Millennium & Copthorne International Limited and its related entities and hotels in Singapore (“we”, “our”, “us”) are committed to protecting and respecting your privacy and personal data.
- Your Consent. Please read this Policy to understand how we may collect, use and disclose your personal data. By accessing this website or other M&C Websites, you hereby acknowledge that you have read this Policy and that you consent to the collection, use and disclosure of your personal data by us and in accordance with this Policy. If you do not consent to the terms of this Policy, please do not access this website or other M&C Websites in particular the following websites or provide any of your personal data:
- Information we may collect from you
We collect personal data that you provide when you access or use M&C Websites and we may collect and process the following data about you:
· Information you give us. At various places on M&C Websites, certain personal data may be requested. You may give us information about you by filling in forms on the relevant websites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use M&C Websites, subscribe to our services, search for a product, place a reservation or other order or enquiry on such websites, or participation in survey, discussions, social media functions or other activities as may be made available on M&C Websites and when you report a problem with these websites.
· Information we collect about you. We may collect information that is sent automatically by your web browser, computer, mobile or tablet device. Please check the settings of your browser and/or device if you want to know what information is automatically sent or if you wish to change your settings. Please also refer to the section on “Cookies” below. In this respect, we may automatically collect the following information:
· technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other information;
· information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from M&C Websites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
· Information we receive from other sources. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
First-party cookies are planted by the website which a user visits. This involves assigning a unique identity to the user by setting the cookie to either the user’s browser and/or hard drive with a view to tracking the user’s journey on the website. First-party cookies are commonly used by website operators for session management, personalisation and recognition purposes when you visit a website.
Third-party cookies are planted by parties other than the owner of the website a user visits. This may be for advertising or in order to allow an add-in to the website to function.
Session cookies are cookies that expire at the end of a browser session, that is when the user exits the browser. They allow websites to link the actions of users during a single browser session to allow them to use the website more efficiently, for example to enable a website to remember what items a user has placed in an online shopping basket.
Persistent cookies are stored on the user’s equipment between browsing sessions. They allow the website to recognise the user on his return which may be used to track the user’s preferences and to tailor services to them. Persistent cookies are considered more privacy intrusive than session cookies.
We use the following cookies:
· Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Uses made of information collected
- We, together with other Millennium & Copthorne Plc group companies which means our subsidiaries, our ultimate holding company and its subsidiaries, and our hotels (whether owned or managed or otherwise under the group) (collectively, “M&C Group”), will use information held about you so that we can provide our services and products including the ability to make and accept reservations for our worldwide portfolio of hotels (“M&C Hotels”) on-line, and for the following purposes:
· to communicate and provide products or services to you;
· to communicate with you;
· to improve our products or services;
· to advise you of other products and services, which may be of interest to you;
· to conduct marketing research, user profile and statistical analysis;
· to verify and process your personal particulars and payments;
· to process, record, execute, monitor, and/or archive your requests and transactions;
· to customise your online experience according to your chosen interests and preferences and enhance your current and future visits to M&C Websites;
· to update our records;
· to detect and protect us against error, fraud and other criminal activity;
· to comply with law, the requests of law enforcement and regulatory officials, or orders of court;
· to enforce our legal rights and remedies; or
· for such other purposes as may be notified to you on or before collection or use of the data or as you may have consented.
M&C Websites also allow you to communicate with us on issues of customer service and to provide feedback on services. We sometimes use this customer information to analyse customers' interests so that it can tailor programs and special offers to better address its customers' needs. You expressly consent to our contacting you by SMS, email, telephone, facsimile and/or by post, and to our processing of your data for the purposes set out in this section and including the following:
· Reservations and Pre-Arrival Information
To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us including to process a reservation for a M&C Hotel, we will ask for the customer's name, mailing address, billing address, electronic-mail information, telephone number, credit-card information, arrival and departure dates, and airline frequent-flier information or information on similar customer-loyalty programs. We also ask for the customer's room preferences and any special requests or needs.
· Customer Service
When customers make customer-service requests, we will ask for the customer's name, mailing address or electronic-mail information, telephone number and other information that will allow us to respond to the request or to resolve any problems at M&C Hotels. To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about
· Electronic Surveys and Post Stay Communications
We conduct online surveys, from time to time, to evaluate our services. Participation in such surveys is voluntary, but customer information is collected during such online surveys for verification purposes, such as name, mailing address, and electronic mail address.
M&C Group and M&C Hotels sometimes offer special promotions, contests, or sweepstakes through which customers can win prizes. Each of these promotions, contests and sweepstakes will have a set of terms and conditions that apply to that event. In some cases, the customer is automatically entered in the contest simply by using the relevant website or meeting some other condition for that contest. In entering such a promotion, contest, or sweepstake, the customer's name, electronic-mail address, or other personal information will be collected to identify the customer and for notification purposes.
· Millennium & Copthorne Loyalty Club
Enrolment on the Millennium & Copthorne Loyalty Club ("MCLC") is voluntary, and subject to a customer meeting the MCLC eligibility criteria. The information provided by a customer to MCLC for the purpose of registration may be accessed, reviewed and updated any time upon the successful application for membership. This can be done via the MCLC website (by logging in with the customer's confirmed membership number and password) and clicking on "Update my Profile".
Please note in some instances we may collect or be provided with personal data which is sensitive. This may include your:
· nationality, as recorded on your passport;
· membership of a political, professional or trade association, where this relates to groups with which you are associated for stays at hotels; and
· health information, where this relates to guest preferences, special requests or needs.
- Disclosure of your information
We may share and transfer your personal information with/ to and among any member of M&C Group, whether in or outside Singapore.
We and M&C Group may also share your information with selected third parties including:
· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
· Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in the eastern part of Singapore). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
· Analytics and search engine providers that assist us in the improvement and optimisation of our website.
· Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your personal information to third parties:
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
· If all or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We may also disclose your personal data to the individuals and entities listed below:
· any third party service provider which hosts or manages data from M&C Websites;
· any other agents, service providers, contractors or subcontractors acting for or on behalf of M&C Group; or
· government or regulatory authorities,
to the extent required in the normal course and scope of our business as a hospitality company, and where required or permitted by applicable law, statute, stock exchange regulation or by-law, regulatory or governmental order or court order.
The above disclosure may be conducted by us or via/ by another member of M&C Group.
- Where we store your personal data
Due to the global nature of our business it is likely that data we collect from you will be transferred, processed and stored in Singapore or at an overseas destination. This disclosure and transfer may be made to an entity within M&C Group, to franchisees, third party service providers and processed by staff located in a country outside of your own. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Your information will not be transferred to third parties outside Singapore except in accordance with the requirements prescribed under the Personal Data Protection Act 2012 (No. 26 of 2012) and its related subsidiary legislation (collectively, “PDPA”).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to M&C Websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Personal data provided by you will be retained as long as the purpose for which the data was collected continues or for reasons provided under the PDPA. Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect M&C Group’s interests.
- Third Party Websites
M&C Websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies, and you hereby waive any claim against us with respect to these linked websites. Please check all third party websites’ policies before you submit any personal data to these websites.
- Your rights
We will take reasonable steps to ensure the accuracy and completeness of any personal data held about you.
To the extent you have provided us with your consent, you have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, or by contacting us at the email address below.
You may request access to, or correction of your personal data that is in our possession or control. Additional privacy policies will be applicable in certain circumstances, for instance where you have agreed to our guest terms and conditions, where you have agreed to the MCLC terms and conditions, or where you have entered into another contract with us or any member of M&C Group.
To enable us to process your requests promptly you should provide us with full details of the particular information sought, and documentary evidence of your identity. You agree that we may need to check and verify your identify and may contact you for further information. You can contact us at any time in order to exercise these rights, to ask any questions related to the Policy or to let us know of any complaint you have relating to the Policy or our use of your data at by contacting us at the relevant contact entities below. Any access request may be subject to a fee and additional fees depending on the nature of your request to meet our costs in providing you with details of the information we hold about you and as permitted under the PDPA. If applicable, we will inform you of the applicable fees and payment must be usually received by us before we proceed further with your request.
Complaints, Feedback & Enquiries. Please direct any complaints, feedback or enquiries you may have regarding the collection, use and/or disclosure of your personal data by the following relevant entities in Singapore to their email or address below:
Studio M Hotel
No.3 Nanson Road, Singapore 238910
Attn: Data Protection Officer