Data Protection Policy

The purpose of this document (“Data Protection Policy”) is to inform you of how Pan Pacific Hotels Group (“PPHG”) manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act” or “PDPA”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, signing up for any products and services offered by us (“Products and Services”), you agree and consent to PPHG (including its related corporations and its ultimate parent company) (collectively, the “Companies”), as well as its representatives and/or agents (collectively referred to herein as “PPHG”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to PPHG in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.

PPHG may from time to time update this Data Protection Policy to ensure that this Data Protection 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 Data Protection Policy as updated from time to time on our website https://www.panpacific.com. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

1.1 In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and 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.

1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other methods of interaction with you.

1.3 Please note that the data protection provisions of the PDPA do not apply to business contact information (“BCI”). BCI is defined in the PDPA as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

(a) when you submit any form, including but not limited to application and registration forms or other forms relating to any of our property developments, hospitality Products or Services;

(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Products and Services;

(c) when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;

(d) when you use our electronic services, or interact with us via our websites, and apps or use services on our websites;

(e) when you request that we contact you or request that you be included in an email or other mailing list;

(f)  when you respond to our promotions, initiatives or to any request for additional Personal Data;

(g) when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;

(h) when your images are captured by us via CCTV cameras or face recognition system while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;

(i) when you are contacted by, and respond to, our marketing representatives and customer service officers;

(j) when we receive references from business partners and third parties, for example, where you have been referred by them with your consent;

(k) when we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our Products and Services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or

(l) 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.

2.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested, or delays in processing your applications.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, PPHG collects, uses processes and discloses your Personal Data for the following specific purposes on basis of the consent given (where applicable) for:

(a) transacting with you and providing our Products and Services;

(b) responding to your queries, feedback, complaints and requests;

(c) managing the administrative and business operations of PPHG and complying with internal policies, reporting requirements and procedures;

(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

(e) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our Products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our Products and Services;

(f) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

(g) matching any Personal Data held which relates to you for any of the purposes listed herein;

(h) preventing, detecting and investigating crime and analysing and managing commercial risks;

(i) managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and  conducting security clearances);

(j) hosting, storing or backing-up your Personal Data, which may be on third party servers or data clouds;

(k) legal purposes in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

(l) our legitimate and/or lawful interests pursued by us or third parties appointed by us. When we rely on such a legitimate and/or lawful interest as a basis, we will conduct an assessment and such interests include (but are not limited to) providing Products or Services that you have contracted with us for or have requested from us in, responding to queries that you may have of us, managing or administering the business relationship between you and us;

(m) conducting investigations relating to disputes, billing or fraud;

(n) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal, statutory or regulatory bodies which are binding on PPHG (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, disclosures required in the public interest or emergencies and conducting audit checks, due diligence and investigations which may be carried out by statutory authorities); and/or; and/or

(o) purposes which are reasonably related to the aforesaid.

3.2  In addition, PPHG collects, uses and discloses your Personal Data for the following purposes:

(a) If you are a shopper, visitor, customer or an employee of an organisation which is a customer of PPHG (for Products and Services relating to, without limitation, hotels and resorts, restaurants, spas, meetings, and events):

(i) providing customer service and support (including but not limited to customer relationship management, service operations and delivery, administering rewards and benefits and attending to your requests for any other goods and services whether or not offered by PPHG); and/or

(ii) purposes which are reasonably related to the aforesaid.

(b) if you are an owner or tenant, or an employee, business partner, director or representative of an organisation that is an owner or tenant of any of our properties, whether existing or prospective:

(i) facilitating and administrating the sale or lease of our properties; (including but not limited to customer relationship management which may include the setting up and administration of any online portals for such customer relationship management, processing and confirming your purchase or tenancy, providing you with services, facilities and administrative support, and administering rewards and benefits);

(ii) maintaining our property developments and remedying defects;

(iii) managing referrals; and/or

(iv) purposes which are reasonably related to the aforesaid.

(c) if you are a visitor to our properties or office premises:

(i) facilities management (including but not limited to issuing visitor access passes, and recording entries to and exits from our premises);

(ii) providing services and facilities; and/or

(iii) purposes which are reasonably related to the aforesaid.

(d) if you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by PPHG:

(i) assessing your suitability as an external service provider or vendor for PPHG;

(ii) managing project tenders and quotations, processing orders or managing the supply of goods and services;

(iii) managing business operations and product development; and/or

(iv) purposes which are reasonably related to the aforesaid.

(e) if you submit an application to us as a candidate for an employment:

(i) conducting interviews;

(ii) processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);

(iii) providing or obtaining references and for background screening;

(iv) assessing your suitability for the position applied for;

(v) onboarding successful candidates and facilitating human resource planning and management; and/or

(vi) purposes which are reasonably related to the aforesaid.

3.3  Furthermore, where permitted under the Act, PPHG may also collect, use and disclose your Personal Data for the following “PPHG Additional Purposes”:

(a) leads generation and management for marketing PPHG's Products and Services, organising promotional and corporate social responsibility projects;

(b) providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes;

(c) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services, whether by PPHG or other third parties;

(d) administering contests and competitions and marketing campaigns, and personalising your experience at PPHG’s touchpoints;

(e) communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);

(f) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you Products and Services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or

(g) purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for PPHG Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by PPHG.

3.4 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. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.5 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.

3.6 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you have requested from PPHG.

4. Disclosure of Personal Data

4.1 PPHG will take commercially reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

(a) PPHG’s related corporations and employees; to provide Products and Services to you, address your questions and requests in relation to your interactions with us as well as our Products and Services, to maintain and operate our systems and/or services;

(b) companies providing services relating to medical screening, insurance and consultancy to PPHG;

(c) agents, contractors or third party service providers who provide operational services to PPHG, such as courier services, customer service, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, or other services to PPHG;

(d) vendors or third party service providers in connection with marketing promotions and services offered by PPHG;

(e) 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 any of the 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;

(h) building and car park management and their respective service providers;

(i) companies which provide corporate secretarial, depository, clearing and book-entry settlement services;

(j) our professional advisers such as consultants, auditors and lawyers;

(k) foreign embassies in relation to facilitating overseas travel arrangements;

(l) relevant government ministries, 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/or

(m) any other party to whom you authorise us to disclose your Personal Data to.

4.2 Please note that the disclosures referred to above may be subject to additional legal requirements under applicable law, if we do disclose your Personal Data, we will only do so to the extent necessary, proportionate and legally permitted.