Data Protection Policy

The purpose of this document (“Data Protection Policy”) is to inform you of how Banyan Tree Holdings Limited and its related corporations (collectively, the "Companies") manages Personal Data (as defined below) 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 the Companies, as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "Banyan Tree", "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 Banyan Tree 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.

Banyan Tree 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 http://www.lagunaproperty.com/privacy-policy.  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 any form, including but not limited to application and registration forms;

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, 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 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 seek information 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

k. 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, Banyan Tree 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. sending you our monthly eNewsletters if you have subscribed to our mailing list;

d. managing the administrative and business operations of Banyan Tree and complying with internal policies and procedures;

e. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

f. 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;

g. matching any Personal Data held which relates to you for any of the purposes listed herein;

h. preventing, detecting and investigating crime and analysing and managing commercial risks;

i. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

j. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

k. 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;

l. managing and preparing reports on incidents and accidents;

m. conducting investigations relating to disputes, billing or fraud;

n. 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 Banyan Tree (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or

o. purposes which are reasonably related to the aforesaid.

3.2 In addition, Banyan Tree 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, a member of the Laguna Holiday Club, the Banyan Tree Private Collection or other similar clubs, or a guest to events organised at our hotel or by us:

(i)     providing customer service and support (including but not limited to customer relationship management, processing and confirming your reservations, managing your events, arranging for transportation, processing your payments and attending to your requests for any other goods and services whether or not offered by Banyan Tree);

(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)    managing our lost-and-found services;

(vi)   administering rewards and benefits;

(vii)  facilitating and organising events;

(viii) processing waiver forms; and/or

(ix)   purposes which are reasonably related to the aforesaid.

b. If you are a guest at our spas, golfing ranges, or restaurants, or a customer of our tour services or the Banyan Tree Gallery;

(i)     providing customer service and support (including but not limited to  customer relationship management, processing and confirming your reservations, bookings and other orders, processing membership applications, and processing your payments);

(ii)    creating and maintaining guest profiles in our system database;

(iii)   administering debt recovery and debt management;

(iv)   administering rewards and benefits; and/or

(v)    purposes which are reasonably related to the aforesaid.

c. If you are an investor or a limited partner in one of our real estate funds:

(i)     providing and administering the funds;

(ii)    managing our sales exhibitions;

(iii)   maintaining communications and our relationship with you; and/or

(iv)   purposes which are reasonably related to the aforesaid.

d. If you are the owner or tenant of one of our properties (including but not limited to Angsana Residences, Banyan Tree Residences, Cassia Residences or Laguna Property):

(i)     facilitating the sale or lease of our properties;

(ii)    providing customer service and support (including but not limited to maintaining the properties and processing your payments); and/or

(iii)   maintaining our database;

(iv)   maintaining communications and our relationship with you;

(v)    purposes which are reasonably related to the aforesaid.

e. 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.

f. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Banyan Tree:

(i)     assessing your suitability as an external service provider or vendor for Banyan Tree;

(ii)    managing project tenders and quotations, processing orders or managing the supply of goods and services;

(iii)   processing and payment of vendor invoices and bills;

(iv)   managing credit facilities applications;

(v)    managing business operations and product development;

(vi)   maintaining communications and our relationship with you;

(vii)  facilities management (including but not limited to maintaining the security of our premises); and/or

(viii) purposes which are reasonably related to the aforesaid.

g. If you submit an application to us as a candidate for employment or representative position:

(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); and/or

(vi)   purposes which are reasonably related to the aforesaid.

h. If you are an existing employee or associate of Banyan Tree:

(i)     conducting background screening;

(ii)    providing remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring awards;