1 – Introduction

At Labrador House, we respect the privacy and confidentiality of the personal data of our clients, associates, and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices, and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2020.

We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

2 – How We Collect Your Personal Data

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g., full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.

We collect your personal data when you:

• Make a reservation: When you make a reservation, we collect your name, contact information, payment details, and any special requests or preferences you may provide to ensure a seamless experience.
• Use our service: During your visit, we collect information related to your use of our services, and any feedback you provide to help us improve our offerings.
• Participate in promotions or loyalty programs: If you sign up for a loyalty program, promotional offers or discount, we collect personal details such as your name, email address and any other information you provide to stay informed about upcoming events, special offers or rewards.
• Interact with our website or mobile app: We gather data when you interact with our website or mobile app to make a booking, browse services, or submit inquiries. This can include cookies, IP address, device information, and other technical details to enhance your browsing experience.
• Provide feedback or contact us: If you contact us via email, phone or our website for inquiries, complaints, or feedback, we collect personal data such as your contact details and the content of your communication to respond and improve our services.
• Register for events or activities: If you register for any events or activities organised, we collect your personal details to confirm your participation and send you relevant event information.

3 – Types of Personal Data We Collect About You

The types of personal data we collect about you include:

• Your contact information (Name, Email Address)
• Your personal details (Name, Gender, Date of Birth, Nationality)
• Your NRIC/Passport last four characters for course attending taking and verification

4 – How We Use Your Personal Data

We use the personal data you provide us for one or more of the following purposes:

• Booking and Reservation Management: To process your reservation requests, confirm bookings, and manage changes or cancellations. This helps us ensure that your reservation experience with us are accurate and meet your preferences.
• Customer Service and Support: To respond to your inquiries, address any issues or concerns, and provide customer support during your reservation experience with us. This includes providing assistance with special requests, complaints, or feedback.
• Billing and Payment Processing: To manage payments, process transactions, issue invoices, and handle any payment-related issues, including refunding charges or adjustments.
• Personalized Experience: To customize your experience based on preferences you share with us, such as dietary requirements, room preferences, or special requests, ensuring that we meet your specific needs during your visit.
• Marketing and Promotions: To send you promotional materials, special offers, and updates about events, discounts, or loyalty programs that may interest you. You may receive this information via email, SMS, or app notifications (with your consent, where required by law).
• Loyalty Programs and Rewards: To enroll you in, manage, and improve our loyalty programs or rewards systems, tracking points, special offers, and benefits you earn during your stays or visits.
• Event and Activity Coordination: To manage your participation in our events, such as booking reservations for special events, group activities, or exclusive experiences.
• Security and Safety: To ensure the security and safety of our guests, staff, and property by using personal data to verify identities, track access, and comply with local laws and regulations.
• Legal and Regulatory Compliance: To comply with legal obligations, such as record-keeping, reporting, and other regulatory requirements related to your reservation with us.
• Feedback and Improvement: To gather feedback from you, whether through surveys, reviews, or other feedback mechanisms, to assess and improve our services, customer satisfaction, and overall guest experience.

5 – Who We Disclose Your Personal Data To

We disclose some of the personal data you provide us to the following entities or organisations outside Labrador House in order to fulfil our services to you:

• Service Providers and Vendors: We may share your personal data with third-party service providers and vendors who assist us in operating our business, such as payment processors, IT support teams, housekeeping services, catering partners, and booking platforms. These third parties are contractually obligated to protect your data and use it solely for the purposes we specify.
• Business Partners: We may share your information with carefully selected business partners for the purpose of offering you promotions, special offers, or loyalty programs. These partners may include travel agencies, tour operators, or event organizers that collaborate with us to provide additional services or experiences.
• Marketing and Advertising Partners: With your consent (where required), we may disclose your personal data to marketing and advertising partners to send you offers, newsletters, and other promotional materials that may interest you. You can opt out of receiving these communications at any time.
• Authorities and Legal Entities: We may disclose your personal data to governmental or regulatory authorities as required by law or in response to legal requests, such as during audits, investigations, or compliance with local laws, tax obligations, or safety regulations.
• Payment Processors: In order to facilitate billing and payment, we may share your payment information with third-party payment processors. These processors handle transactions securely and are subject to their own privacy policies and regulations.
• Emergency Services or Healthcare Providers: In the event of an emergency, we may disclose relevant personal data (e.g., medical information or contact details) to emergency responders, healthcare professionals, or other relevant parties to ensure your safety and well-being.
• Corporate Affiliates: If our business is part of a larger corporate group or franchise, we may share your personal data with other affiliates within the group for operational purposes, such as managing your reservations across multiple locations or enhancing customer support services.
• Legal Advisors: We may share your data with legal advisors or professionals in the event of legal claims or disputes, or when required for the protection of our rights, property, and business interests.

We only share your personal data with these parties when necessary and ensure that they handle your information securely and in accordance with applicable data protection laws. Where required, we will seek your consent prior to disclosing your personal data to third parties.

6 – How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use, or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g., when you apply for a job with us by sending in your resume/CV containing personal information.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to Labrador House are included):

• the personal data is publicly available;
• the personal data is disclosed by a public agency or disclosed to a public agency;
• the personal data is necessary for any investigation or proceedings;
• the personal data is necessary for evaluative purposes (e.g., determining the suitability of a job applicant for the job applied for);
• the personal data is necessary for the purpose of managing or terminating an employment relationship; and
• the personal data is necessary for a business asset transaction.

6.2 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g., without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “Unsubscribe” feature in an online service.

6.3 Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences.

The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

6.4 Third-Party Consent

We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.

7 – How We Ensure the Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

8 – How We Protect Your Personal Data

We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or similar risks.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.

9 – How We Retain Your Personal Data

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10 – How You Can Access and Make Correction to Your Personal Data

You may write in to us to find out how we have been using or disclosing your personal data over the past year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date, you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

11 – Transfer of Personal Data

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.

12 – Mandatory Data Breach Notification

In the unlikely event that we suffer a data breach pertaining to unauthorised access or disclosure of personal data being stored or processed by us, we will meet the PDPA's breach notification timelines and requirements to perform the needful, including but not limited to informing relevant authorities and affected individuals, based on the Significant Harm or Significant Scale definitions as set out by the PDPA.

13 – Contacting Us

If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@labradorvilla.com

Any query or complaint should include, at least, the following details:

• your full name and contact information; and
• brief description of your query or complaint.

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.

14 – Changes to this Data Protection Notice

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

Last updated: 13 January 2025