We use your personal information in order to fulfil our commitment to providing an unparalleled guest experience in connection with all of your interactions with Royal Plaza on Scotts, Singapore. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
2 The Application of this Policy
This Policy applies to personal information regarding guests and the other individuals from the European Union, United Kingdom and Switzerland with whom we do business or who visit us and to the use of that personal information in any form, whether oral, electronic and/or written.
This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with The Royal Plaza Group or Royal Plaza on Scotts.
While this Policy is intended to describe the broadest range of our personal information processing activities, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country/region may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
3 Types of Personal Information We Collect
The term “personal information” in this Policy refers to information that identifies or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include:
4 How We Use Personal Information
Subject to applicable laws, we may collect, use and disclose portions of your personal information in order to:
When we process your personal information as one of our guests or someone else with whom we do business, we do so in our legitimate interests (as detailed above), because of legal obligations we are subject to or because the information is required to fulfil contractual obligations to you, anyone involved in making your travel arrangements (e.g. travel agents, group travel organizers or your employer) and vendors (e.g. credit card companies, airline operators and third party loyalty programs).
Royal Plaza on Scotts uses and retains your personal information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines. For example, reservation records are retained for a period of five (5) years following the year in which the reservation was made, and sales contracts are retained for a period of Statute of Limitations plus ten (10) years. Personal information in records may be maintained for longer periods if subject to a legal hold or specific country/region requirement.
5 Disclosures of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law.
Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:
5.1 Our Agents, Service Providers and Suppliers
Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures. A list of the categories of third party agents, service providers and suppliers to which your information may be transferred may be found here.
5.2 Consumer Insights
Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us via email firstname.lastname@example.org
5.3 Credit Authorization
When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.
5.4 Business Transfers
In the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.
5.5 Legal Requirements
We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
6 Information We Collect When You Visit Us Online
If you access Royal Plaza on Scotts website, you may wish to know the following:
6.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
6.2 Usage Information
When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website. That information is not linked to you as an individual unless you create a user profile, but we may keep records of the type of device being used.
6.3 Cookies and Other Similar Technology
We use cookie technology on our websites to allow us to evaluate and improve the functionality of our websites. Our cookies by themselves cannot be used to reveal your identity. They identify your browser or device, but not you, to our servers when you visit our websites.
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our websites, including the customization features associated with creating a user profile.
6.4 Social Media
Our websites may also contain plug-ins and other features that integrate third-party social media platforms into our websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
6.5 Links to Other Websites
If you visit our website and decide, for example, to purchase a gift certificate, submit request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.
6.6 Minor Children
Our websites do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.
6.7 Targeted Advertising
Where permitted by law, we may work with other companies to share advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own websites or apps or communications sent by us, or advertisements from us displayed on other companies’ websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g. postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. Additionally, where you have consented to us doing so, we may also share your personal information with carefully-selected third parties, who may communicate directly with you. You can always choose whether or not to receive any or all of these communications by contacting us at email@example.com or following the “unsubscribe” instructions contained in the communications.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
8 Updating or Accessing Your Personal Information
Under data protection law in Europe, you have various rights in relation to the personal information about you that we process.
With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by email to firstname.lastname@example.org. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.
You may request that we correct, delete, and/or stop or restrict processing or using personal information that we hold about you by sending an email to email@example.com. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
Finally, you may in some circumstances have the ability to object to the processing of your personal information on the grounds of your particular situation. You may do so by sending us a written request by letter or email to the addresses set out at Section 9 below. If we agree that you are entitled to so object, we will cease to process your personal information.
If you are unhappy with the way we have handled your request, you can escalate your concern to the Chief Privacy Officer by sending an email to firstname.lastname@example.org
9 Changes to this Policy
Just as our business changes constantly, this Policy may also change. Where the Policy changes, we will take appropriate steps to bring the amendment to your attention. To assist you, this Policy has an effective date set out at the end of this document.
While this Policy alone does not create contractual rights, Royal Plaza on Scotts has ensured compliance with some of its legal obligations in some countries in relation to personal information by creating a set of binding standards and policies (known in some countries as binding corporate rules), approved by a number of national privacy regulators. As a result, depending on your circumstances and location, you may be able to enforce your privacy rights using those standards or policies through that regulator or a court. If you would like to know more about these standards and policies, please contact the Chief Privacy Officer at email@example.com
All requests for access to your personal information must be submitted in writing by email. We may respond to your request by letter, email, telephone or any other suitable method.
Effective Date: May 2018