PERSONAL DATA PROTECTION ACT (PDPA) 2010 NOTICE & PRIVACY POLICY

TRANSWORLD TRAVEL SERVICES SDN BHD (Company No. 133990-H/198501001543) (“the Company”, “we”, “us”, or “our”) is committed to safeguarding the personal data of our clients, website visitors, and partners.

This comprehensive Privacy Policy and Personal Data Protection Notice is prepared in accordance with the Malaysian Personal Data Protection Act 2010 (PDPA). It outlines how we collect, process, disclose, transfer, store, and protect your personal data through our website (twtmiri.com), corporate office, and ticketing outlets.

By engaging our services, booking tours, purchasing airline tickets, or interacting with our digital platforms, you explicitly consent to the processing of your Personal Data as outlined in this document.

1. Description and Categories of Personal Data Collected

We collect personal data that is reasonably necessary to fulfill your travel requirements, comply with legal obligations, or optimize our website. This includes, but is not limited to:

• Identity & General Data: Full name (matching Passport or MyKad), National Identity Card Number (MyKad), Passport number, place of issue, expiry date, date of birth, nationality, and gender.

• Contact Information: Permanent/billing address, mobile phone number, office phone number, and email address.

• Financial & Transaction Data: Bank account details, credit/debit card details (including cardholder name, card number, expiration date), and payment histories.

• Travel & Itinerary Specifications: Frequent flyer numbers, hotel loyalty program details, flight preferences, travel dates, destinations, and companion details.

• Sensitive Personal Data: Medical records or physical health status (required for mobility assistance, wheelchair arrangements, or airline fitness-to-fly clearances), and religious or dietary beliefs (for halal, kosher, or allergen-specific meal preferences).

• Technical Data: Internet Protocol (IP) address, browser type, geographic location, device type, and operational metrics collected via cookies when you browse twtmiri.com.

2. Sources of Your Personal Data

We collect personal data through transparent, lawful means:

• Directly from You: When you submit booking enquiries, fill out physical or online forms, register an account on our website, or message our travel consultants.

• From Third Parties acting on your behalf: When a corporate employer, family member, or group tour leader books travel packages for you and provides your details.

• Publicly Available Sources: Official corporate websites, directories, or government registries (primarily for corporate B2B accounts).

• Digital Interactions: Automatically via website cookies and web analytics tools.

3. Purposes of Processing Personal Data

Your personal data will be processed by us for the following operational, legal, and administrative purposes:

Core Travel Logistics

• Facilitating, issuing, and processing airline bookings, train tickets, cruise reservations, and vehicle rentals.

• Securing hotel accommodation, tour guide services, and entry tickets to attractions.

• Processing, compiling, and submitting international visa applications to foreign embassies and high commissions.

Administration & Financials

• Verifying your identity, authenticating payments, and processing invoicing or refunds.

• Liaising with insurance providers to issue comprehensive travel insurance coverage.

• Providing emergency customer support during travel disruptions, flight cancellations, or medical crises abroad.

Regulatory & Legal Compliance

• Complying with aviation safety regulations, immigration controls, customs declarations, and local law enforcement requirements.

• Maintaining internal tax, audit, and financial records as demanded by the Inland Revenue Board of Malaysia (LHDN) and the Companies Commission of Malaysia (SSM).

Marketing & Communication (Conditional upon Choice)

• Sending updates on customized tour packages, seasonal travel promotions, Sarawak tourism updates, or corporate newsletter distributions (subject to your opt-in preference).

4. Disclosure and Transfer of Personal Data (Third Parties)

To successfully deliver international and domestic travel arrangements, your personal data must inevitably be shared with specific third-party entities.

Cross-Border Transfers (Global Service Providers)

Your travel data may be transferred to, stored, or processed outside of Malaysia. This includes:

• Airlines & Global Distribution Systems (GDS): Air carriers (e.g., Malaysia Airlines, AirAsia, Singapore Airlines) and booking infrastructure providers (e.g., Amadeus, Sabre, Galileo) to secure seating and ticketing.

• In-Destination Suppliers: Destination Management Companies (DMCs), land tour operators, international hotel chains, and local transportation providers situated outside Malaysia.

• Consulates and Embassies: Foreign diplomatic missions located within Malaysia or regionally, to secure valid entry visas.

Local & Professional Disclosures

• Payment Gateways & Financial Institutions: Authorized banks and third-party merchant processors handling transactions for twtmiri.com.

• Government Authorities: The Department of Immigration Malaysia, civil aviation bodies, or Royal Malaysia Police, where mandatory by law.

• Professional Enablers: Our appointed external auditors, legal counsel, and IT/cloud service infrastructure hosting providers.

Our Commitment: We mandate that all third-party partners and contractors implement equivalent data protection controls to safeguard your data, restricting usage exclusively to the service they are contracted to fulfill.

5. Security Measures (Data Protection)

We employ stringent technical and administrative security measures to fulfill the Security Principle of the PDPA:

• Digital Safeguards: Secure Sockets Layer (SSL) encryption protocol is applied to encrypt data transmissions across twtmiri.com. Firewalls and restricted user controls secure our reservation networks.

• Physical Security: Physical copies of sensitive items (e.g., passport photocopies, visa application sheets) are preserved in locked archival storage with restricted staff clearance.

• Staff Governance: Our internal personnel are bound by strict confidentiality clauses. Unauthorized entry, reproduction, or leakage of client profiles results in formal disciplinary and legal prosecution.

6. Data Retention Period

We will not retain personal data longer than is required to execute the stated service parameters or satisfy regulatory compliance timelines:

• Booking Records: Maintained for a standard duration of seven (7) years following transaction completion to remain compliant with the Malaysian Income Tax Act 1967 and corporate audit criteria.

• Marketing Profiles: Kept active until you withdraw consent or request an explicit unsubscription from our distribution channels.

• Passport Copies / Visa Drafts: Securely purged or shredded as soon as the respective travel itinerary concludes or the application visa is granted/returned by the consulate.

7. Integrity and Rights of the Data Subject

As a data subject under the PDPA, you possess legal autonomy over your data. You may exercise the following rights:

• Right of Access: You can request a complete copy of the personal profiles we maintain under your identity.

• Right of Correction (Data Integrity): If your passport numbers, name spelling, or contact info change, you may demand instantaneous data correction to prevent booking errors.

• Right to Withdraw Consent: You can completely withdraw your consent for us to process your data. Note: If you withdraw consent for core booking functions, we will be forced to terminate your travel arrangements without liability.

• Right to Limit Processing: You can instruct us to use your data only for flight ticketing, while explicitly barring us from using it for promotional marketing.

8. Contact, Access and Correction Inquiries

To update details, exercise any data privileges, or file an official complaint regarding your data handling, you may reach out directly to our designated Compliance Representative:

Data Protection Officer
Transworld Travel Services Sdn Bhd
Physical Address: Lot 2.04, 2nd Floor, Wisma Pelita Tunku, 98000 Miri, Sarawak, Malaysia.
Direct Telephone: +60 85-422 277
Official Email: twtmiri@hotmail.com