CUSTOMER PERSONAL DATA PROTECTION CHARTER
1. CURATAS COMMITMENT TO PROTECTING PRIVACY
We consider you an important customer. Our first priority is to offer you exceptional experiences throughout the Curatas Site.
Your complete satisfaction and confidence in Curatas is absolutely essential to us.
2. SCOPE OF APPLICATION
In this charter, “Curatas” means:
Curatas with Unique Entity Number 53432427D and with registered office at 21 Lorong Siglap, Singapore 456815
3. CURATAS’ SEVEN PRINCIPLES FOR PROTECTING YOUR PERSONAL DATA
In accordance with applicable regulations, we have instituted the following ten principles throughout Curatas:
1. Lawfulness: We use personal data only if:
· we obtain the consent of the person, OR
· it is necessary to do so for the performance of a contract to which the person is a party, OR
· it is necessary for compliance with a legal obligation, OR
· it is necessary in order to protect the vital interests of the person, OR
· we have a legitimate interest in using personal data and our usage does not adversely affect the persons’ rights
2. Fairness: We can explain why we need the personal data we collect.
· Purpose limitation and data minimisation: We only use personal data that we really need. If the result can be achieved with less personal data, then we make sure we use the minimum data required.
3. Transparency: We inform people about the way we use their personal data
4. We facilitate the exercise of the people’s rights: access to their personal data, rectification and erasure of their personal data and the right to object to the use of their personal data
5. Storage limitation: We retain personal data for a limited period
· We ensure the security of personal data, i.e. its integrity and confidentiality.
· If a third party uses personal data, we make sure it has the capacity to protect that personal data.
6. If personal data is transferred outside Singapore, we ensure this transfer is covered by specific legal tools.
7. If personal data is compromised (lost, stolen, damaged, unavailable…), we notify such breaches to the respective country’s responsible authority and to the person concerned, if the breach is likely to cause a high-risk in respect of the rights and freedoms of this person.
For any questions concerning the seven principles of Curatas; data protection policies, please contact the Curatas team.
4. WHAT PERSONAL DATA IS COLLECTED?
At various times, we may collect information about you and/or the persons accompanying you, including the following:
· Contact details (for example, last name, first name, telephone number, email)
· Personal information (for example, date of birth, nationality)
· Information relating to your children (for example, first name, date of birth, age)
· Your credit card number (for transaction purposes)
· Information contained on a form of identification (such as ID card, passport or driver license)
· Your membership number for the Curatas loyalty program or another partner program (for example, an airline loyalty programme) and information related to your activities within the context of the loyalty program
· Your preferences and interests (for example, fashion, lifestyle, type of newspapers/magazines, sports, cultural interests, food and beverages preferences, etc.)
· Your questions/comments, during or following an experience in one of the establishments located within in Curatas Site.
· Technical and location data you generate as a result of using our websites and applications.
The information collected in relation to persons under 16 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, Curatas team to arrange for this information to be deleted.
In order to meet your requirements or provide you with a specific service (such as dietary requirements), we may have to collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation. In this case, we will only process this data if you provide your express prior consent.
5. WHEN IS YOUR PERSONAL DATA COLLECTED?
Personal data may be collected on a variety of occasions, including:
1. Site activities:
· Ordering at Curatas
· Requests, complaints and/or disputes.
2. Participation in marketing programs or events:
· Signing up for loyalty programs
· Participation in customer surveys
· Online games or competitions
· Subscription to newsletters, in order to receive offers and promotions via email.
3. Transmission of information from third parties:
· Tour operators, travel agencies (online or not), online shopping systems and others
4. Internet activities:
· Connection to Curatas’ website (IP address, cookies in accordance with our Policy about the use of tracers)
· Online forms (online reservation, questionnaires, Curatas’ pages on social networks, social networks login devices such as Facebook login, conversations with chatbot, etc.).
6. WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?
The table below sets out why we process your data, the lawful basis for the processing and the associated retention period:
7. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA
Curatas endeavours to provide you with the same and/or more improved services throughout your journey with us. Thus, we have to share your personal data with internal and external recipients subject to the following conditions:
1. We share your data with a number of authorized people and departments in Curatas in order to offer you the best experience in our outlets and shops. The following teams may have access to your data:
· Curatas Team
· IT departments and authorised vendors
· Commercial partners and marketing services
· Legal services if applicable
· Generally, any appropriate person within Curatas entities for certain specific categories of personal data.
In particular, the data related to your preferences, satisfaction and, if the case may be, your loyalty program membership is shared within the operations under the Curatas brand. This data is used to improve the quality of service and your experience in Curatas.
With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your shopping experience, for example:
· External service providers: IT sub-contractors, international call centres, banks, credit card issuers, external lawyers, dispatchers.
· Commercial partners: Curatas may, unless you specify otherwise to the Curatas Team, enhance your profile by sharing certain personal information with its preferred commercial partners. In this case, a trusted third party may cross-check, analyse and combine your data. This data processing will allow Curatas and its privileged contractual partners to determine your interests and customer profile to allow us to send you personalized offers.
· Social networking sites: In order to allow you to be identified on the Curatas website without the need to fill out a registration form, Curatas may put in place a social network login system. If you log in using the social network login system, you explicitly authorize Curatas to access and store the public data on your social network account (e.g. Facebook, LinkedIn, Google, Instagram…), as well as other data stated during use of such social network login system. Curatas may also communicate your email address to social networks in order to identify whether you are already a user of the concerned social network and in order to post personalized, relevant adverts on your social network account if appropriate.
With local authorities: We may be obliged to send your information to local authorities if this is required by law or as part of an inquiry. We will ensure that any such transfer is carried out in accordance with local regulations.
8. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in clause 6 of this charter, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection.
Consequently, in addition to implementation of this charter, Curatas employs appropriate measures to ensure secure transfer of your personal data to Curatas entity or to an external recipient located in a country offering a different level of privacy from that in the country where the personal data was collected.
9. DATA SECURITY
Curatas takes appropriate technical and organizational measures, in accordance with applicable legal provisions (in particular: Art. 32 GDPR), to protect your personal data against illicit or accidental destruction, alteration or loss misuse and unauthorized access, modification or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.) to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services. In relation to the submission of credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction. Organizational measures ensure the security of the processing.
11. YOUR RIGHTS
You have the right to obtain information about and access your personal data collected by Curatas, subject to applicable legal provisions. Also, you have the right to have your personal data rectified, erased or have the processing of it restricted. Furthermore you have the right to data portability and to issue instructions on how your data is to be treated after your death (hopefully as late as possible!). You can also object to the processing of your personal data, in particular to the sharing of the data related to your preferences and satisfaction between the outlets operating in Curatas.
In the event that you wish to exercise any of your above rights, please contact the Curatas Team directly by sending an email to email@example.com or by writing to the address below:
21 Lorong Siglap, Singapore 456815
For the purposes of confidentiality and personal data protection, we will need to check your identity in order to respond to your request. In case of reasonable doubts concerning your identity you may be asked to include a copy of an official piece of identification, such as an ID card or passport, along with your request. A black and white copy of the relevant page of your identity document is sufficient.
All requests will receive a response as swiftly as possible.
You may also exercise your rights in respect of your personal data that is stored and processed by a hotel as a data controller. To do this, you must contact the hotel directly.
You also have the right to lodge a complaint with a data protection authority. For your information,
You can contact Curatas’ data protection officer by writing to firstname.lastname@example.org or to the above postal address
We may modify this charter from time to time. Consequently, we recommend that you consult it regularly.
13. QUESTIONS AND CONTACTS
For any questions concerning Curatas’ personal data protection policy, please contact the Curatas Team (See clause "Your rights").