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 properties, developments, or Products and 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, including without limitation where you interact with us via our websites and apps or use the same;
(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 documentation or information including your résumé and/or CV 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 while you are within our premises or photographs or videos taken by us or our representatives when you attend events hosted by us at non-public spaces;
(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 reason.
2.2. If you provide us with any Personal Data relating to a third party (e.g. information relating to 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 and for the collection, use, and disclosure of their Personal Data for the respective purposes by or for the benefit of HPL Group.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. If you do not do so, we may not be able to provide you with Products and Services.
6.1. In addition to and without limiting the consents you have provided to us for our collection, use, and/or disclosure of your Personal Data for the purposes set out elsewhere in this Policy or as may otherwise have been notified to you, where permitted by applicable law, HPL Group may also, in accordance with the requirements thereof, collect, use, and/or disclose your Personal Data as further detailed below, including without consent, where we meet the requirements of applicable law:
(a) for our legitimate interests or the legitimate interests of other persons, including without limitation for the following purposes:
(i) any investigations or proceedings;
(ii) fraud detection and prevention;
(iii) entering into, managing, or terminating an employment relationship or appointment; and
(iv) detection and prevention of misuse of Products and Services; and
(b) we may collect your Personal Data from any of the Companies, we may use your Personal Data, and any of the Companies may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective customer of any of the Companies).
7.1. When you interact with us on our websites, we may automatically receive information from your browser and record this in our server logs. We may also employ cookies in order for our server to recognise a return visitor and understand user behaviour including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed, and the time spent per web page). You agree that: (a) we shall retain all rights, title and interest in and to all such gathered information and data; and (b) any intellectual property rights of or in the results of such analytics shall vest solely in us.
7.2. Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device.
7.3. 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 use certain services or enter certain part(s) of our websites. This may also impact your user experience while on our websites.
9.1. HPL Group will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
9.2. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data.
9.3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, or unauthorised and/or fraudulent use of your username and password.
10.1. If you:
(a) have any questions or feedback relating to your Personal Data or our Policy, including without limitation our reliance on the legitimate interests and/or deemed consent bases for collecting, using and/or disclosing your Personal Data as described in this Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Policy; or
(c) would like to obtain access or make corrections to your Personal Data records,
you can contact us via the contact details set out below:
Data Protection Officer
dpo@hotelprop.com.sg
10.2. Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to HPL Group on your behalf.
10.3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, HPL Group may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with HPL Group, and breach of your contractual obligations or undertakings. HPL Group’s legal rights and remedies in such event are expressly reserved
11.1. Our websites may contain links to other third-party operated websites operated by third parties over which we have no control over. We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked to our websites. Once you have left our website by clicking a relevant link, you should check the applicable privacy and/or data protection policy of the third party website to find out more about how they will handle any information they collect from you.
12.1. This Policy and your use of this website shall be governed in all respects by the laws of Singapore.