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PERSONAL DATA
“Personal Data” in this Policy refers to data that can identify an individual.
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COLLECTION OF PERSONAL DATA
The types of Personal Data collected includes, among other things (depending on the nature of your interaction with us):
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Name
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NRIC number, FIN number, passport number
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Date of birth
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Gender
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Country of birth / nationality
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Vehicle number
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Telephone numbers
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Email addresses
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Credit card information
You may have provided the Personal Data to us personally or authorized other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals. These individuals could be your superiors, employees, subordinates, colleagues and your family members.
Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in Section 3, or other purposes for which your consent has been sought and obtained.
If you are located in the European Union or other regions with laws governing data collection and use that may differ from Singapore law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
We’ll only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (GDPR- from 25th May 2018) and the Singapore’s Personal Data Protection Act 2012 (PDPA).
FOR EU RESIDENTS ONLY
In addition to our policies above, Custom House Properties may retain or disclose your Personal Data if we have a good faith belief that such processing is reasonably necessary to:
comply with applicable law, regulation, court order, legal process or other binding request;
prevent harm, injury or damage to us, our property, our staff or members of the public;
defend our legal rights or enforce the applicable Terms of Service; or
detect, prevent, or otherwise address fraud or security issues.
Personal Data Transfers
In addition to our policies above, please note that your Personal Data may be transferred to and stored in countries which do not provide the same level of protection for personal data as under your local law. The rights of governmental and law enforcement authorities to access your Personal Data may also differ. By using or visiting Custom House Properties’s website, you authorise us to use your Personal Data in Singapore where we operate.
Direct Marketing Opt-Out
Provision of your Personal Data for the Custom House Properties’s direct marketing activities is voluntary and Custom House Properties will not use your Personal Data for direct marketing purposes without first obtaining your consent in accordance with applicable law. You may withdraw your consent at any time by following the unsubscribe link in our direct marketing emails or by contacting info@customshouseproperties.com
Children
We do not inadvertently acquire Personal Data or other information from users under the age of 16 and will not knowingly provide this data to any third party for any purpose. If you are under 16 years old, you may not submit any personal data to us.
If a child does provide us with Personal Data over Services, a parent or guardian of that child may contact us and upon notification, we will delete from our records any information collected from children under the age of 16.
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PURPOSES FOR COLLECTION AND USE OF PERSONAL DATA
Generally, we collect and use Personal Data for the following purposes:
If you are a guest of Custom House Properties (including guests and customers of any services provided by Custom House Properties)
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To provide products and services to guests and to respond to guests’ queries, requests and feedback
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To provide, run, operate, administer and manage loyalty programmes and rewards programmes
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To keep guests updated on Custom House Properties’s products and services, including promotions, loyalty and reward programmes, for guests who have opted to receive updates.
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To seek feedback from guests and evaluate Custom House Properties’s products and services and how Custom House Properties can improve its products and services
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To manage the administrative and business operations of Custom House Properties
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To comply with applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Custom House Properties
If you are a Vendor / Service Provider / Business Partner of Custom House Properties
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For the purposes of the supply of products and services and support by vendors / service providers / business partners to Custom House Properties and the evaluation of such products and services
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Processing and payment of vendor invoices
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To manage the administrative and business operations of Custom House Properties
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To comply with applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Custom House Properties
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Security checks
Others
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To evaluate applications for employment, internships and industrial attachments with Custom House Properties
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 or disclose your Personal Data and sought your consent to such purposes. We only collect and use Personal Data for purposes for which you have consented to. If we need to use your Personal Data for any purpose to which you have not previously consented, we will seek your consent prior to using your Personal Data for the new purpose.
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DISCLOSURE, SHARING AND TRANSFER OF PERSONAL DATA
Custom House Properties does not sell or rent Personal Data that we collect from individuals, including our website visitors. We disclose and transfer Personal Data to the following parties for the purposes of managing, operating, administering and running our business and for our business and legal purposes, and in the course of or in connection with providing our products and services to our guests:
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To other members of the Custom House Properties for the purpose of keeping guests updated on the products and services, including promotions, loyalty and reward programmes of other members of the Custom House Properties, for guests who have opted to receive updates
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To other members of the Custom House Properties for purposes of evaluating our products and services and our business as a group
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To government and non-government authorities, agencies and/or regulators as required under applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies
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To our business partners for the purposes of providing products and services to our guests
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Vendors or third party service providers in connection with marketing promotions and services offered by Custom House Properties and to facilitate the planning of events / functions that Custom House Properties organises or is involved in
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To our service providers (who may be located outside Singapore) that have been retained to perform services on our behalf or on behalf of members of the Custom House Properties, including:
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Agents, contractors or third party service providers who provide operational services to Custom House Properties, e.g. courier services, telecommunications, information technology, etc.;
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Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers; and
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Vendors, service providers and consultants that have been engaged to help manage, operate, administer and run Custom House Properties’s operations and business process or provide services to facilitate our provision of our products and services
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For job applicants, your Personal Data may be shared with other members of the Custom House Properties if Custom House Properties takes the view that you may be suitable or eligible for another job position with one of the members of the Custom House Properties, unless you inform us otherwise (please refer to Section 8). The Personal Data will be used in a confidential manner to help the Custom House Properties monitor their recruitment processes.
Custom House Properties requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the section “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.
Custom House Properties’s website may contain links to third parties which are not controlled by us and which are not covered by this Personal Data Policy. You are responsible for reviewing the privacy policies for all such third parties before disclosing your Personal Data to any third party, directly or indirectly.
In addition, we would disclose Personal Data in the following circumstances:
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When we are required to do so by law
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In response to a request from law enforcement authorities or other governmental officials
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To comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data and
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Where disclosure is necessary for investigations or legal proceedings
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COOKIES AND OTHER TECHNOLOGIES
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A cookie is a small piece of information that is placed on your computer when you visit certain websites. The cookies placed by the servers hosting our websites are readable only by us, and cookies cannot access, read or modify any other data on an electric device, nor does it capture any data which allows us to identify you individually. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
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Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
Custom House Properties does not control cookies in third party sites and services, and visitors are encouraged to check the data protection policies of these sites and services to learn about their use of cookies and other technology.
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PROTECTION AND SECURITY OF PERSONAL DATA
Custom House Properties employs a reasonable range of technology and physical security arrangements and maintain safeguards to protect against the accidental or unauthorized access, collection, use, disclosure, copying, modification, disposal, deletion and other similar risks to Personal Data.
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RETENTION OF PERSONAL INFORMATION
Custom House Properties only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. For more information on our Personal Data Retention Policy, please contact our Data Protection Officer at the contact details set out in Section 8 below.
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CONTACTING US - FEEDBACK, WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA
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If you:
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access and make corrections to your Personal Data records,
you can contact our DPO via the following channels:
Phone: +90 123 456 7890
Email: info@customshouseproperties.com
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If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Custom House Properties may not be in a position to administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Custom House Properties, and your being in breach of your contractual obligations or undertakings. Custom House Properties’s legal rights and remedies in such event are expressly reserved.
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UPDATES TO THIS PERSONAL DATA NOTICE
We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes or updates to the notice. We will indicate the effective date of the notice. If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data.
Effective Date: 01 Mar 2024