Privacy Policy
By accessing or using the Sites or Services in any manner, you agree to the terms and conditions in this Privacy Policy
1. Scope of Privacy Policy
This Privacy Policy applies to all individuals whose personal data is collected, used or processed by the company including, but not limited to:
- Our guests and other individuals who visit our properties, use our Services or Sites;
- contact persons and/or authorized representatives of our corporate clients, suppliers or vendors; and/or
- prospective clients, suppliers or vendors.
This Privacy policy is applied through the use of the KINN website, www.staywithkinn.com, and or any of our related sites, software and applications accessible on or by any domain owned by MGH (including any translations of the same, the “Site” or “Sites”). This Privacy Policy excludes services that state that they are offered under a different privacy policy.
Our Privacy Policy is applied globally unless there is a specific country privacy policy which applies to you or to the location where you are staying or visiting as a guest. Our data collection and processing practices may be more restrictive subject to local laws in certain jurisdictions our hotels and Services are located.
Our Privacy Policy does not apply to services offered by other companies or individuals, including other products or sites that may be displayed or linked to you such as our processing of your Personal Information on behalf of third parties such as companies that offer packaged travel arrangements.
Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
2. Types of Personal Information
The collection of Personal Information occurs when you register to use our Sites or Services by:
- Making a booking reservation, purchase or other transaction
- Using our WiFi
- Filling out a survey about your guest experience
- Entering a contest or promotion
- Requesting for customer support through “Contact Us” or similar features on our Site or Services
- Reporting a problem or question about our Services
Under such circumstances, we may collect your name, organization, phone number, or email address, and in some instances, you may elect to provide us with location and address information.
If you stay at one of our properties, we may collect:
- Your name, contact details and demographic information;
- Your financial and billing information;
- Information about your travel details, your preferences and history relating to your reservation;
- Information collected through the closed circuit television system, internet systems, smart or mobile device, card key and other security and technology systems, used in connection with, for example, responding to emergencies and incidents.
If you or your organization plan an event or meeting at one our facilities, we may collect:
- Personal Information related to the event or meeting
- Guest list and information about the guests at your event
If you use and interact with our Sites or Services (including email), we may collect:
- Information about your device and your usage of our websites or emails
In some instances, you may provide to us Sensitive Personal Information. Defined by privacy laws in some countries as personal information from which we can determine or infer an individual’s:
- Racial or ethnic origin and religious beliefs
- Political opinions, trade union membership or professional association
- Physical or mental health condition
- Medical treatment, genetic data and biometric information
- Information about an individual’s sexual life or sexual orientation
We only process Sensitive Personal Information in your jurisdiction to the extent permitted by applicable law. You are not required to provide MGH with any of your Sensitive Personal Information, and choosing not to do so will not prevent you from purchasing any Services from MGH.
We do not generally collect Sensitive Personal Information unless it is volunteered by you. For example, we may use health information provided by you to serve you better and meet your particular needs, such as for the provision of disability access.
If you provide us or our service providers with any Personal Information relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy.
3. Sources of Collection
We obtain the types of Personal Information listed above from the following sources:
- Directly from our guests or their agents. Such as from information that our guests provide to us in order to reserve a room at a hotel, or email messages we send out.
- Indirectly from our guests or their agents. Such as the information we collect while providing Services to them.
- Directly and indirectly from activity on our Sites and Services. Such as website usage details as described in this Privacy Policy.
- From social media websites, such as Facebook, LinkedIn, and Instagram.
- From third parties that assist us in providing certain transactions and services, even though it appears that you may not have left our Site, such as reservations, online travel agencies, payment processing, and hosting.
We collect information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google and similar partners.
The technologies we use for this automatic data collection may include, but not limited to, the following. It might not be implemented concurrently at any point in time when you are accessing our Sites or Services:
- Clickstream Data is information collected by our computers when you request webpages from the Sites. It may include information such as:
- the page served;
- the time spent viewing the page;
- the source of the request;
- the type of browser making the request;
- the preceding page viewed and similar information.
Clickstream data permits us to analyse, for example, how visitors arrive at the Sites, what type of content is popular, and what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
Location-Based Services is the location of the device used to access the Site or Services, for example by using WiFi signals or other technologies.
This information will be collected only if you consent to enable location-based capabilities on your device. You can decide at any time not to share your location, or to limit when your location is collected, by choosing the applicable setting on your device.
4. Purpose and Use of Personal Information
We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Site and Services, including analysis of activity.
- To inform you about Services and products available from MGH or that may otherwise be of interest to you.
- To fulfil the services, reservations, purchases and other transactions that you (or, if applicable, anyone involved in the process of making your travel arrangements) request from us.
- To authorize access to our Sites and Services.
- To validate your identity or verify communications from you.
- To offer and administer programs.
- To customize or tailor your experience of the Services.
- To manage, store and enhance guest data and preferences.
- To communicate and administer your participation in special programs, surveys, contests, prize draws and other offers or promotions, and to deliver pertinent emails.
- To send you administrative messages and facilitate your use of, and our operation of, the Services.
- For marketing purposes, including but not limited to, facilitating interest-based advertising, creating traveller profiles, creating custom audiences for targeted advertising, sending integrated marketing messages across channels and devices and personalizing email marketing that we send to you.
- To facilitate social sharing functionality.
- To improve our customer service, conduct customer satisfaction, market research, and quality assurance reviews.
- To respond to and support Users regarding their use of the Sites and Services.
- To process applications for employment that you submit through the Sites (or third-party sites).
- For our legitimate business purposes, such as data analysis, audits, operating and expanding our business activities.
- To administer general recordkeeping.
- To comply with all applicable legal requirements, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, or courts.
- To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our guests or visitors.
- Any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent, or for any other lawful purpose.
We and our service providers may use IP addresses to understand the locations from which our guests and visitors are accessing the Services. Except where prohibited by applicable law or regulation, we may combine information collected through one source with information obtained through other resources. We also may supplement the information we collect with information obtained from third parties. We will treat any information that we combine with your personal information as Personal Information pursuant to this Privacy Policy.
Whenever we collect Personal Information from you, we may do so on the following bases:
- Your consent to such collection and use
- Our legitimate business interest, including but not limited to the following circumstances:
- Intra-organization transfers for administrative purposes
- Product development and enhancement
- Fraud detection and prevention
- Enhancement of our cybersecurity including our network and information systems
- General business operations and diligence
- Compliance with legal obligations under applicable laws, rules or regulations, including
without limitation, to the order of governmental authorities or courts
5. Withdrawal of Consent
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Data Protection Policy, you may write to our Data Protection Officer at dpo@gaiaco.ltd.
Please note that withdrawing consent for purposes necessary for us to fulfil our contractual obligations or providing our services to you may affect our ability to proceed with certain transactions or interactions. Upon receiving your withdrawal request, we will review and inform you of any potential consequences and provide you a Consent Withdrawal Form for your completion prior to processing your request.
Withdrawal of consent does not affect our right to continue to collect, use and disclose personal data pursuant to an exception under the PDPA or as required/authorised under any other written law.
6. How we Protect your Personal Information
MGH maintains commercially reasonable technical and organizational safeguards designed to protect the User’s Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Information or any other information you disclose or transmit to us.
We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.
For your own privacy protection, we urge you to keep all passwords confidential. We also recommend that you do not include sensitive information such as passwords, social security numbers or payment information, in any emails that you send to us
7. Disclosure of Personal Information to Third Parties
We may disclose your Personal Information for a business purpose to the following categories of third parties:
- Related companies of MGH Hospitality Pte. Ltd., both within and outside of your jurisdiction
- Our business partners, agents, vendors and service providers who we work with as part of our business model, including but not limited to merchant partners, payment service providers and other third party service providers such as:
- Strategic business partners who provide goods, services and offers that enhance your experience at our properties, or that we believe will be of interest to you.
- Service providers and other third parties we use to support our business, including without limitation those performing core services related to the operation of our business and/or the Services.
- Any actual or prospective partner or counterparty to corporate or financing activities (such as but not limited to investors, acquirers, joint venture partners, assignees or transferees, investor, acquirer, joint venture partner or finance provider) for the purposes of facilitating such transaction.
- Owners and franchisees of properties operating under our family of trademarks and brands.
- New owners and/or managers of a hotel or other property previously operated under our family of trademarks and brands following a change in management or ownership of the hotel or other property.
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of MGH, including legal advisors, consultants, insurers and insurance brokers, governmental authorities, arbitration institutions and courts if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Fulfil any purpose for which you provide it as described in this Privacy Policy.
- Meet any applicable law, regulation, legal process or enforceable governmental request.
- Enforce applicable Terms of Use, including investigation of potential violations.
- Detect, prevent, or otherwise address fraud, security or technical issues.
- Protect against harm to the rights, property, assets or safety of The Standard, our guests or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law.
- Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of The Standard’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by The Standard about its guests and users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy.
- For any other purpose disclosed when you provide the information and when we obtain your consent to do so.
We attempt to notify visitors and guests about legal demands for their Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we have no obligation to do so.
To the extent possible, we encrypt, anonymize and aggregate all personal data before sharing it with third parties. This means that we will endeavor to strip all identifying features from all personal data prior to sharing it and present such information in aggregated form rather than individually.
8. Data Breach Notification
9. Storing and Retaining Personal Information
We have centralized some of our data processing activities and, as a result, we may, directly or indirectly through our organization and affiliates, and through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy and in accordance with applicable data privacy laws.
Specifically, such information may be transferred to, and stored at, a location outside of your jurisdiction, such as Singapore or the location of the hotel where you are staying. The jurisdiction where your Personal Information will be processed may or may not have laws that seek to preserve the privacy of Personal Information. Your Personal Information may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy.
By submitting your Personal Information using the Sites or Services, you understand and agree to this transfer, storing or processing.
We use and retain your Personal Information for as long as necessary to fulfil the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
10. Your Rights under Singapore Data Protection Laws
The PDPA accords rights to Singaporean citizens and residents which we are committed to respecting and upholding. Your rights under the PDPA which are supplemented by our own internal policy include:
- the right to consent to collection, use, or disclosure of personal data by the organization;
- the right to request access to and correct your own personal data;
- the right to complete and accurate data collection;
- the right to be informed on the purposes for collection, use, or disclosure of personal data, which must be for reasonable and appropriate purposes;
- the right to have personal data protected by reasonable security arrangements;
- the right to have personal data collection ceased immediately as soon as there is an assumption that the purpose for collecting the personal data is no longer being served by keeping it; and
- the right to withdraw consent for us to process your personal data.
You may exercise these rights by sending in a request by email to dpo@gaiaco.ltd. Please provide sufficient details allowing us to identify you, as well as the scope and nature of your request. We will respond to you within thirty (30) business days from your request. We will not a charge a fee for responding to your request (as long as it is not unfounded, vexatious, repetitive or excessive).
11. Review and Changes to Privacy Policy
12. Governing Law
This Personal Data Protection Policy and your use of this website shall be governed by Singapore law. To the extent the applicable law is one other than the law of the Republic of Singapore, you agree to waive all rights and remedies to the extent such rights and remedies would not have been available had this Personal Data Protection Policy and your use of this website been governed solely by Singapore law.
This policy is effective and last updated from 18 Oct 2021.
13. How to Contact Us
We welcome your views about our website and our privacy policy. If you have any questions about this privacy policy or any concerns regarding how we manage your personal data, you may contact our Data Protection Officer (DPO) at dpo@gaiaco.ltd.
