The Garcha Group Personal Data Protection Policy (effective 15 October 2014)
This is the data protection policy of THE Garcha GROUP. In this policy, the terms “we”, “us” and “our” refer to The Garcha Group and the term “The Garcha Group” refers collectively to us, our parent company and/or its subsidiaries.
What personal data we collect
Personal data is data that can be used to identify a natural person. Examples of personal data include your name, nationality, date of birth, sex, contact details (address, email address, telephone numbers), passport or other identification number and your image on CCTV and in photographs.
If you provide the personal data of anyone else (such as anyone you book a room with or order products or services for), it means that you have obtained his/her consent to our collection, use and disclosure of his/her personal data for the purposes set out in this policy or that you validly give us such consent on their behalf.
Our purposes for collection, use and disclosure of personal data
We collect, use and disclose personal data for the following purposes:
Serving our guests/customers
◦ providing products and services as requested;
◦ providing benefits and entitlements to subscribers of our loyalty programs, which may include the promotion of products and services of the Garcha Hotels group and our partners;
◦ responding to queries or feedback; and/or
◦ addressing or investigating complaints, claims or disputes.
◦ processing orders and bookings for products and services;
◦ processing and collecting payment for products and services provided;
◦ creation, storage, hosting, backup (whether for disaster recovery or other purposes) of guest/customer records and financial and other business records; and/or
◦ verifying identity and conducting screenings, due diligence checks and credit checks.
◦ guarding and securing our premises; for monitoring and assessing the provision of products and services;
◦ financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
◦ business research, planning, statistical analysis and policy development;
◦ enhancing and improving our services;
◦ compliance with internal policies, procedures and directives;
◦ enforcing obligations owed to us; and/or
◦ complying with our legal obligations and requirements.
Marketing and promotion
◦ With your consent, conducting marketing and promotion in relation to us, other THE GARCHA GROUP group entities and/or our respective partners.
◦ We will not send telemarketing messages to your Singapore telephone number via text messages, telephone calls or facsimile transmission if we do not have your clear and unambiguous consent in writing or other recorded form to do so or if you have made the appropriate registration of your number with the Do Not Call Registry.
Photography and CCTV (closed-circuit television)
◦ We may take photographs and make videos and/or sound recordings in and around our premises from time to time, including our conference venues and function rooms. You may be captured in such photographs and recordings.
◦ We may use such photographs and/or recordings in our publications, websites and other communication channels, as well as in third party media, or display them in and around our premises and/or the premises of THE GARCHA GROUP.
◦ CCTV may be in operation in and around our premises as necessary in the interests of security.
Any other purposes relating to or arising out of the above.
We may disclose the personal data to third parties, whether located in Singapore or elsewhere, in order to achieve the purposes stated in this policy. Such third parties include:
• other THE GARCHA GROUP entities and our respective partners for the provision of products and services at your request or the conduct of marketing and promotions with your consent;
• our service providers, contractors and agents;
• third parties that you have used to purchase or make reservations or bookings for our products and services, including referral agencies, business introducers, travel agencies, online reservations booking engines, event organisers or similar service providers;
• other THE GARCHA GROUP group entities for group-wide business purposes or where such disclosure is required or permitted by law;
• regulatory authorities, any statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives or where such disclosure is required or permitted by law;
• third party accreditation and certification bodies for the purposes of obtaining and maintaining accreditation and/or certification of our business, goods and services; and/or
• anyone involved in the payment for products and services provided to you, anyone you have authorised to use our facilities, products and services and anyone you have authorized us to contact or communicate with.
We may also collect, use and disclose personal data where required or permitted by law for any purpose.
In order to achieve any of the purposes referred to above, we may need to transfer personal data outside Singapore. If we do so, we will ensure that such personal data is protected to a standard comparable to the protection accorded to personal data under the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore. In summary, this means:
• the collection, use and/or disclosure of your personal data would be for the purpose(s) for which you have given consent;
• steps would be taken to ensure accuracy and completeness of your personal data when your personal data is used or disclosed to third parties;
• security arrangements would be made to protect your personal data;
• your personal data would be retained only if necessary for legal and business purposes; and/or
• anyone who receives your personal data from us is either in a jurisdiction which has comparable data protection laws or is otherwise bound to protect your personal data.
Retention of personal data
We will retain personal data for a reasonable period in accordance with our legal and business purposes.
Access to and correction of personal data
If you wish to correct or have access to your personal data, please contact us. See the “How to contact us” section at the end of this policy. We may charge a reasonable fee for processing a request for access to personal data.
How to contact us
If you have questions or concerns regarding your personal data or any aspect of this policy, please contact us at firstname.lastname@example.org
Amendments and updates
We may amend this policy from time to time and will make available the updated policy on our Internet site at www.garchahotels.com Each time we collect, use or disclose personal data, the latest version of this policy in force at the time will apply.