1 July 2014

The purpose of this document (“Data Protection Policy”) is to inform you of how Shangri-La Hotel Limited manages Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to Shangri-La Hotel Limited (including its related corporations) (collectively, the “Companies“), as well as their respective representatives and/or agents (“Representatives“) (the Companies and Representatives collectively referred to herein as “Shangri-La“, “us“, “we” or “our“) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy. 

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to Shangri-La in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.

Shangri-La may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website. Please check back regularly for updated information on the handling of your Personal Data.


1. Personal Data

1.1 In this Data Protection Policy, “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 other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.


2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

(a) when you submit an application, registration form, or other forms relating to any of our 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 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, or interact with us via our websites or use services on our websites;
(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 casual labour application or when you provide documents or information including your resume and/or CVs 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 via photographs or videos taken by us or our representatives when you attend events at our premises;
(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, or when you have made bookings at our hotel through them;
(k) when we seek information from third parties about you in connection with the products and services you have applied for; and/or
(l) when you submit your Personal Data to us for any other reason.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data unless you provide such information or login with your account credentials.

2.3 If you provide us with any Personal Data relating to a third party (e.g. information of 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 for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.


3. Purposes for the Collection, Use and Disclosure of Your Personal Data 

3.1 Generally, Shangri-La collects, uses and discloses your Personal Data for the following purposes:
(a) responding to your queries, feedback, complaints and requests;
(b) verifying your identity;
(c) managing the administrative and business operations of Shangri-La and complying with internal policies and procedures;
(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies
(e) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
(f) matching any Personal Data held which relates to you for any of the purposes listed herein;
(g) preventing, detecting and investigating crime and analysing and managing commercial risks;
(h) managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(i) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(j) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(k) managing and preparing reports on incidents and accidents;
(l) conducting investigations relating to disputes, billing or fraud;
(m) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Shangri-La (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
(n) purposes which are reasonably related to the aforesaid.

3.2 In addition, Shangri-La collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
(a) If you are a guest at our hotel, or a guest to events organised at our hotel:
(i) providing customer service and support (including but not limited to customer relationship management, processing your reservations, managing your events, processing of payments and attending to your requests for any other goods and services whether or not offered by Shangri-La);
(ii) creating and maintaining guest profiles in our system database;
(iii) corresponding with travel agents on your behalf;
(iv) administering debt recovery and debt management;
(v) administering rewards and benefits; and/or
(vi) purposes which are reasonably related to the aforesaid.
(b) If you are a customer or guest at our spa, health club or restaurants;
(i) providing customer service and support (including but not limited to customer relationship management, processing reservations and membership applications, managing your events and processing of payments);
(ii) creating and maintaining guest profiles in our spa and health club system database;
(iii) indemnifying the hotel from liability related to your use of the health club or consumption of restaurant food outside the restaurant;
(iv) administering debt recovery and debt management;
(v) administering rewards and benefits; and/or
(vi) purposes which are reasonably related to the aforesaid.
(c) If you are a visitor to our premises:
(i) facilities management (including but not limited to issuing visitor access passes, and recording entries to and exits from our premises); and/or
(ii) purposes which are reasonably related to the aforesaid.
(d) If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Shangri-La:
(i) managing project tenders and quotations, processing orders or managing the supply of goods and services;
(ii) processing and payment of vendor invoices and bills;
(iii) managing business operations and product development;
(iv) maintaining internal communications;
(v) facilities management (including but not limited to maintaining the security of our premises); and/or
(vi) purposes which are reasonably related to the aforesaid.
(e) If you submit an application to us as a candidate for employment (including for freelance or casual labour employment):
(i) conducting interviews;
(ii) processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
(iii) obtaining employee references and for background screening;
(iv) assessing your suitability for the position applied for;
(v) facilities management (including but not limited to maintaining the security of our premises and recording entries and exists);
(vi) generating and disseminating reports (including but not limited to budgeting, surveys and requests); and/or
(vii) any other purposes relating to any of the above.
(f) If you are an existing employee, freelance personnel, or casual labour of Shangri-La:
(i) conducting background screening;
(ii) administering compensation and benefits (including but not limited to staff insurance, medical schemes, and long-service incentives);
(iii) processing and issuing new staff uniforms;
(iv) providing remuneration and reviewing salary and bonuses;
(v) facilitating onboarding processes (including but not limited to creating system access profiles, processing work permits and medical screening);
(vi) business continuity, manpower and logistical management (including but not limited to providing IT and administrative support, emergency contact planning, employee mobility management and leave management);
(vii) facilitating the execution of business operations;
(viii) training, learning and talent development;
(ix) conducting evaluation, career planning and staff appraisals;
(x) nominating and processing staff awards for exceptional performance;
(xi) facilitating local transport arrangements and overseas travel arrangements;
(xii) conducting internal or external audits;
(xiii) facilities management (including but not limited to maintaining the security of our premises, maintaining proper key access control and recording entries and exists);
(xiv) generating and disseminating reports (including but not limited to budgeting, surveys and requests);
(xv) conducting analytics, surveys and research for human resource planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;
(xvi) ensuring that the administrative and business operations of Shangri-La function in a secure, efficient and effective manner (including but not limited to providing internal staff contact databases, providing internal communications and maintenance);
(xvii) administering cessation processes; and/or
(xviii) any other purposes relating to any of the above.
(g) If you are a member of our loyalty clubs (including but not limited to Shang Rewards, eClub or WorldBonus):
(i) creating and maintaining member profiles in our system database for future reference;
(ii) providing membership service and support, including but not limited to tracking members’ reward points and processing membership reward redemptions; and/or
(iii) any other purposes relating to any of the above.

3.3 Furthermore, where permitted under the Act, Shangri-La may also collect, use and disclose your Personal Data for the following “Shangri-La Additional Purposes”:
(a) providing or marketing additional products, services and benefits to you, including but not limited to special events, promotions, loyalty and reward programmes from Shangri-La;
(b) matching Personal Data with other data collected for other purposes and from other sources (including but not limited to third parties) in connection with the provision, marketing or offering of products and services by Shangri-La;
(c) leads generation and management for marketing Shangri-La’s products and services;
(d) administering and organising contests, lucky draws, promotional events, competitions and marketing campaigns, and personalising your experience at Shangri-La’s touchpoints;
(e) communicating to you advertisements involving details of our products and services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);
(f) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
(g) purposes which are reasonably related to the aforesaid.

3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Shangri-La may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

3.5 In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.6 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.

3.7 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you have requested from Shangri-La.


4. Disclosure of Personal Data 

4.1 Shangri-La will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) Shangri-La’s related corporations (including but not limited to Shangri-La’s headquarters in Hong Kong and Traders’ / Kerry hotels);
(b) companies providing services relating to medical screening, insurance and consultancy to Shangri-La;
(c) agents, contractors or third party service providers who provide operational services to Shangri-La, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, employee recognition or other services to Shangri-La;
(d) vendors or third party service providers in connection with marketing promotions and services offered by Shangri-La;
(e) our partners in the tourism industry, including but not limited to the Singapore Hotel Association, Singapore Tourism Board, Sentosa Development Corporation, and other hospitality counterparts;
(f) 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;
(g) external banks, credit card companies and their respective service providers;
(h) our professional advisers such as consultants, auditors and lawyers;
(i) foreign embassies in relation to facilitating overseas travel arrangements;
(j) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(k) any other party to whom you authorise us to disclose your Personal Data to.


5. Use of Cookies 

5.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites and allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electric device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

5.2 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 enter certain part(s) of our website.


6. Data Security

6.1 Shangri-La 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.

6.2 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 when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

6.3 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, on unauthorised and/or fraudulent use of your username and password.


7. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

7.1 If you:
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access and make corrections to your Personal Data records,
please contact Shangri-La as follows:
• Call: +65 6213 4985
• Email: devendra.pandey@shangri-la.com
• Write to our Data Protection Officer at:
Devendra Pandey, Area IT Manager
Shangri-La Hotel, Singapore, Orange Grove Road, Singapore 258350

7.2 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 Shangri-La on your behalf.

7.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Shangri-La 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 Shangri-La, and your being in breach of your contractual obligations or undertakings. Shangri-La’s legal rights and remedies in such event are expressly reserved.


8. Governing Law
8.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.