The purpose of this document (“Data Protection Policy”) is to inform you of how Laguna Banyan Tree Limited (LBTL) 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 "LBTL", "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 LBTL. 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.
LBTL 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://sanctuaryclub.com/en/privacypolicy. Please check back regularly for updated information on the handling of your 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.
2.1 Generally, we collect Personal Data in the following ways:
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.
3.1 Generally, LBTL collects, uses and discloses your Personal Data for the following purposes:
3.2 In addition, LBTL 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 Angsana Vacation 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);
(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, Dhawa 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;
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 LBTL
(i) assessing your suitability as an external service provider or vendor for LBTL;
(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 LBTL
(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;
(iii) administrative and support processes relating to your employment, including its management and termination, as well as staff benefits, including manpower, business continuity and logistics management or support, processing expense claims, medical insurance applications, leave administration, training, learning and talent development, managing provident funds, bank loans and visa applications, and planning and organising corporate events;
(iv) providing you with tools and/or facilities to enable or facilitate the performance of your duties;
(v) compiling and publishing internal directories and emergency contact lists for business continuity;
(vi) facilitating overseas travel arrangements (including but not limited to setting up travel accounts);
(vii) conducting internal or external audits;
(viii) facilities management (including but not limited to maintaining the security of our premises, maintaining proper key access control and recording entries and exists);
(ix) 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;
(x) ensuring that the administrative and business operations of LBTL function in a secure, efficient and effective manner (including but not limited to providing internal communications and maintenance);
(xi) administering cessation processes; and/or
(xii) purposes which are reasonably related to the aforesaid.
i. If you are a shareholder, authorised bank signatory of LBTL or sit on the Board of Directors of LBTL:
(i) onboarding or facilitating your appointment;
(ii) maintaining statutory registers and to manage the publication of shareholder or director statistics on annual reports and circulars; and/or
(iii) purposes which are reasonably related to the aforesaid.
j. If you are a contributor or donor to the Banyan Tree Global Foundation:
(i) managing our corporate social responsibility projects;
(ii) inviting you to attend our dialogue and distinguished lecture sessions;
3.3 Furthermore, where permitted under the Act, LBTL may also collect, use and disclose your Personal Data for the following “Banyan Tree Additional Purposes”:
3.4 If you have provided your Thailand/Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Thailand/Singapore telephone number(s), then from time to time, LBTL may contact you using such Thailand/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 LBTL.
4.1 LBTL 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 Thailand:
5.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operatingsystem a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
5.2 Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic 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.
5.3 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.
6.1 LBTL 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 or use our mobile services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. 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.
7.1 If you:
Call: +65 6849 5742
Write to our Data Protection Officer at:
Risk Management / Data Protection Officer
211 Upper Bukit Timah Road
Call: +66 76 362 333
Write to our Data Protection Officer at:
390/1 Moo 1, Srisoonthorn road, Cherngtalay, Thalang, Phuket 83110 Thailand
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 such party directly to make any queries, feedback, complaints, and access and correction requests to LBTL 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, LBTL 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 LBTL, and your being in breach of your contractual obligations or undertakings. LBTL’s legal rights and remedies in such event are expressly reserved.
8.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore/Thailand.
What measures are taken to protect my personal data?
How can I exercise my rights under GDPR?