The purpose of this document (“Data Protection Policy”) is to inform you of how Beachside residence 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 “Beachside Residence”, “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 Beachside Residence in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use, or disclose your Personal Data.

Beachside Residence 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. Please check back regularly for updated information on the handling of your Personal Data.

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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:

• when you submit any form, including but not limited to application and registration forms;
• 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;
• 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;
• when you use our electronic services, or interact with us via our websites or use services on our websites;
• when you request that we contact you or request that you be included in an email or other mailing list;
• when you respond to our promotions, initiatives, or to any request for additional Personal Data;
• 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;
• 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;
• when you are contacted by, and respond to, our marketing representatives and customer service officers;
• 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
• 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, Beachside Residence collects, uses, and discloses your Personal Data for the following purposes:

• responding to your queries, feedback, complaints, and requests;
• verifying your identity;
• sending you our monthly eNewsletters if you have subscribed to our mailing list;
• managing the administrative and business operations of Beachside Residence and complying with internal policies and procedures;
• facilitating business asset transactions (which may extend to any mergers, acquisitions, or asset sales) involving any of the Companies;
• 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 behavior, preferences, and market trends, and to review, develop and improve the quality of our products and services;
• matching any Personal Data held which relates to you for any of the purposes listed herein;
• preventing, detecting, and investigating crime and analysing and managing commercial risks;
• managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
• monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training, and performance evaluation and identity verification purposes;
• 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;
• managing and preparing reports on incidents and accidents;
• conducting investigations relating to disputes, billing, or fraud;
• 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 Beachside Residence (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence, and investigations); and/or
• purposes which are reasonably related to the aforesaid.

Sections for specific purposes for different user types (such as hotel guests, spa guests, investors, etc.) and Additional Purposes have been adjusted to refer to “Beachside Residence” in place of “Banyan Group.”

4. Disclosure of Personal Data

4.1 Beachside Residence 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 Singapore:

any other party to whom you authorise us to disclose your Personal Data to.

Beachside Residence’s related corporations;

companies providing services relating to medical screening, insurance and consultancy to Beachside Residence;

agents, contractors, or third-party service providers who provide operational services to Beachside Residence, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, employee recognition, or other services to Beachside Residence;

vendors or third-party service providers in connection with marketing promotions and services offered by Beachside Residence;

our partners in the tourism industry and other hospitality counterparts;

any business partner, investor, assignee, or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale) involving any of the Companies;

external food and beverages establishments;

airline companies and travel agents;

external banks, credit card companies, secretarial agents, and their respective service providers;

our professional advisers such as consultants, auditors, and lawyers;

foreign embassies in relation to facilitating overseas travel arrangements;

relevant government ministries, regulators, statutory boards or authorities, or law enforcement agencies to comply with any laws, rules, guidelines, and regulations or schemes imposed by any governmental authority; and

5. Use of Cookies

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 operating system 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. Data Security

6.1 Beachside Residence 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. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

7.1 If you:

a. have any questions or feedback relating to your Personal Data or our Data Protection Policy;

b. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

c. would like to obtain access and make corrections to your Personal Data records, you can approach us via the following channels:

Call: +65 6849 5988

Email: data-privacy@groupbeachside.com

Write to our Data Protection Officer at:

Data Protection Officer

211 Upper Bukit Timah Road

Singapore 588182

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 Beachside Residence 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, Beachside Residence 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 Beachside Residence, and your being in breach of your contractual obligations or undertakings. Beachside Residence’s legal rights and remedies in such event are expressly reserved.

8. Governing Law

8.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

GDPR Addendum

Please also refer to the GDPR Addendum.

Data Privacy External FAQ

1. Where is my personal data stored?

All data is securely stored in Payment Card Industry Data Security Standard certified (PCI DSS) data centers provided by industry leaders Oracle, Sabre, and TravelClick.

2. What types of information are collected?

a. These may include, but are not limited to, names, contact information, payment information, date of birth, and preferences.

b. We may also receive data from external parties which our guests may use, e.g., Expedia.com, Booking.com, or the like.

3. How is this information used?

a. Beachside Residence collects personal information of our guests in order to carry out our obligation to fulfil their stay at our hotels, and provide a high level of service accordingly.

b. We may also use this information with their consent for marketing activities to provide news of our hotels and activities.

c. We may also use this information to communicate with the guest, from time to time via email, phone, or text to respond to their queries, service follow-ups, or to improve our services.

d. We provide this data to our Third Party service provider to process on our behalf, to send out reservation related, and/or marketing material, and also validate the email address provided during the booking process. These providers are bound by confidentiality clauses and are not permitted to use the data for any other purposes.

e. We may share data with payment processing providers and/or financial institutions for fraud detection and prevention, and payment processing activities.

f. We only provide data to the relevant local law enforcement authorities as required by law for the prevention, detection, and prosecution of criminal acts as we are legally obliged to.

4. What measures are taken to protect my personal data?

a. Policies and practices are in place to ensure that data security is not compromised at any point of collection or processing of such data.

b. Personal data will only be used and retained for the purposes required/consented to and this has been communicated to all our staff on a regular basis.

c. A new Data Protection Statement has also been drafted and enacted internally to ensure our compliance with all relevant data protection rules.

5. How can I exercise my rights under GDPR?

a. If you have any queries, you can contact us at data.privacy@beachside.com for further assistance.

b. Visit us at https://www.beachside.com/privacy-policy for more information.

c. We will respond to your request as soon as possible, within one calendar month at the latest.