Your privacy and protecting your Personal Data (as defined below) are important to us and is a responsibility that we take seriously. This Privacy Statement will help you to understand the purpose for which we collect, use and disclose your Personal Data.
By interacting with us and submitting Personal Data to us through our websites, mobile applications, physical premises, physical or online documents and any other channels, you agree and consent to us (and our related corporations) (collectively, “Cathay Organisation”), as well as our representatives, agents, employees (collectively referred to here as “Cathay Group”, “us”, “we” or “our”), collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to the Cathay Organisation’s authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.
Cathay Organisation may from time to time update this Privacy Statement to ensure that it is consistent with the Personal Data Protection Act 2012 (“PDPA”) of Singapore and any future developments and changes in the legal or regulatory requirements.
1. Personal Data
1.1 In this Privacy Statement, “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 any other information which we have or are likely to have access to, including data in our records as may be updated from time to time.
1.2 Examples of such Personal Data include the individual’s name, NRIC number or FIN, passport number, photograph or mobile telephone number, mailing address, email address and any other information relating to any individual provided to us by an individual, their agent or representative.
2. How we collect Personal Data
2.1 Generally, we collect Personal Data in the following ways:
(a) When you use our electronic services or interact with us via our websites, mobile applications, social media platforms or use our services on our websites;
(b) When you submit inquiries, applications, or forms;
(c) When you sign up for newsletters, promotions, or events;
(d) When you enter into any agreement, make a booking or provide information in respect of your interaction with us;
(e) When you visit our properties, and we capture your images via CCTV surveillance 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.
(f) When you interact with our staff, including customer service officers, marketing personnel and/or property managers through written means, face-to-face meetings, social media platforms, applications or emails.
(g) when you submit an employment application or provide documents or information via a resume and/or CV.
(h) Through third-party sources such as public databases, partners, or government agencies.
(i) When you submit your Personal Data to us for any other reason.
3. Purpose of Collection of Personal Data
3.1 Generally, we collect, use, and disclose your Personal Data for the following purposes:
(a) Managing the administrative and business operations of Cathay Organisation and complying with internal policies, reporting requirements and procedures;
(b) Providing customer service and responding to your feedback, inquiries or requests;
(c) Processing and managing transactions related to hotel or serviced apartment bookings, property rentals or any other form of occupation in the properties that we own or operate;
(d) Communicating with you about property-related matters, updates, or changes;
(e) Conducting market research or surveys, performing market analysis, managing and enhancing our products and services and developing new products;
(f) Conducting marketing promotions;
(f) Managing our properties, including security, maintenance, and emergency purposes;
(g) Complying with applicable laws and legal obligations, including assisting law enforcement agencies, regulatory authorities, other governmental agencies and audits;
(h) Sending you promotional and marketing communications where you have consented; and
(i) Purposes related to those above.
4. Disclosure of your Personal Data
Subject to the provisions of any applicable law, we may disclose your Personal Data to our subsidiaries, affiliates, and associated companies, service providers, contractors, and agents who assist us in delivering our services (e.g., IT services, marketing agencies, real estate agencies, payment processors, auditors and lawyers etc), government agencies or regulators to comply with legal obligations, third parties in connection with business transactions, such as mergers or acquisitions and any other party to whom you have authorized us to disclose your data.
5. Data Security
5.1 We will take commercially reasonable steps to protect your Personal Data from unauthorized access, use, disclosure, modification, or destruction. This includes implementing technical, administrative, and physical security measures, such as encryption, secure servers, access controls, and regular security audits.
5.2 However, you will appreciate that we cannot guarantee that these measures are foolproof and safe from unauthorised access. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your Personal Data. If you would prefer that we not collect Personal Data, please do not provide us with any such information.
6. Retention of Personal Data
We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable laws and regulations. When Personal Data is no longer required, we will dispose of it securely.
7. Use of Cookies
7.1 When you visit our websites, we may assign one or more cookies to your computer or other electronic device. Cookies are small text files which allow us to remember information and statistics about your visit, including, without limitation, information on how you arrive at our website, what kind of browser you are on, what operating system you are currently using, your IP address, and click stream information and time stamp (for example which pages you have viewed, the time the pages were accessed and the time spent per web page).
7.2 By continuing to use our websites, you are agreeing to the use of the cookies as outlined above. Should you wish to disable the cookies associated with these technologies, you may do so by changing the settings on your browser. However, if you choose to do so, you may be restricted from some services offered on our websites, and certain interactive features on our websites may be similarly restricted or rendered inoperable.
8. Links to Third-Party websites
This Privacy Statement does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites we do not operate or control. These websites should have their own privacy notices, which you can read to understand how they collect and process your Personal Data and your rights.
9. Contacting us – Withdrawal of Consent, Access and Correction of your Personal Data
If you have any questions or concerns about your Personal Data, would like to withdraw consent for the use or collection of your Personal Data, or would like to access or correct your Personal Data records, you may contact us via the following channels:
Write:
Data Protection Officer
Cathay Organisation Holdings Ltd
22 Martin Road #06-00
Singapore 239058
Call: (65) 6337 8181
Email: [email protected]
10. Governing Law
This Privacy Statement shall be governed in all respects by the laws of Singapore.
Date: 2nd October 2024