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At RE&S Holdings Limited (collectively "RE&S") we respect the privacy and confidentiality of the personal data of our Clients, Associates and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
2 How We Collect Your Personal Data
Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g. full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.
We collect your personal data when you:
• you apply for any of our membership or loyalty programs;
• you contact us for making any reservations (at any of our outlets or reservation lines), whether through phone, fax, letters, emails, online or otherwise;
• you contact us on your queries, feedback, request and/or complaints;
• you fill in any of our forms, whether physical or online, including but not limited to survey and feedback forms;
• you participate in our marketing and/or promotional events, such as lucky draws, road shows, or seasonal products launches;
• you request for or use any of our services, including but not limited to events and catering;
• you are submitting an employment application to us;
• you provide us with your contact details at any of our outlets, whether through leaving a copy of your business card with us or otherwise;
• your images being captured by our close-circuit television cameras while you are near or within our premises, or via photographs or videos taken by us or our representatives at our premises and outlets;
• you visit or browsing our website(s);
• you subscribe for email alerts on our website;
• our conducting of interviews for matters including but not limited to employment;
• our conducting of market research or surveys;
• you interact with our staff via telephone calls, letters, fax, face-to-face meetings, social media platforms, emails and any other forms of communication; or
• you submit your personal data to us for any other reason.
3 Types of Personal Data We Collect About You
The types of personal data we collect about you include:
• Your contact information (Name, Address, Phone No., Email Address)
• Your personal details (Name, Gender, Date of Birth, Country of Birth, Country of Residence, Citizenship, Nationality, Race/Ethnicity)
• Your personal and professional details contained in your curriculum vitae when you apply to us for a job.
4 How We Use Your Personal Data
We use the personal data you provide us for one or more of the following purposes:
• to process your application as a member to our membership or loyalty programs, administer and manage your membership, and provide you the benefits of such programs;
• to administer, manage and carry out marketing activities including but not limited to lucky draws, competitions, road shows, or seasonal products launches;
• to announce, in any form of media the results of our lucky draws, competitions or other marketing or promotional events, and to identify and contact the winners of any prizes won from such events;
• to provide and send you marketing, advertising and promotional information and materials relating to membership or loyalty programs, products, events and/or services offered by RE&S through various channels including (but not limited to) SMS, voice calls, email, mail and online platforms (such as social media);
• to facilitate and support customer service and reservations, carry out your request, provide services, or respond to any enquiries, complaints or feedback given by you or on your behalf;
• to manage our internal administrative and business operations and comply with internal policies and procedures;
• to conduct market research and enhance our customer service;
• to provide training to our staff;
• to facilitate your access to our website;
• to manage the safety and security of our premises;
• for our auditing, internal investigations, compliance, risk management, conflict of interest reporting and security processes;
• to comply with applicable laws, regulations, rules, codes of practice, guidelines and other requirements (including but not limited to providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies);
• to prevent, detect and investigate crime;
• to analyse and manage commercial risks;
• for the purposes of legal proceedings;
• to defend or extend any rights of RE&S;
• to administer and process your employment application;
• to administer and maintain shareholder relations;
• to verify your identity;
• for any evaluative purpose as defined in the Personal Data Protection Act;
• for any other purposes that we have specifically notified you of; or
• for any other purposes that a reasonable person would consider appropriate in the circumstances.
5 Who We Disclose Your Personal Data To
We disclose some of the personal data you provide us to the following entities or organisations outside RE&S in order to fulfil our services to you:
• our agents, contractors, sub-contractors, service providers or data processors who have been contracted to provide administrative, financial, legal, accounting, IT, research, operational, marketing, communications, transportation, payment, analytics, training, storage, printing, security or other services;
• our consultants and professional advisers (such as accountants, lawyers, auditors);
• our business partners and affiliates;
• external banks, credit card companies and their respective service providers;
• courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as required or authorised by law;
• 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, subsidiaries or business units in RE&S; or
• any other party to whom you authorise us to disclose your personal data to.
Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.
6 How We Manage the Collection, Use and Disclosure of Your Personal Data
6.1 Obtaining Consent
Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us using our job application forms.
We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to RE&S are included):
• The personal data is publicly available
• The personal data is disclosed by a public agency or disclosed to a public agency
• The personal data is necessary for any investigation or proceedings
• The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)
• The personal data is necessary for the purpose of managing or terminating an employment relationship
• The personal data is necessary for a business asset transaction
6.2 Withdrawal of Consent
If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us.
Your request for withdrawal of consent can take the form of an email or letter to us, or through the "UNSUB" feature in an online service.
We use "cookies" to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.
Most cookies we use are "session cookies", which will be deleted automatically from the hard disk of your computer at the end of the session.
You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.
6.4 Third-Party Consent
If you do a transaction with us on behalf of another individual that will require you to provide that individual's personal data to us, you must ensure that this individual has given his/her expressed consent to provide his/her personal data to us through you. We will require you to get a written confirmation from this individual that he/she has indeed given his/her expressed consent to you for us to collect, use or disclose his/her personal data.
7 How We Ensure the Accuracy of Your Personal Data
We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.
From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).
8 How We Protect Your Personal Data
We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks.
We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a 'need to know' basis.
When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.
9 How We Retain Your Personal Data
We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.
We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.
10 How You Can Access and Make Correction to Your Personal Data
You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.
If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.
11 Transfer of Personal Data
Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore's PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.
12 Changes to this Data Protection Notice
We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.
Changes to this Notice take effect when they are posted on our website.
13 Contact Us
Any query or complaint should include, at least, the following details:
• Your full name and contact information
• Brief description of your query or complaint
We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.