Sino Hotels (referred to herein as “Sino”, “we”, “us”, or “our”) recognise that privacy is an important issue. This Internet Privacy Notice informs you about the type of personal data we collect on this website, the third parties with whom we might share such information, and how you can review or change the personal data you provide to us. We are dedicated to respecting your privacy and safeguarding your personally identifiable information (“personal data”).
Providing your personal data to us is voluntary, however if you do not provide this information we may not be able to provide you with the products, services or information you have requested.
When disclosing personal data to us, please ensure that the data you provide is complete and accurate. You will notify us immediately of any changes to relevant personal data so that we can update our records. To the extent permitted by law, we may take any action with respect to your personal data that we deem necessary or appropriate if we believe that it may cause us, or any third party, to suffer any loss, liability or damage.
You agree that where, in connection with our website, you submit personal data relating to third parties, you will have their consent to submit and process such data for a specified purpose(s) and that you will be responsible for any claim they may have that their information has been misappropriated from them or provided to us without their consent. We may contact the third party to confirm their consent to the relevant purpose(s) for processing their personal data.
B. CATEGORIES OF INFORMATION WE COLLECT
The information including personal data that we collect may include but not limited to:
- - Your name, gender, date of birth, marital status, occupation and the particulars of your registered status with any of our subsidiaries, associated companies and/or partners;
- - Your contact information such as telephone numbers, mailing addresses, e-mail addresses and fax numbers;
- - Your credit card or relevant payment information;
- - Your passport information including passport number, nationality, and a copy of your physical passport;
- - Your login and password details, so that we can retrieve your login details if you forget or lose them;
- - Booking and billing data that may be generated at the time you make an online booking via our website, or a third party partner website, for example Red Dot Payment;
- - Your favourite hotels and charities;
- - Your communication preferences;
- - Your responses to market surveys and contests conducted by us or on our behalf.
Minors and Children
Our websites and online services are not intended for use by minors and children and we request them not to provide personal data to us on any of our websites unless with the permission of their parent or guardian.
C. PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
When you make a reservation or purchase hotel accommodation, your request will be passed to a Sino Hotel’s reservation website that will request your name and address along with other information which personally identifies you to assist with your reservation and stay such as credit card information including its number and related details, date of arrival/departure, membership number (if any), and room preferences. We need to process your data in this way in order to perform our contractual obligations to you in relation to products and services you have requested, and to process your registration at one of our hotels.
We also collect personal data in relation to the following services.
Sweepstakes and Contests:
On occasion, we conduct sweepstakes and contests that offer the opportunity to win prizes. Each sweepstake has its own Terms and Conditions for your acceptance. Some sweepstakes require you to choose to enter and for others you will be entered automatically if certain conditions are met (e.g., making a reservation with a certain credit card). As part of entering a sweepstake, certain personal data such as name, credit card details and email address may be required. From time to time we may partner with other companies mentioned below to provide co-sponsored or co-branded promotions, products and services and may share your personal data with our co-sponsor. If you enter one of these sweepstakes or contests, you shall accept the Terms and Conditions and we may share your personal data with our co-sponsor or the third party sponsor. We need to process your personal data in this way in order to perform our contractual obligations to you in relation to a sweepstake or contest. If you do not accept the Terms and Conditions, we will not be able to offer these opportunities to you.
Contacting Us by E-mail with Questions or Comments:
When you send us an email or message us from one of our sites, we may retain information such as the content (including any follow up questions you may have), your email address, and our response. We may use this information, for example, to measure how effectively we address customer concerns online, to personalise your experience, and to continuously improve our service to you. It is in our legitimate interest to process your personal data in this way, as it allows us to deliver the type of content and product offerings in which you are most interested, to better understand and meet your needs, and to enhance our relationship with you. It also enables us to maintain high levels of customer service and responsiveness. Please click here to view the Site Usage Agreement for more details on the use of materials you submit to us.
D. DISCLOSING PERSONAL DATE TO THIRD PARTIES
In order to conduct our business, and provide products and services to you, we may disclose the personal data that you voluntarily share with us to the following third parties:
- 1. Sino Hotels including The Fullerton Hotel Singapore, The Fullerton Bay Hotel Singapore, The Fullerton Hotel Sydney, The Fullerton Ocean Park Hotel Hong Kong, City Garden Hotel, Hong Kong Gold Coast Hotel, Island Pacific Hotel, The Royal Pacific Hotel & Towers, The Pottinger Hong Kong, The Olympian Hong Kong;
- 2. Other Sino Group affiliate companies and their associates and successors (including the purchaser of the whole or part of our business);
- 3. Our business partners (“Partner Companies”) who may offer goods or services or information in relation to our business (including hotels, travel, entertainment, food and beverage, spa, conferencing, fashion, education, transportation, banking and other consumer products and services);
- 4. Agents, contractors, sub-contractors or third party service providers (including the company provide the system for running the programme or the fulfilment house for arranging the membership card and other service providers who support on service delivery to members or provide administrative, telecommunication, computer or other services to us in connection with operation of our business), and/or
- 5. Other third parties who may offer goods or services or information we think may be of interest to you, to provide services and products, process reservations and other transactions you request and to provide you with customer service.
We also rely on third party service providers to help us deliver products and services and programmes, offer products and services, and provide services in connection with our websites including communicating news and delivering promotional materials via e-mail and direct mail and administering sweepstakes and surveys.
Except as detailed in this Internet Privacy Notice, Sino Hotels will not disclose personal data to third parties outside Sino Hotels without your consent.
E. INTERNATIONAL TRANSFERS OF PERSONAL DATA
In most instances personal data is processed in the territory where the hotel is located. Personal data may also be transferred to, and stored at, another jurisdiction outside the European Economic Area (“EEA”). We will take steps that are reasonably necessary to ensure that your personal data is treated in accordance with applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal data.
F. THIRD PARTY WEBSITES
If you enter or choose to leave our websites via links to other non-Sino Group and/or non-Sino Hotels sites (including those of our advertisers, content providers, vendors, independent hotels, affiliates and partners), your visits to those sites are not covered by this Internet Privacy Notice. We do not control and shall not be responsible for the collection of personal data by third party websites, or websites not controlled or authorised by us and these websites may have their own privacy practices. We accept no responsibility or liability for third party websites' practices and policies. You should contact the relevant website administrator or web master directly to ask questions about their privacy practices and policies.
G. SECURITY AND STORAGE OF PERSONAL DATA
All internet users accept that there is an element of inherent security risk when dealing online over the internet, and we cannot guarantee the security of any personal data you disclose online. You accept the inherent security implications of dealing online over the Internet and will not hold us responsible for any breach of security unless we have been negligent and then only to the limits set out in the Site Usage Agreement. Nevertheless, we take reasonable steps and use appropriate technical and organisational measures to ensure appropriate security of the personal data we hold, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage.
We will only retain your personal data for as long as is necessary for the purposes for which that personal data was collected or processed and to the extent permitted by applicable laws. When we no longer need to use your personal data, we will remove it from our systems/records or take steps to anonymise such information so that you can no longer be identified from it (unless we need to keep your personal data for a longer period to comply with legal or regulatory obligations to which we are subject).
H. YOUR RIGHTS
Under the Personal Data Protection Act, you are entitled to access and make changes to any personal data relating to your profile held in our database. You should update the personal data held by us whenever there is a change.
If you want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your personal data is handled by us or third parties on our behalf, you may contact:
Data Privacy Officer
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws within a reasonable time, and at least within one month. We reserve the right to charge a reasonable fee for the processing of any such access request. As indicated above, all requests for access to your personal information must be submitted in writing. When communicating your request, please be sure to include your full name, address and telephone number so we can ascertain your identity, and specify clearly the type of enquiry and the original source of data collection. We may ask you to verify your identity in order to help us respond efficiently to your request.
In addition, in some circumstances based on applicable data protection laws, you may request that we cease sharing personal data about you with our business partners or that Sino Hotels cease using personal data about you on the grounds that such personal data was acquired by unjust means or used in violation of law by sending your written request to our Data Privacy Officer. We will seek to honour those requests consistently with applicable data protection laws.
- Access. You have the right to request a copy of the personal data we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information.
- Rectification. You have the right to have incomplete or inaccurate personal data that we process about you corrected. Please note that you can always make certain adjustments to certain personal data directly through your online account.
I. COOKIES POLICY
We may automatically track and collect your IP address, domain server, the type of computer and type of web browser you are using and use “cookies” to (i) customise website content specific to your interests, (ii) ensure that you do not see the same advertisement repeatedly, (iii) store your password so you do not have to re-enter it each time you use the sites and (iv) improve and update the websites. Some of the websites operated on our behalf are hosted and managed by other companies which may also track and collect this information using cookies.
“Cookies” are small pieces of electronic information (specifically, a string of text) that your browser and your operating system store on your hard drive for record-keeping purposes. Cookies can store a user’s ID and password, personalise home pages, identify which parts of a site have been visited and / or keep track of previous website use, selections or purchases.
We will only use certain cookies if you have provided consent for us to do so the first time you visit our website (we may ask you to provide consent again in future). At any time, you can choose whether to accept or deny cookies; your browser on your computer is often initially set to accept cookies. However, you can choose to deny cookies and continue browsing the sites.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Google Analytics stored by Google for 1 day to 2 years, depending on the cookies – We use Google Analytics to help analyse which pages on our website visitors viewed. When you visit our website, your web browser automatically sends certain information to Google. For more information on how Google uses your data, please refer to https://www.google.com/intl/en/policies/privacy/partners/. To opt-out, please click: here.
J. INTERNET PRIVACY NOTICE CHANGES
In the future, we may make changes to this Internet Privacy Notice. The revised Internet Privacy Notice will be dated and be displayed via a pop-up link on this website so that you will know what types of information we gather and the categories of third parties with whom we may share the information, and we will take any further action as required under applicable law, for example, obtaining your consent where we seek to process your personal data for a new purpose(s).
If you wish to opt out of receiving email communications from us, please click the “unsubscribe” link in each email you receive from us. Alternatively, and/or for any questions or concerns about this Internet Privacy Notice, you may contact us at:
Data Privacy Officer
This Internet Privacy Notice is written in the English language and may be translated into other languages. The English version shall prevail over the translated version in case of any consistency.