Information Collected from All Visitors to our Website
We will obtain personal data about you when you visit us.
“Personal Data” refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information.
Additional Personal Information that May be Collected
STH may collect and process:
Personal information, such as:
- 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
- your payment related information, such as your bank account or credit card information, and your credit history.
- 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 STH for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the stsignature.com Website.
- 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).
- 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:
- 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;
- 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;
- 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;
- when you use or purchase our services or products;
- when you establish any online accounts with us;
- when you request that we contact you;
- when you respond to our request for additional Personal Data;
- when you ask to be included in an email or other mailing list;
- when you respond to our promotions and other initiatives;
- when you respond to our market surveys;
- when you submit a job application;
- when we receive references from business partners, online travel agents and third parties, for example, where you have been referred by them;
- when you submit your Personal Data to us for any other reason;
- when you make a reservation (for example through our reservation team over the phone or online); and
- 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:
- provide you with the products or services that have been requested
- 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);
- communicate with you and respond to your queries, requests and complaints;
- provide ongoing information about our products and services which may be of interest to you;
- handle disputes and conduct and facilitate investigations and proceedings;
- protect and enforce our contractual and legal rights and obligations (including repayment obligations) and for credit and internal risk management;
- prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
- 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;
- facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any STH entity; and
- 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 STH 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:
- 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
- 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:
- other divisions or entities within Straits Organization;
- our joint venture/ alliance partners;
- 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;
- 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;
- insurers or insurance investigators and credit providers;
- the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- 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 STH;
- our professional advisors such as our auditors and lawyers;
- relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
- 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;
- banks, credit card companies and their respective service providers; and
- 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
STH does not sell, rent, lease, or release your Personal Information to third parties. STH 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, STH 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 STH, and they are required to maintain the confidentiality of your Personal Information.
Disclosure of Personal Information
STH 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 STH or the Website; (b) protect and defend the rights or property of STH; and (c) act under exigent circumstances to protect the personal safety of users of stsignature.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 stsignature.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.
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 STH 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@example.com. 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 STH 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 firstname.lastname@example.org. 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@example.com.
Third Party Modules
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:
- 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.
- 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.
- 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 send an email to firstname.lastname@example.org.
Please provide your full name, contact details and the name of the property(s) you stayed at so that we can assist you appropriately.
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
In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.
Posted as of 27 September 2020.