KG may collect and process: 1. Personal
information, such as: a) your name, passport number or other identification
number, telephone number(s), mailing address, email address and any other
information relating to you which you have provided us in any form you may have
submitted to us, or in other forms of interaction with you; and b) your payment
related information, such as your bank account or credit card information, and
your credit history. 2. Information about your computer hardware and software
when you use our Website. The information can include: your IP address, browser
type, domain names, access times and referring website addresses. This
information is used by KG for the operation of the Services, to maintain
quality of the Services, and to provide general statistics regarding use of the
stresidences.com Website. 3. In respect of our activities in the EU, Personal
Data shall also include personal data revealing racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union
membership, and the processing of genetic data, biometric data for the purpose
of uniquely identifying a natural person, data concerning health or data
concerning a natural person's sex life or sexual orientation, criminal
convictions and offences, and other information defined as personal data under
GDPR such as internet protocol addresses and cookie identifiers (insofar as
such information is capable of identifying individuals either directly or
indirectly). 4. In addition, if you make a reservation to be a resident at one
of our serviced apartments or hotels, you may also be asked to provide further
information including photo identification about yourself and your family
members, such as the dates of your arrival and departure. In order to provide
you with better service, we may also collect your preferences, e.g. the
preferred location of your apartment (low floor, high floor, etc.), type of
bed, preferred facilities etc.
Collection of Personal Data
Generally, we collect your Personal Data in
the following ways: a) when you submit forms, information or feedback relating
to any of our products or services (including by use of our interactive IT
touch screens such as iPads/Tablets), or submit any online queries; b) when you
register for or use any of our services on websites or apps owned or operated
by us or when you register as a member of websites owned and/or operated by us;
c) when you interact with any of our staff, for example, via face-to-face
meetings, telephone calls, letters, online forms (such as any “Contact Us”
forms on our websites), reservation chat, social media platforms and emails; d)
when you use or purchase our services or products; e) when you establish any
online accounts with us; f) when you request that we contact you; g) when you
respond to our request for additional Personal Data; h) when you ask to be
included in an email or other mailing list; i) when you respond to our
promotions and other initiatives; j) when you respond to our market surveys; k)
when you submit a job application; l) when we receive references from business
partners, online travel agents and third parties, for example, where you have
been referred by them; m) when you submit your Personal Data to us for any
other reason; n) when you make a reservation (for example through our
reservation team over the phone or online); and o) when you browse our website.
We may monitor or record phone calls and customer-facing interactions for
quality assurance, employee training and performance evaluation, identity verification
purposes, feedback, respond to your queries and requests and resolve complaints
and other related purposes. Such monitoring or recording will be in accordance
with applicable law. If you provide Personal Data of a third party (e.g.
information of your dependent, spouse, children and/or parents) to us, you
represent and warrant that the collection, use and disclosure of that Personal
Data to us, as well as the further processing of that Personal Data by us for
the purposes set out below, is lawful.
Use and Disclosure of Personal Data
In general, we will, subject to applicable
law, use and disclose your Personal Data for the following purposes: a) provide
you with the products or services that have been requested; b) help us review,
develop, improve, manage the delivery of and – to the extent this requires the
use of Personal Data – enhance our products and services, including analysing
future customer needs, conducting market research, customer satisfaction
surveys and data analytics for example to enable us to understand and determine
customer location, preferences and demographics (which does not involve
automated profiling or result in automated decision-making activity which is
regulated under the GDPR); c) communicate with you and respond to your queries,
requests and complaints; d) provide ongoing information about our products and
services which may be of interest to you; e) handle disputes and conduct and
facilitate investigations and proceedings; f) protect and enforce our
contractual and legal rights and obligations (including repayment obligations)
and for credit and internal risk management; g) prevent, detect and investigate
crime, including fraud and money-laundering, and to analyse and manage other
commercial risks; h) manage our infrastructure and facilitate business
operations (including but not limited to billing, customer service and customer
verification) and comply with internal policies and procedures; i) facilitate
business asset transactions (which may extend to any merger, acquisition or
asset sale) involving any KG entity; and j) comply with any applicable rules,
laws and regulations, codes of practice or guidelines or assist in law
enforcement and investigations by relevant authorities. Generally, we process
your Personal Data for one or more of the specific purposes identified in this
Policy based on your consent obtained. Where GDPR applies, the legal basis for
our processing of your Personal Data could also be that it is necessary for the
legitimate interests pursued by us, or a third party. These legitimate
interests include providing services to you where you are our client, managing
the relationship between KG and you and facilitating internal business purposes
and administrative purposes. In some cases, the provision and processing of
your Personal Data may be a statutory and/or contractual requirement, or may be
necessary in order to perform any contract you have agreed with us or perform
services that you have requested. When you apply for or hold a co-brand product
which is offered jointly by us and our co- brand partner(s), we may also
collect, use and disclose your Personal Data for the purpose of sharing your
Personal Data with the co-brand partners for offering, marketing and promoting
to you any products, services, offers or events which the co-brand partner
thinks may be of interest to you. We will only share your Personal Data with
the co-brand partners where permitted by applicable law. Where you have
provided us with specific consents, we may also use and disclose your Personal
Data for the following purposes: a) providing services and extending benefits
to you, including promotions, loyalty and reward programmes, sending you
industry market updates (e.g. in real estate), newsletters (e.g. on property)
and other information on our products, services, offers or promotions which may
be of interest to you and conducting market research to develop special offers,
promotional and/or marketing programmes; and b) administering contests,
competitions and conducting lucky draws, including, where necessary, announcing
the results of these contests, competitions and lucky draws and identifying and
contacting the winners. In relation to particular products or services or in
your interactions with us, we may also notify or have specifically notified you
of other purposes for which we collect, use or disclose your Personal Data. If
so, we will collect, use and disclose your Personal Data for these additional
purposes as well, unless we have specifically notified you otherwise. Your
Personal Data will be protected and kept confidential, but subject to the
provisions of any applicable law, your Personal Data may, depending on the
products or services concerned, be disclosed to third parties set out below.
Such disclosure may be subject to additional legal requirements under
applicable law, depending on the nature of such transfer to third parties. Your
Personal Data will, in each case, only be disclosed to the extent necessary and
proportionate. The third parties are: a) other divisions or entities within
Straits Organization; b) our joint venture/ alliance partners; c) our agents,
contractors, third party service providers and specialist advisers who have
been contracted to provide us with administrative, financial, research, operational
or other services in pursuance of the purposes set out in this Policy, such as
telecommunications, information technology, payment, payroll, processing,
training, market research, storage and archival; d) any third party business
partners who offer goods and services or sponsor contests or other promotional
programmes, whether in conjunction with us or not, and where permitted by
applicable laws; e) insurers or insurance investigators and credit providers;
f) the Credit Bureau, or in the event of default or disputes, any debt
collection agencies or dispute resolution centres; g) any business partner,
investor, assignee or transferee (actual or prospective) to facilitate business
asset transactions (which may extend to any merger, acquisition or asset sale)
involving KG; h) our professional advisors such as our auditors and lawyers; i)
relevant government regulators or authority or law enforcement agency to comply
with any laws or rules and regulations imposed by any governmental authority;
j) anyone to whom we transfer or may transfer our rights and obligations,
including, for example, where we obtain the services of a third party
organisation to handle any aspect of the processing of your Personal Data for
the purposes notified to you in accordance with this Policy; k) banks, credit
card companies and their respective service providers; and l) any other party
as may be consented to by you, as specified by you or as may be notified to you
by us in subsequent notices.
Transfer of Personal Data
Your Personal Data may be stored in external
servers located overseas. In addition, as described above, in carrying out our
business, it may be necessary to share information about you with and between
our related corporations and third party service providers, some of which may
be located in countries outside your country of residence. Such countries may
not afford a standard of protection similar to those in your country of
residence. However, we will take reasonable steps to ensure that your Personal
Data transmitted outside of your country of residence is adequately protected.
In addition, we will ensure that such transfers comply with the requirements of
the applicable data protection laws.
Retention of Personal Data
We may retain your Personal Data for as long
as it is necessary for the purposes it has been collected, and (i) in most
cases, up to 7 years; or (ii) in respect of our activities in the EU, up to 10
years, unless otherwise permitted by applicable law or in order to defend legal
claims. Where we no longer require your Personal Data for those purposes, we
will cease to retain such Personal Data in accordance with our internal
retention policy.
Non-disclosure
KG does not sell, rent, lease, or release your
Personal Information to third parties. KG may, from time to time, contact you
on behalf of external business partners about a particular offering that may be
of interest to you. In those cases, your unique Personal Information is not
transferred to the third party without your explicit consent. In addition, KG
may share data with trusted partners to help us perform statistical analysis,
send you email or provide customer support. All such third parties are
prohibited from using your personal information except to provide these
services to KG, and they are required to maintain the confidentiality of your
Personal Information.
Disclosure of Personal Information
KG will disclose or share your Personal
Information, without notice, only if required to do so by law or in the good
faith belief that any such action is necessary to: (a) comply with any legal
requirements or comply with legal process served on KG or the Website; (b)
protect and defend the rights or property of KG; and (c) act under exigent
circumstances to protect the personal safety of users of stresidences.com, or
the general public. We may disclose your personal information to third parties:
(a) in the event that we sell or buy any business or assets, in which case we
may disclose your personal data to the prospective seller or buyer of such
business or assets; and (b) if stresidences.com or substantially all of its
assets are acquired by a third party, in which case personal data held by it
about its customers will be one of the transferred assets.
Use of Cookies
The Website uses “cookies” to help you
personalize your online experience. A cookie is a text file that is placed on
your hard drive by a web page server. Cookies cannot be used to run programs or
deliver viruses to your computer. Cookies are uniquely assigned to you, and can
only be read by a web server in the domain that issued the cookie to you.
Cookies on the Website may be used to ensure a smooth user experience, perform
analytics, and for showing relevant advertisements. Please note that third
parties (such as analytics software) may also use cookies, over which we have
no control. These cookies are likely to be analytical/performance cookies or
targeting cookies. The Website uses Google Analytics. Please refer to http://www.google.com/policies/privacy/partners to
find out more about how Google uses data when you use our website and how to
control the information sent to Google. Most Web browsers automatically accept
cookies, but you can usually modify your browser setting to decline cookies if
you prefer. If you choose to decline cookies, you may not be able to access all
or parts of our Website or to fully experience the interactive features of the KG
services or websites you visit.
Security of Your Personal Information
We strive to maintain the safety of your
Personal Information. Any payment transactions will be encrypted using SSL
technology. Unfortunately, no internet-based service is completely secure.
Although we will do our best to protect your personal data, we cannot guarantee
the security of your data transmitted to our site; any transmission is at your
own risk. Once we have received your information, we will use strict procedures
and security features to try to prevent unauthorised access.
Access to, Updating, and Non-Use of Your Personal Information
Subject to the exceptions referred to in
section 21(2) of PDPA, you have the right to request a copy of the information
that we hold about you. If you would like a copy of some or all of your
personal information, please send an email
to
[email protected]. We may make a small charge for this
service. We want to ensure that your Personal Information is accurate and up to
date. If any of the information that you have provided to KG changes, for
example if you change your email address, name or contact number, please let us
know the correct details by sending an email
to
[email protected]. You may ask us, or we may ask you, to
correct information you or we think is inaccurate, and you may also ask us to
remove information which is inaccurate. You have the right to ask us not to
collect, use, process, or disclose your Personal Information in any of the
manner described herein. We will usually inform you (before collecting your
Personal Information) if we intend to use your Personal Information for such
purposes or if we intend to disclose your Personal Information to any third
party for such purposes. You can give us notice of your intention to halt the
collection, use, processing, or disclosure of your Personal Information at any
time by contacting us at
[email protected].
Third-Party Sites
Our website may contain links to other
websites operated by third parties, such as our business partners. We are not
responsible for the privacy practices of websites operated by third parties
that are linked to our website, unless that is a mandatory requirement by
applicable data protection laws and regulations. We encourage you to learn
about the privacy policies of such third parties. Once you have left our
website, you should check the applicable privacy policy of such third parties
at their respective websites to determine how they will handle any information
they collect from you.
Third Party Modules
Our website uses the Google Maps API from
Google Inc (“Google”). For more information about the privacy practices of
Google, please see Google’s Privacy Policy available at https://www.google.com/policies/privacy or
such other URL as Google may provide from time to time. Subject to the
requirements of applicable data protection laws, by using our website and/or
such functionality built into the website, you agree that Google’s Privacy
Policy and this Policy shall apply to the collection, use and disclosure of
your Personal Data by Google and KG respectively.
Telemarketing Policy
This section outlines our telemarketing policy
which relates only to individual users of Singapore telephone numbers and was
developed to comply with the Do Not Call (“DNC”) provisions under the PDPA. Our
telemarketing policy applies to Straits Organization unless we have notified
you otherwise in writing. We aim to comply with the DNC provisions and your
choices to receive promotional and marketing messages: a) If you have
registered your Singapore telephone number with the relevant Singapore DNC
registers, we will not send you promotional and marketing messages via SMS,
calls and other means (as applicable) to your telephone number. b) However, if
you have previously consented to our sending you such messages to your
Singapore telephone number(s), we will continue to do so until you withdraw
such consent, regardless of your DNC nominations. c) Also, if you currently
have an existing, ongoing relationship with us, depending on the nature of that
relationship, we may continue to send you promotional or marketing messages via
SMS about products and services which are related to that ongoing relationship
notwithstanding your registration with the DNC Registry, unless you opt-out of
receiving such messages.
How to Contact Us
If you have any questions about this Policy or
any queries relating to your Personal Data, or you would like to obtain access
and/or make corrections to your Personal Data records, please contact us
at
[email protected]. Please provide your full name, contact
details and the name of the property(s) you stayed at so that we can assist you
appropriately.
Governing Law
This Policy and your use of this website shall
be governed in all respects by the laws of Singapore. For the avoidance of
doubt, the applicable data protection laws will apply to the processing of your
Personal Data.
Changes to this Policy
This Policy will be reviewed from time to time
by us. We may also from time to time update this Policy to take account of new
laws and technology, changes to our operations and practices and the changing
business environment. KG encourages you to periodically review this Privacy
Policy to be informed of how KG is protecting your information. In the event of
any inconsistencies between the English version and other translations of this
Policy, the English version shall prevail. Updated on 05 August 2021.