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GROUP PRIVACY POLICY Effective Date: December 2020 ABOUT Bonvests Holdings Limited is an investment holding company engaged in the provision of management services to its subsidiaries. The Company’s businesses include property development and investment, hotel ownership and management, and waste management and contract cleaning. PRIVACY POLICY This Policy has been adopted by Bonvests Holdings Limited (“Bonvests”), and other organisations and business units related to Bonvests (including its subsidiaries) including the hospitality and commercial businesses and properties owned and operated globally by Bonvests Holdings Limited. In this Policy, “we”, “us” or “our” also collectively refers to Bonvests, or any business unit within the Bonvests Holdings Limited Group, as appropriate. At Bonvests, we respect your right to privacy and are committed to safeguarding your personal data. We make every attempt to ensure that all our business practices that involve the use of your information are compliant with the Singapore Personal Data Protection Act (Act 26 of 2012) (PDPA) and all other applicable privacy regulations in the countries where we operate including the European Union (EU) General Data Protection Regulation (GDPR) and, at all times only collect and process your personal information in accordance with applicable data protection laws. This Policy describes how we collect, use, disclose and process your personal data, and applies to personal data we collect about you. This Policy supplements but does not supersede or replace any other consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data. AMENDMENTS TO THIS POLICY We review and may amend this Policy from time to time to reflect changes in applicable laws or the way we handle personal data. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. You are encouraged to re-visit our Policy from time to time to keep yourself updated on these changes which can also be found at https://www.bonvests.com.sg/privacy-policy/ INFORMATION COLLECTED In order to for us to operate effectively and provide you with the best experiences with our products and services, we may request and collect information about you, whether as website visitors, tenants, hotel guests, dining patrons, loyalty programme members or you/your company contacting us for any purposes. Your personal information can come to us via various channels, including but not limited to:
Information Provided Voluntarily Full name/Contact (Email/Telephone/Address) Details/Passport/Visa Information Information Collected Automatically Information which includes your IP address, device type, unique device identification number, browser type, broad geographic location and other technical information may be collected from your device under applicable data protection laws. We use this information for our internal analytics purposes and improve the quality and relevance of our website. Log Information Information from business partners such as airlines, tour operators, travel agencies, reservations systems and third parties providing marketing and promotional services to us or from your family members or friends who provide your personal data to us on your behalf; with your valid consent to honour your reservation. Additionally, from your referees, educational institutions or previous employers (if you have applied to us for a job); And, from public agencies or other public sources otherwise legally permitted. ACCURACY & COMPLETENESS It is your responsibility to ensure that all personal data that you provide is accurate and complete, up to date and to inform us of relevant changes to your personal data. MINORS This site is not intended for children under the age of 18. Minors under 18 years of age must obtain consent from their parent or guardian before submitting any personal data to us. USE OF INFORMATION We will only collect, process and/or use your personal information for purposes connected or relevant to our business, or to manage your relationship with us, such as: – entering into or fulfilling a contractual obligation with you – processing your transactions (online reservations/bookings) with us, or to provide products and services to you; – administrative purposes, including finance, IT and HR purposes, quality assurance and staff training; – conducting market research and statistical analysis, customer satisfactions and quality assurance surveys, including development of new products and services or evaluation and improvement of our existing products and services; – facilitating business asset transactions; – replying to or taking actions in response to your requests, enquiries and feedback; – provide privileges, benefits and services to you, process applications for and administer membership programmes, verify and validate your ability to access and use certain services – communicating and providing marketing and promotion to you – information on special events/offers/promotions and any new services, news updates through direct marketing – security and safety purposes, in connection with the properties that we own or manage, or events organised by us or conducted at our properties; – compliance with laws and regulations, internal policies and procedures, including audit, accounting, risk management and record keeping; – enforcing legal obligations owed to us, or responding to complaints, litigation or investigations concerning us; – such purposes that may be informed to you when your personal data is collected; and/or – any other reasonable purposes related to the aforesaid. INFORMATION SHARING & TRANSFER We may also disclose your personal data for the purposes described above or as required or permitted by law, for example, to: – between and among our group entities; dedicated employees who have access to, and are associated with processing of personal information, are obliged to respect the confidentiality of the personal information – our business partners, third party vendors and service providers, who are engaged to provide business, support, operational and/ or administrative functions such as auditing, legal, marketing, payment, fulfilment and delivery of orders. – third parties that we conduct joint marketing and cross promotions with – regulatory authorities, statutory bodies or public agencies, including to support their investigations . Your Personal Information may be transferred to and processed in countries other than the country in which you are a resident or across multiple jurisdictions. These countries may have data protection laws that are different from the laws of your country. However, we have taken the appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice and any applicable laws. COOKIES You should be aware that information and data is automatically collected through the use of ‘cookies’. Cookies, which are small text files a web site can use to recognise repeat users, facilitate the user’s continuing access to and use of the site. They allow a site to track usage behaviour and compile data which will allow content improvements and targeted advertising. Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it. Most browsers are initially set to accept cookies, if you do not want to accept cookies you can modify the settings on your Internet browser to block them. Rejecting cookies however will affect your ability to benefit from the conveniences afforded by the use of cookies and you may not be able to use some of our services and customization features. DATA SECURITY & STORAGE Bonvests uses reasonable precautions to protect your personal data and store it securely. Using the most sophisticated encryption technology available and secured transmissions via private network, we have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. We retain your personal data only for the period necessary for the purposes set out in this Policy or in accordance to the provisions of applicable law. We take reasonable steps to safely and securely delete, dispose of, anonymise and/or block personal information when we no longer need it. Each business subsidiary too goes to great measures to ensure that all personal information is kept in a secure location and that only designated individual have access to this information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. DATA PROTECTION RIGHTS You have the right to request access to, correction of and/or deletion of your data at any time. If you do not want your personal data to be collected, used, and/or disclosed by us in the aforementioned manner, you may withdraw your consent by completing the appropriate form via mail or email to the contact details specified below. You have the right to Opt Out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you. CONTACT US If you have any questions or comments about this Privacy Policy, or you wish to access or update your personal information, please contact us at: Bonvests Holdings Limited Data Privacy Officer TERMS OF USE BONVESTS HOLDINGS LIMITED website: Thank you for visiting www.bonvests.com.sg, (hereinafter referred to as the ‘Bonvests Site’). The Content of www.bonvests.com.sg is prepared and/or authorised by Bonvests Holdings Limited (“Bonvests”) headquartered in Singapore Acceptance of Terms By accessing and/or using any part of the Bonvests Site and/or using any services provided via this Bonvests Site, you shall be deemed to have accepted to be legally bound by the terms and conditions set out herein (these “Terms of Use”). As a condition of your use of this Site, you warrant that you will not use the Site for any purpose that is unlawful, inappropriate, or prohibited by the terms of this agreement. Access to Website – Bonvests reserves all rights to deny or restrict access to this Bonvests Site to any person or block access from any internet source or address to this Bonvests Site at any time in its sole discretion and without providing any notice or reason. Bonvests reserves the right to modify, add, vary or amend all or part of these Terms of Use from time to time without prior notice to you. Your continued use of this Bonvests Site and any of the services provided herein after such changes are posted, shall be deemed an agreement by you to these Terms of Use as modified. Governing Laws & Jurisdiction – The user and Bonvests agree that all matters relating to and/or any disputes arising out of the user’s access to, or use of the Bonvests Site shall be governed by and interpreted and construed and enforced exclusively in accordance with the substantive domestic laws of the Republic of Singapore, without regard to the conflicts of law principles thereof. INTELLECTUAL PROPERTY RIGHTS The Content of the Bonvests Site is the copyright property of Bonvests Holdings Limited or its licensors. Copyright © Bonvests Holdings 2020. All rights reserved. All copyright and other intellectual property rights in all text, images, sound, software and other materials (herein referred to as Content) on this Bonvests Site are owned by Bonvests and affiliated companies or are included with permission of the relevant owners. References to affiliates or associates shall include all members of Bonvests Holdings Limited. All trademarks displayed on this site are owned by Bonvests. The name of Bonvests and its components of its logo and registered trademarks owned by the following company. You may not use any trademark or service mark appearing on this site without our prior written consent. Bonvests Holding Limited CONTENTS The information and material contained in this Bonvests Site are for general references only and does not in any case constitute a legally binding offer. The Content of this Bonvests Site is provided “as is” basis without warranty or any kind, either express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose, or non-infringement. While Bonvests shall use our best endeavours to verify that the Content of the Bonvests Site is accurate, complete and current, the information may contain technical inaccuracies or typographical errors, Bonvests reserves the right to make changes, corrections and and/or improvements to the information, and to the products and programmes described in such information, at any time without notice. You may browse this Bonvests Site to reproduce extracts from it, for your information and for non-commercial and personal purposes only. The Content of this Bonvests Site may not be modified or incorporated in any other work, publication or site without the express prior written consent of Bonvests is prohibited. Use of or visit to this Bonvests Site does not constitute an offer of goods and services by Bonvests. Goods and services may only be available in certain countries and any offer to purchase goods or to retain services from Bonvests are subject to acceptance by Bonvests and in accordance with specific terms and conditions on which they are offered. LINKED SITES The Bonvests Site may contain or make reference to trademarks patents, copyright technology products processes or other proprietary rights of Bonvests and/or other parties. The linking of third party websites to this Bonvests Site does not indicate any association with or endorsement by Bonvests. Bonvests does not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third party websites. These third party websites may have privacy practices that differ from those of Bonvests. If you submit personal data to any of those sites, your personal data is not subject to this privacy statement. By clicking on these links and leave the Bonvests Site, Bonvests does not exercise control over any data or any information which you give to any other entity after leaving the Bonvests Site. The linking of other websites to the Bonvests Site is prohibited without express, prior written consent of Bonvests. WARRANTIES/ DISCLAIMERS Liability Waiver – Bonvests disclaims any warranty or representation of any kind, express or implied, as to any matter whatsoever relating to this Bonvests Site or any Linked Site. To the fullest extent allowed by law, Bonvests shall accept no responsibility or liability in respect of any loss or damages howsoever arising herein. Bonvests assumes no responsibility for, and makes no warranty that, functions on the Bonvests Site will be uninterrupted or error-free, that defects will be corrected, or that the Bonvests Site (including its Content) or the servers that make it available will be free of viruses or other harmful components. Accordingly, you hereby release each member of Bonvests Holdings Limited (and its agents, representatives, related companies, and associated companies, subsidiaries and legal and other professional advisors, from all claims, losses, damages, and/or liability in respect of injuries, losses, damages of any kind arising out of or in connection with this Bonvests Site. COMMUNICATIONS
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