Privacy Policy

We at MGH Hospitality Pte Ltd (“MGH”), via the operations of our brand KINN Capsule Hotel and all related businesses and services (“KINN”), are committed to meeting our data protection obligations and ensuring that any personal information we collect is collected and stored in accordance with generally applicable data protection laws and best practices.

This Privacy Policy applies to data collection and privacy practices of MGH and when we collect personal information through your use of the KINN website, www.staywithkinn.com, and any of our other related sites, software and applications accessible on or by any domain owned by MGH (including any translations of the same, the “Site” or “Sites”), through our social media pages or mobile applications that we control, through email messages that we may send to you, and when you visit or stay as a guest at one of our properties or purchase related services (collectively, the “Services”). Please note that this Privacy Policy excludes services that state that they are offered under a different privacy policy.

Please familiarize yourself with our privacy practices. As one of our guests or as a visitor using the Sites or Services, you understand and agree that we collect, use and disclose your personal information in accordance with this Privacy Policy and applicable data privacy laws. By accessing or using the Sites or Services in any manner, you agree to the terms and conditions in this Privacy Policy.

MGH is an organization as defined by the Personal Data Protection Act (PDPA) and our registered office address is at 138 Robinson Road, #05-03 Oxley Tower, Singapore 068906.

When will the Privacy Policy apply?

Our Privacy Policy applies to all of the Services offered by MGH to our guests and other individuals who visit our properties, use our Services or use our Sites, including contact persons and/or authorized representatives of our corporate clients, suppliers or vendors and/or prospective clients, suppliers or vendors. Our Privacy Policy is intended to describe our data collection practices globally and applies 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. However, because the data protection and privacy laws in some jurisdictions where our hotels and Services are located may restrict our data collection and processing practices, our practices may be more restrictive subject to local laws.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Sites or Services. For example, this Privacy Policy does not apply to 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.

What types of Personal Information will be collected?

The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:

If you express an interest in obtaining additional information about our Services, request customer support, use the “Contact Us” or similar features on our Site or Services, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information as specified at the time, including 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 voluntarily submit certain information in connection with the use of the Sites or other Services, such as making a booking reservation, purchase or other transaction, using our WiFi, filling out a survey about your guest experience or entering a contest or promotion, we collect the information you have provided as part of such Services;
If you report a problem or have a question about our Services, you may provide us with contact information, such as a phone number or email address;
If you stay at one our properties, we may collect:
- Your name, contact details and demographic information (for example, gender or age);
- Your financial and billing information, such as credit card details;
- Information about your travel details, preferences and history, or relating to your reservation, for example your arrival and departure information, special requests, vehicles brought onto the property, concierge, health club, spa, room delivery and other services;
- Information collected through the use of a 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 plans an event or meeting at one our facilities, we may collect Personal Information related to the event or meeting such as the guest list and information about the guests at your event;
If you use and interact with our Sites or Services (including email), we may automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information under applicable law; and
In some instances, you may provide to us Sensitive Personal Information. We use the term “Sensitive Personal Information” as defined by the privacy laws in some countries, which means personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership or professional association, physical or mental health condition, medical treatment, genetic data, biometric information, and 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.

How do we collect your Personal Information?

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from our guests or their agents. For example, from information that our guests provide to us in order to reserve a room at a hotel.
Indirectly from our guests or their agents. For example, through information we collect from our clients in the course of providing Services to them.
Directly and indirectly from activity on our Sites and Services. For example, from website usage details that are collected as described in this Privacy Policy or by cookies (described below).
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, for example reservations, online travel agencies, payment processing, and hosting.

We and our partners use various technologies to collect and store information when you visit one of our Sites or Services, and this may include using cookies or similar technologies to identify your browser or device. We may also use these technologies to collect and store 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 the following. Please note that the list below is non-exhaustive, and might not be implemented concurrently at any point in time when you are accessing our Sites or Services:

Cookies: A cookie is a small text file stored directly on your device that a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the Site and to track usage behavior of, for example, the webpages you visit. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.
Web Beacons: Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data: Clickstream data is information collected by our computers when you request webpages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze, 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: We may collect 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.

How do we use the Personal Information we collect?

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 fulfill 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, including facilitating your requests to plan and purchase hotel accommodations or other travel services such as transportation and to reserve dining, lounge and spa services;
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 about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, prize draws and other offers or promotions, and to deliver pertinent emails;
To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Services;
For marketing purposes, including but not limited to, facilitating interest-based advertising, creating traveler profiles, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we send to you, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities that may be of interest 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; and
For 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.

We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by us. We may also use your information to manage our contractual relationship with you, to proceed with your request to entering into a contractual relationship with us, or to comply with our legal obligations.

To the extent we rely on consent for the processing of your Personal Information, we will seek such consent at the time we collect your Personal Information. We may also use the Personal Information we obtain about you in other ways for which we provide specific notice at the time of collection.

Why do we collect your Personal Information?

Whenever we collect Personal Information from you, we may do so on the following bases:

Your consent to such collection and use;
Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
- Intra-organization transfers for administrative purposes;
- Product development and enhancement, where the processing enables The Standard to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our visitors and guests, and to better understand how people interact with our Sites and Services;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence.
When we need to comply with our legal obligations under applicable laws, rules or regulations, including without limitation, to the order of governmental authorities or courts.

Sharing your information with 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. This includes, but is not limited to, merchant partners, payment service providers and other third party service providers such as:
1. 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
2. Service providers and other third parties we use to support our business, including without limitation those performing core services (such as reservations, billing, credit card processing, customer support services, customer relationship management, property management, accounting, auditing, processing insurance claims, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services
3. 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
4. Owners and franchisees of properties operating under our family of trademarks and brands
5. 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:

Fulfill 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.

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 and Personal 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. As described below in the section titled “How we protect your Personal Information”, we have put in place commercially reasonable technical and organizational procedures to safeguard the treatment of information and Personal Information, in accordance with applicable law.

We use and retain your Personal Information for as long as necessary to fulfill 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.

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. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.

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.

Your rights under Singapore data protection laws

We take our data protection obligations and your data privacy rights seriously. 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 hello@159.223.92.241. 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 two months of 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).

Data Breaches

In the event of a data breach, we will immediately work to identify the extent and cause of the breach and whether any personal data has been compromised. If we find that your personal data may have been compromised, we will immediately inform you so that you may take the necessary steps to protect yourself from potentially malicious actors.

Changes to this privacy notice

Any changes we may make to our privacy policy in the future will be posted on this page and published on our website. Please check back frequently to stay informed of any updates or changes to our privacy policy.

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 October 2021.