please read this Privacy Policy carefully before using our Website or submitting any personal information.

2. Personal Data We Collect

We may collect the following categories of personal data from you:

• Identity Data: first name, last name
• Contact Data: email address, telephone number
• Technical Data: IP address, browser type and version, time zone, browser plug-in types and versions, operating system and platform, device identifiers, and other technology on the devices you use to access the Website
• Usage Data: information about how you use our Website, including pages visited, time spent on pages, links clicked and referring URLs
• Communications Data: messages and enquiries you send us through contact forms or direct email
• Marketing Preferences: your preferences in receiving marketing from us and your communication preferences

We do not knowingly collect sensitive personal data (also known as "special category" data under UK GDPR) such as health information, racial or ethnic origin, political opinions, or financial data through this Website. We do not accept payments and do not collect payment card information.

3. How We Collect Personal Data

We collect personal data through the following means:

• Direct interactions: when you complete a form on our Website (such as the free guide enrolment form or contact form), email us, or otherwise contact us voluntarily
• Automated technologies: as you interact with our Website, we may automatically collect Technical Data and Usage Data using cookies, web beacons, server logs and similar tracking technologies
• Third parties: we may receive Technical Data from analytics providers such as Google Analytics and advertising networks

4. Legal Basis for Processing

Under UK GDPR, we are required to have a valid legal basis for each processing activity involving your personal data. We rely on the following legal bases:

• Consent (Article 6(1)(a)): where you have given clear consent, for example by submitting a form to receive our free guides or by accepting our cookie notice. You may withdraw consent at any time by contacting us
• Legitimate Interests (Article 6(1)(f)): for purposes such as Website security, fraud prevention, improving our Website and services, and direct marketing (where we have conducted a balancing test and our interests do not override your rights)
• Legal Obligation (Article 6(1)(c)): where processing is necessary to comply with a legal obligation to which we are subject under United Kingdom law

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To deliver the free travel guides, itineraries and resources you have requested
• To respond to your enquiries and provide customer support
• To send you relevant travel information, updates and occasional promotional communications about Singapore tours and island experiences (where you have consented)
• To improve and personalise your experience on our Website
• To analyse Website usage and performance through analytics tools
• To detect and prevent fraud, unauthorised access and security incidents
• To comply with our legal and regulatory obligations

6. Cookies and Tracking Technologies

Our Website uses cookies — small text files placed on your device — to distinguish you from other users, remember your preferences and improve your browsing experience. We use the following types of cookies:

• Strictly Necessary Cookies: essential for the Website to function correctly. These cannot be disabled.
• Analytics Cookies: help us understand how visitors interact with the Website by collecting information anonymously. We may use Google Analytics or similar services.
• Preference Cookies: remember your settings and choices (such as whether you have accepted our cookie notice) to improve your experience.

You can control cookie settings through your web browser. However, disabling certain cookies may affect Website functionality. By accepting our cookie notice, you consent to the use of non-essential cookies as described above.

7. Data Sharing and Disclosure

We do not sell, rent or trade your personal data to third parties for their own marketing purposes. We may share your personal data in the following limited circumstances:

• Service Providers: trusted third-party companies that help us operate the Website and deliver our services (such as email delivery services, hosting providers and analytics platforms), who process data only on our documented instructions
• Legal Requirements: where disclosure is required by law, court order, or regulatory authority in the United Kingdom
• Business Transfers: in the event of a merger, acquisition, restructuring or sale of assets, your data may be transferred to a successor entity, subject to equivalent data protection obligations

All third-party service providers we engage are required to process your data lawfully and in accordance with our instructions and applicable data protection law. We do not permit them to use your data for their own purposes.

8. International Data Transfers

Some of our third-party service providers may be based outside the United Kingdom. Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements, such as using standard contractual clauses approved by the Information Commissioner's Office (ICO) or transfers to countries with an adequate level of protection as determined by the UK Government.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine retention periods include:

• The nature of the personal data and the purposes for which it was collected
• Whether the business relationship with you is ongoing
• Legal, regulatory or contractual obligations to retain certain records
• Applicable statutory limitation periods for legal claims

When personal data is no longer required, we securely delete or anonymise it.

10. Your Rights Under UK GDPR

Under UK data protection law, you have the following rights in relation to your personal data:

• Right of Access: to request a copy of the personal data we hold about you
• Right to Rectification: to request correction of inaccurate or incomplete data
• Right to Erasure: to request deletion of your personal data in certain circumstances ("right to be forgotten")
• Right to Restriction: to request that we restrict processing of your data in certain circumstances
• Right to Data Portability: to receive your personal data in a structured, commonly used and machine-readable format
• Right to Object: to object to processing based on legitimate interests or for direct marketing purposes
• Rights Related to Automated Decision-Making: not to be subject to decisions made solely by automated means that produce legal or similarly significant effects

To exercise any of these rights, please contact us using the details in Section 12 below. We will respond to verified requests within one month. There is no charge for exercising your rights, unless requests are manifestly unfounded or excessive.

11. Complaints

If you have concerns about how we handle your personal data and are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 | Website: ico.org.uk

We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

12. Contact Us

For any questions, requests or concerns relating to this Privacy Policy or our data processing practices, please contact our data protection representative:

JOEL MICO CONSTRUCTION LIMITED
128 City Road
London, United Kingdom
EC1V 2NX
Email: privacy@bodafernandoynancy.com

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the most recent revision is shown at the top of this page. We encourage you to review this page periodically to stay informed about how we protect your information.