Data Protection Policy

1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images. We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :    

(a) To administer your reservation or purchase of hotel accommodation with us, so that we may perform our contractual obligations to you in relation to the product and/or services which you have requested;   

(b) To send you administrative information (such as information regarding your reservations and reservation confirmations);   

(c) To provide you with marketing and/or promotional materials to you if we feel that these materials might be of interest to you;   
  
(d) To administer your online account and/or membership program with us;  

(e) To fully respond to any questions, queries, requests and/or complaints;   

(f) To ensure the safety and security of you and other guests and personnel when you visit us;   

(g) To administer your application for employment on our website, including to process the personal data 
which you have provided us with for the purposes of a job position, and  to notify you of any similar job openings in the future;  

(h) To process website data to enable us to monitor and improve our website;   

(i) To comply with our legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process;   

(j) any other purposes which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”)  

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

2.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.

3.1 We respect the confidentiality of the personal data you have provided to us.

3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations; 

(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way; 

(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual; 

(d) cases in which the disclosure is necessary for any investigation or proceedings; 

(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; 

(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or 

(g) where such disclosure without your consent is permitted by the PDPA or by law. 

3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA. 

3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data. 

4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. Please note that we will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request.
 
4.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.

4.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will :

(a) correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.; and

(b) subject to paragraph 4.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by Hotel Grand Pacific Singapore within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose. 

4.4 Notwithstanding paragraph 4.3(b), we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

4.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting a written request to us. Please note that we will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request.  

5.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.

5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal.

6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Hotel Grand Pacific Singapore to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

6.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

6.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.

7.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

7.2 Please contact us through one of the following methods with your complaint or grievance :

(a) Singapore telephone number: +65 6336 0811.
(b) Email: dpo@hotelgrandpacific.com.sg 'Attention it to the ‘Data Protection Officer’.
(c) Office address: 101 Victoria Street Singapore 188018 Attention it to the ‘Data Protection Officer’

7.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.

7.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at http://www.hotelgrandpacific.com.sg/privacypolicy-en.html.

8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.