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By continuing to use the website, you will be agreeing to our Personal Data Protection Policy, Terms & Conditions and Cookies Policy.

Personal Data Protection Policy

Protection of your Personal Data is important to us. This Personal Data Protection Policy (“Policy”) outlines how [Suzette International Pte.Ltd./Suzette Holding Co. Ltd. (“Suzette”)], as well as Suzette’s representatives and/or agents (collectively referred to herein as “Suzette”, “we”, “us” or “our”) collectively or singularly as the context requires, manages the Personal Data within our possession or our control .

Please take a moment to read this 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 us collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Policy.

We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws.

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which Suzette may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

For the avoidance of doubt, to the maximum extent permitted under applicable law, nothing in this Policy establishes any liability on the part of Suzette.

Your Personal Data

“Personal Data” refers to any data or information about you where you can be identified either (a) from that data alone; or (b) from that data combined with other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):

1. your name, telephone number(s), mailing address, email address and any other information relating to you which you have provided to us in any form you may have submitted to us, or in other forms of interaction with you;
2. information about your use of our websites and services, including cookies, information about your domain name, IP addresses, subscription account details and membership details;and
   your payment related information, such as your bank account or credit card information, and your credit history.

Collection of Personal Data

Generally, we collect your Personal Data in the following ways:

1. when you submit forms (online or otherwise) relating to any of our products or services, or submit any online queries;
2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us;
3. when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites and/or any membership programmes owned and/or operated by us;
4. when you register for membership on our mobile application(s) and/or website, or use any of our services on any mobile applications owned or operated by us;
5. when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, forms (including any “Contact Us” forms on our websites), reservation chat, social media platforms and emails;
6. when you use or purchase our services or products;
7. when you establish any online accounts with us;
8. when you request that we contact you;
9. when you respond to our request for additional Personal Data;
10. when you ask to be included in an email or other mailing list (such as our newsletter);
11. when you respond to our promotions and other initiatives;
12. when you respond to our market surveys;
13. when your images are captured by us via CCTV cameras while you are within our property and/or premises;
14. when your photographs or videos are taken by us or our representatives when you attend or participate in events held within our properties and/or premises;
15. when you submit your Personal Data to us for any other reason; and
16. when you browse our website. Please refer to our Cookies Policy for more information.

We may monitor or record phone calls and external-facing interactions (including interactions with our members and customers) for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. Such monitoring or recording will be in accordance with applicable law.

If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

Purposes for Collection , Use and Disclosure of Personal Data

In general, we will, subject to applicable law, collect, use and disclose your Personal Data for the following purposes:

1. to provide you with the products or services that you have requested (including the redemption of products, services or the administering of other benefits associated with any of our partners);
2. to help us review, develop, improve, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing customer behaviour and future customer needs, conducting market research and data analytics (including by requesting feedback from you or your participation in surveys);
3. for authentication and verification purposes;
4. to communicate with you and respond to your queries, requests and complaints;
5. to handle disputes and conduct and facilitate investigations and proceedings;
6. to protect and enforce our contractual and legal rights and obligations;
7. to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
8. to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
9. to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures;
10. to organise, facilitate, and administer roadshows, tours, promotional events,;
11. to comply with any contractual terms and conditions to which Suzette is bound by;
12. to commence, respond to, or act 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);
13. to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
14. to match any Personal Data held which relates to you for any of the purposes listed herein;
15. to facilitate business asset transactions (which may extend to any merger, acquisition or asset sales);
16. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and
17. purposes which are reasonably related to the aforesaid.

In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

The above purposes are not exhaustive, and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

When you apply for or hold a co-brand product which is offered jointly by us and our co-brand partner(s), we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the co-brand partners for offering, marketing and promoting to you any products, services, offers or events which the co-brand partner thinks may be of interest to you. We will only share your Personal Data with the co-brand partners where permitted by applicable law.

Where you have provided us with specific consents, we may also collect, use and disclose your Personal Data for the following purposes:

1. providing services and extending benefits to you, including promotions, loyalty and reward programmes, and sending you industry market updates, newsletters and other information on our products, services, offers or promotions which may be of interest to you;
2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or third parties;
3. administering contests, competitions and conducting lucky draws, including, where necessary, announcing the results of these contests, competitions and lucky draws and identifying and contacting the winners; and
4. conducting market research to understand and determine customer locations, preferences and demographics for us to develop special offers, promotional and/or marketing programmes.

In relation to particular products or services or in your interactions with us, we may also notify or 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.

Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties whether they are located overseas or in Singapore only to the extent necessary and proportionate:

1. other divisions or entities within Suzette’s corporate group;
2. our joint venture/ alliance partners;
3. our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services in pursuance of the purposes set out in this Policy, such as telecommunications, information technology, payment, processing, training, market research, storage and archival;
4. vendors or third party services providers and our marketing and business partners in connection with marketing promotions, products and services;
5. our corporate clients which provided your Personal Data to us or by which you indicated to us that your Personal Data may be collected, used or disclosed ;
6. any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not, and where permitted by applicable laws;
7. insurers or insurance investigators and credit providers;
8. in the event of default or disputes, any debt collection agencies or dispute resolution centres;
9. 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);
10. our professional advisors such as our consultants, auditors and lawyers;
11. relevant government ministries, regulators, statutory boards or authority or law enforcement agencies to comply with any laws or rules and regulations or schemes imposed by any governmental authority;
12. anyone to whom we transfer or may transfer our rights and obligations, including, for example, where we obtain the services of a third party organisation to handle any aspect of the processing of your Personal Data for the purposes notified to you in accordance with this Policy;
13. banks, credit card companies and their respective service providers; and
14. any other party as may be consented to by you, as specified by you or as may be notified to you by us in subsequent notices.

We require that organisations which handle or obtain your Personal Data as service providers to us acknowledge the confidentiality of your Personal Data, undertake to respect any individual’s right to privacy and comply with the PDPA and any other applicable data protection laws. We also require that these organisations use your Personal Data only for our purposes and follow our directions with respect to your Personal Data.

As described above, in carrying out our business, it may be necessary to share your Personal Data with and between our related corporations and third party service providers. We will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected.

Keeping Your Personal Data Accurate and Up-To-Date

We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide, or delays in providing you with products and services you have requested, or processing any requests and applications you may have made to us.

Telemarketing Policy

Our Telemarketing Policy relates only to individual users of Singapore telephone numbers and was developed to comply with our obligations under the Do Not Call (“DNC”) provisions under the PDPA (where applicable).

We aim to comply with the DNC provisions and your choices to receive promotional and marketing messages.

If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages via SMS, fax, calls and other means (as applicable) to your telephone number.

However, if you have previously consented to our sending you such messages to your Singapore telephone number(s), we will continue to do so until you withdraw such consent, regardless of your DNC nominations.

Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS or fax about products and services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you do not opt-in to the receiving of such messages.

Retention of Personal Data

We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, used and/or disclosed as set out in this Policy, or as required or permitted by applicable laws, and in most cases, up to 3 years unless otherwise required by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data in accordance with our internal Personal Data retention policy.

Withdrawal of Consent

You may withdraw your consent given for any or all purposes set out in this Policy in writing by contacting our DPO in accordance with below this section. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Suzette, and your being in breach of your contractual obligations or undertakings. Suzette’s legal rights and remedies in such event are expressly reserved.

Without prejudice to the foregoing, you agree and acknowledge any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to us in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information, subject to your withdrawal of consent for your receipt of the same.

How to contact us
If you:

1. have any questions or feedback relating to your Personal Data or about this Policy;
2. would like to withdraw your consent to any use of your Personal Data as set out in this Policy; or
3. would like to obtain access and make correction to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested),