Revised and posted as of 23 December 2015
The Ascott Limited, of registered address at 168 Robinson Road, Capital Tower, #30-01, Singapore 068912, (“Ascott”) is committed to safeguarding your Personal Data. Please read the following policy to understand how any Personal Data that you provide to us will be treated.
Your consent to this Policy supplements but does not supersede nor replace any other consents you may have previously provided to Ascott nor does it affect any rights which Ascott may have at law in connection with the collection, use or disclosure of your Personal Data.
For the avoidance of doubt, this Policy forms a part of the terms and conditions governing your relationship with us (“Terms and Conditions”) and should be read in conjunction with those Terms and Conditions.
1. What Personal Data do we collect from you?
1.1 We receive and store information about you which you provide to us, or which we collect from our website when you make a reservation, submit forms or enquiries to us or via other forms of interaction. This includes information, whether true or not, about an individual who can be indentified or identifiable (a) from that data; or (b) from that data combined with other information to which we have or are likely to have access, including data in our records as may be updated from time to time (“Personal Data”). Examples of personal data which we may collect from you include: personal information about yourself such as your name, passport/identification details, postal address, e-mail address, telephone or mobile number and credit card details. 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. smoking or non-smoking room, the preferred location of your apartment (low floor, high floor, etc.), type of bed, preferred newspaper etc. The Personal Data which we collect from you will be stored in electronic and/or in hard copy files.
1.2 You always have the option of not providing the Personal Data requested, or of withdrawing your consent to any or all use of your Personal Data (see paragraph 8below), although please note that we may be legally permitted or required to continue to process your Personal Data in certain circumstances in accordance with applicable law even if you withdraw your consent. However, depending on the nature of your request and the Personal Data concerned (for example, if you do not provide us with mandatory information), we may not be able to process your reservation, registration or request, or continue providing you with the products or services requested or administer any contractual relationship which may be in place.
2. How do we collect Personal Data?
2.1 Generally, we collect Personal Data in the following ways:
(a) when you make a reservation (which, if made on-line, is effected by clicking the ‘accept’ button) or submit forms relating to any of our Products and Services (defined below);
(b) when you make a reservation through our global reservation team over the phone or interact with any of our staff, for example, via telephone calls, letters, face-to-face meetings, online forms, reservation chat, social media platforms and emails;
(c) when you use some of our services, for example, websites and apps including establishing any Ascott Online Advantage accounts with us;
(d) when you request that we contact you, sign up as an Ascott Online Advantage member, be included in an email or other mailing list;
(e) when you respond to our promotions (provided to you in accordance with your prior consent and with applicable laws), initiatives or to any request for additional Personal Data;
(f) when you are contacted by (in accordance with the consent provided by you and/or in accordance with applicable laws), and respond to, our marketing representatives;
(g) when we receive references or reservations from our business partners, online travel agents and third parties, for example, where you have been referred by them;
(h) when we seek information from third parties about you in connection with the Products and Services you have applied for; and
(i) when you submit your Personal Data to us for any other reasons.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. In the event your Personal Data becomes inaccurate because of modifications, it is your responsibility to update your information with Ascott. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
3. What are the purposes for which we collect, use, store, duplicate, transfer, disclose or process your Personal Data?
3.1 Ascott’s primary goals in collecting, using, storing, duplicating, transferring, disclosing and processing your Personal Data includes providing our Products and Services (for details see para 3.5), enabling Ascott to improve our service levels, maintain the client relationship, respond to your feedback, queries, requests and resolve complaints, customer research, and other related purposes. To the extent Ascott stores and uses usage/traffic data of websites to establish user profiles to improve services and for marketing purposes, this will be done only with a pseudonym and Ascott will not reconnect such data with other data. Users may object to the establishment of such user profiles (see paragraph 8.)
3.2 We may also collect, use, duplicate, transfer or disclose your Personal Data for the purposes of managing the administrative and business operations of Ascott and complying with internal policies and procedures, including conducting audits, preventing, detecting and investigating crime and analyzing and managing commercial risks and conducting investigations relating to disputes, billing or fraud, and other related purposes.
3.3 We may also collect, use, duplicate, transfer or disclose your Personal Data in order to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Ascott, to facilitate any mergers, acquisitions or asset sales and to safeguard and enforce our contractual and legal rights and obligations, and other related purposes.
3.4 We may also 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. We will inform you about the recording when you call us and give you the opportunity to indicate that you do not wish for the conversation to be recorded.
3.5 In addition:
(a) If you are an individual using the products or services of Ascott, or an employee of an organisation which is a customer of Ascott (for products and services relating to, without limitation, our serviced apartments (“Products and Services”), Ascott may collect, use, duplicate, transfer and disclose your Personal Data for the purpose of providing you with the Products and Services which you have requested, facilitating the daily operation of the Products and Services (including but not limited to billing, customer service and customer verification), providing membership services to you when you sign up as an Ascott Online Advantage member, enforcement of repayment obligations, credit and internal risk management. We may also analyse your use of our Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you and purposes which are reasonably related to the aforesaid.
(b) If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Ascott, we may collect, use, duplicate, transfer or disclose your Personal Data for the purposes of managing project tenders or the supply of goods and services, processing and payment of vendor invoices and purposes which are reasonably related to the aforesaid.
(c) If you submit an application to us as a candidate for an employment position, and have consented explicitly when submitting your application we may collect, use, duplicate, transfer or disclose your Personal Data for the purposes of conducting interviews and assessing your suitability for the position applied for, processing your application which includes pre-recruitment checks and background screening, providing or obtaining employee references, processing staff referrals and any other purposes relating to any of the above;
3.6 Like most businesses, marketing is important to our business' success. We may therefore, from time to time, send you marketing and promotional material in relation to Products and Services (including but not limited to our enewsletter) or products and services of our marketing partners which we believe may be of interest to you, subject to the consent provided by you, whether you are a current or prospective customer. We may also collect, use, duplicate, transfer and disclose your Personal Data for the following “Ascott Additional Purposes”:
(i) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to Ascott's Products and Services;
(ii) leads generation and management for marketing Ascott's Products and Services;
(iii) providing and/or marketing or offering other Products and Services and benefits to you, including promotions, loyalty and reward programmes from Ascott;
(iv) administering contests, competitions and marketing campaigns or organising promotional events and corporate social responsibility projects; and
(v) purposes which are reasonably related to the aforesaid,
in each case described in this paragraph 3.6, we will only send you marketing and promotional material where such practice is in accordance with applicable laws and, where required under applicable laws, with your prior express consent.
3.7 If you are receiving promotional information from us or your Personal Data is otherwise being used for Ascott Additional Purposes and you no longer wish to receive such information, or to have your Personal Data used or disclosed for these Ascott Additional Purposes, please see paragraph 8 below for more information.
3.8 If you have provided us with your telephone number(s) and have indicated your consent to receiving marketing or promotional information via your telephone number(s), then from time to time, Ascott may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our Products and Services.
3.9 In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, duplicate, transfer or disclose your Personal Data. If so, upon obtaining your consent in accordance with applicable laws, we will collect, use, duplicate, transfer and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
4.1 Ascott will take reasonable steps using administrative, technical and physical safeguards to protect your Personal Data against unauthorised access, modification, alteration, distortion, damage or disclosure. 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 these related corporations and third party service providers may be located in countries outside Singapore or the European Economic Area that may not afford an adequate protection to personal data or have protections in place which are similar to those in your country of residence. However, Ascott will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected.
4.2 Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following parties (whether inside or outside the country in which your Personal Data was originally collected), who will each be subject to a duty to keep your Personal Data confidential (subject to any applicable laws or regulations or orders issued by a court or regulatory authority of competent jurisdiction):
(a) Ascott’s related corporations, affiliates and third parties to provide Products and Services to you, address your questions and requests in relation to your billing arrangements with us as well as our Products and Services, to maintain and operate our systems and/or services;
(b) companies providing services relating to insurance and consultancy to Ascott;
(c) agents, contractors or third party service providers who provide operational services to Ascott, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Ascott;
(d) vendors or third party service providers in connection with marketing promotions and services offered by Ascott, subject to and in accordance with the prior express consent provided by you;
(e) any investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of our group companies;
(f) collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
(g) external banks, credit card companies and their respective service providers for the purposes of processing payments made by or to you;
(h) our professional advisers such as auditors and lawyers;
(i) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(j) any other party to whom you authorise us to disclose your Personal Data to.
For avoidance of doubt, reference to any organizations or entities in this Section means reference to the organizations or entities and their representatives, employees, agents and advisors.
5.3 What are Cookies: A cookie is a small file containing a string of characters that is sent to your computer when you visit our websites for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website, your browser will read the cookie and relay the information back to the website or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
5.4 Which cookies are used on our website?
The information below explains the cookies we use on our website and why we use them:
These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
These cookies are used to make the websites easier for you to use, and to enable you to navigate from page to page within each website more easily.
These cookies are automatically deleted once you close your browser.
Unique third-party persistent cookies, clear gifs or beacon gifs
These cookies do not collect personally identifiable information on you. The information collected via these cookies are used to build profiles of different types of users in order to better tailor our products and services to each profiled group of visitors.
(c) When you interact with us on our websites, we may collect for the purposes of analysis statistical information from which individuals cannot be identified (“Aggregate Information”), such as number of users, their frequency of use, the number of page views (or page impressions) that occur on the websites and common entry and exit points into and out of the websites.
(d) We use such statistical information to understand how people use our websites and to help us improve their structure and contents. We cannot identify you personally from this information.
5.6 In addition to the cookies described above, we may also use other cookies on our website in future. These additional cookies will generally be used for the purposes described above. If the additional cookies are used for other purposes, or to collect other types of data, or provide new functionality, this section on cookies will be updated accordingly.
5.7 As we use Google Analytics on the website, a service provided by Google Inc, you should also review the Google Analytics security and privacy principles available at https://support.google.com/analytics/answer/6004245?hl=en. We use Google Analytics cookies to collect information about how visitors use our websites and the total number of times a visitor has been into our website. We use the information to improve the website and enhance the experience of our online visitors. You can, at any time, opt-out from the use of Google Analytics by either changing the settings on your browser accordingly or by clicking at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
5.8 We use the cookies of third party social networking platforms and websites to enable you to interact with these platforms and websites to share information about our websites through them (e.g. through "Like" or "Share" buttons or through comment boxes, etc.). The social networking platforms in question will have access and use the information in these cookies for their own purposes and we invite you to consult their respective privacy and cookie policies.
5.9 Information stored in cookies on the website is used exclusively by Ascott, except the one saved by Google Analytics, which is used and maintained by Google and Ascott, for statistical purposes. Our third party ad-servers, if any, may also use the information stored in the cookies to customise your website experience. We do not have any direct control over the content of these adverts.
5.10 The way which cookies can be managed depends on your browser. The following links provide information on how to configure or disable cookies in each browser:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Internet Explorer: https://windows.microsoft.com/en-SG/internet-explorer/delete-manage-cookies#ie=ie-9
- Safari: https://support.apple.com/kb/HT1677?utm_source=Agillic%20Dialogue
- Safari for iPhone: https://support.apple.com/kb/ta38619
- Chrome for Android: https://support.google.com/chrome/answer/2392971?hl=en
6. Term of retention of your Personal Data
6.1 We will retain your information for a term which shall not exceed the time strictly necessary for the purposes set out in this Policy, or for our legal or business purposes. In any case, such retention will not exceed five (5) years after the last contact between you and us, unless you continue to have a subsisting relationship with us as an Ascott Online Advantage member or subscriber of our enewsletters.
7. Third-Party Sites
8. Your rights - Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
8.1 In accordance with applicable law, you have a right to access, update, rectify and modify the Personal Data we have about you which is held by us. You also have a right to oppose, for legitimate grounds, to the processing of your information, including objecting to the processing of user profiles or to the use of your Personal Data for marketing purposes. Should you oppose to the processing of your information for legitimate grounds, you understand that we may not be able to provide you with the Products and Services.
8.2 If you:
(a) have any questions or feedback relating to your Personal Data or our Policy; or
(b) would like to exercise any of the rights set out in this paragraph 8.1;
please contact Ascott as follows:
Call: (65) 6736 9789
Write in: Data Protection Officer
168 Robinson Road, #30-01, Capital Tower, Singapore 068912
(when writing in, please enclose your full name and your passport / identification number so that we can identify you)
(c) are an Ascott Online Advantage member or a subscriber of our newsletters, you will also have the option to correct your profile data online;
(d) are an Ascott Online Advantage member, you will have the option of deactivating your account online;
(e) wish to unsubscribe from our mailing list, you may use our unsubscription form available at our websites, namely www.the-ascott.com, www.citadines.comand www.somerset.com. If submitting a formal request to unsubscribe from our mailing list through email, please include “Unsubscribe” in the subject title of your email.
8.3 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Ascott on your behalf.
9. Ascott’s Telemarketing Policy for Individual Users of Singapore Telephone Numbers
9.1 Ascott’s Telemarketing Policy relates only to individual users of Singapore telephone numbers and was developed to comply with the Do Not Call (“DNC”) provisions under Singapore’s Personal Data Protection Act 2012 (“PDPA”). Our Telemarketing Policy for Singapore Telephone Numbers applies to Ascott and our related corporations unless we have notified you otherwise in writing.
9.2 From 2 January 2014, the DNC provisions introduce certain changes to the way in which businesses may send you promotional and marketing messages via SMS, fax, calls and other means using your Singapore telephone number(s). These are messages sent to you with the intention of or advertising, promoting or offering to provide goods or services, interests in land, business or investment opportunities or advertising or promoting the supplier or provider of the aforesaid.
These changes will however generally not affect businesses sending other types of messages to you using Singapore telephone number(s) such as informational and service related messages, messages that are for business to business marketing, market survey/research or which promote charitable or religious causes, and personal messages sent by individuals.
For more information, please visit the website Do Not Call Registry & You.
9.3 Ascott aims to comply with the DNC provisions and respects your choices to receive promotional and marketing messages:
- If you have registered your Singapore telephone number with the Singapore Do Not Call (DNC) registry, we will not send you promotional and marketing messages via SMS, fax, calls and other means to your telephone number.
- 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.
9.4 The Data Protection Officer shall oversee our compliance with the DNC provisions and the rest of the PDPA. Should you have any feedback or enquiries on our compliance with the DNC provisions or you would like to manage how we may send promotional or marketing messages via your Singapore telephone number, please contact our Data Protection Officer via the methods set out in paragraph 8 above.
10. Governing Law
11. Notices and revision
11.1 Ascott may from time to time modify, update / change this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our website. Please check back regularly for updated information on the handling of your Personal Data. If we make any material changes in the way we collect, use, and/or share your Personal Data, we will notify you by posting notice of the changes on the website.
11.2 In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.