Effective date: 08/01/2020
SUMMARY OF HOW WE USE YOUR DATA
- What do we do with your information and what is the legal basis for this use? Lodgis Hospitality Holdings Pte Ltd as well as its affiliates, subsidiaries and related entities (also refer to as “Fusion”, “we” or “us”), uses your personal data to process and facilitate bookings, provide you with highly-individualized service at our hotels or for delivery to your chosen location, respond to your requests for information, inform you of our products and services and other purposes as set out in this notice.
- Disclosure: Data is shared with companies in the Fusion, third party service providers and professional advisers that are mainly located in Vietnam, Singapore, and Australia.
- Your rights: You have certain rights to your personal data under applicable laws, including a right to object to some of the processing which Fusion carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
WHAT DOES THIS NOTICE COVER?
This is the Privacy Notice of Fusion. It describes how we will make use of data which you provide to us or any of our Fusion companies.
Please read this page carefully before you start to use this site. Our site may include links to other websites over which we have no control. Fusion is not responsible for the privacy policies or practices of other websites. We may also link to other websites operated by Fusion which operate under separate privacy policies. If you access these websites via our site, you should review the privacy policies of those websites so you can understand how they collect, use and share your information.
If you have any queries regarding this Privacy Notice or complaints about our use of your information please contact us at email@example.com and we will do our best to deal with your complaint or query as soon as possible.
INFORMATION WHICH WE MAY OBTAIN ABOUT YOU
The types of information we may collect and process from you include:
- your contact information (e.g. salutation, name, telephone number, email address, postal address, organisation);
- your financial information (e.g. credit card number, security code, expiration date);
- information related to your travel profile (e.g. accommodation and travel preferences, booking history, special health accommodations, any comment your note to us);
- information related to your client profile (e.g. delivery address, country of residence, favourite currency);
- your marketing preferences, including any consents you have given us;
- if you contact us or our agents, we may keep a record of that communication and any communications and correspondence with you; and
- information related to the browser or device you use to access our sites, including where available, your IP address, operating system and browser type, for system administration and security reasons and to collect aggregate information.
WHAT INFORMATION ABOUT YOU DO WE RECEIVE FROM THIRD PARTIES?
Sometimes, we receive information about you from third parties. In particular:
we may receive information about you from travel agents, tour operators and destination management companies, corporate companies whom you have direct contact. The information we collect from such third parties include your contact information and information related to your travel profile.
- when you interact with us on social media platforms such as Facebook, Instagram and YouTube (depending on your privacy preferences on those platforms);
WHAT WE DO WITH YOUR INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?
We may use the personal data you supply to us via our site for the following purposes:
- to fulfil a contract, or take steps linked to a contract: this is relevant where you make bookings or place an order with us. This includes, for example:
- processing and facilitating bookings, including verifying your identity, taking payments and communicating with you;
- providing customer services;
- as required by Fusion to conduct our business and pursue our legitimate interests, in particular:
- responding to requests which you have submitted via our site and to deal with on-going matters relating to such requests;
- presenting content from our site in the way that we consider most effective;
- providing you with highly-individualized service at our hotels and presenting you with information relating to Fusion;
- if you provide a credit or debit card as payment, we use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see data sharing below);
- monitoring customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- using information you provide to investigate any complaints received from you or from others, about our website or our products or services;
- using data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
- where you give us consent:
- providing you with travel-related information, information relating to Fusion or promotional details about products and services that may be of interest to you, as well as personalised mailings (electronic or otherwise) or other communications;
- invite you to join our e-newsletter distribution;
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time.
- for purposes which are required by law, such as:
- in response to requests by government or law enforcement authorities conducting an investigation;
WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
WHO WILL WE SHARE THIS DATA WITH, WHERE AND WHEN?
Fusion may disclose your personal data to the following categories of recipients (in all cases, only when necessary to fulfil their functions):
- our staff (including employees and external consultants), professional advisors and agents;
- third party service providers which process your personal data on behalf of Fusion and who are bound by contractual obligations to keep your personal data confidential and appropriately secure. In particular, we use third party providers of website hosting, backend service provider, analytics, crash reporting, and email marketing;
- government authorities, regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws;
- if there is a corporate sale, merger, reorganisation, insolvency event or other similar event.
Our office headquarters are based in Vietnam, and our main data centre is located in Singapore. Therefore, where required to perform our contract with you or for our wider business purposes, the information that we hold about you will be transferred to, and stored at, a destination in Singapore. In addition, we use Intouch Data as a marketing platform to send eDM based out of Australia. By making a reservation, visiting or staying at a Fusion branded property or using any Fusion Group branded service, you understand that we may transfer your personal data.In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your personal data.
- What cookies do we use and why?
Fusion uses the following cookies:
|Strictly Necessary Cookies||These cookies are essential to the operation of our services. Without these cookies, the services in question would not work properly (e.g. you wouldn’t be able to navigate around the site or access certain types of content). These cookies cannot therefore be turned off.||2 years|
|Functionality Cookies||These cookies provide you with a better browsing experience based on the choices you make. These cookies allow our website to remember choices users make (such as the country you visit our website from, language, text size, fonts, currency, and search parameters) and provide enhanced, more personal features. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.||2 years|
|Social Media Cookies||These cookies are used when users share information using social media accounts. These cookies are used when you share information using a social media sharing button or “like” button on our sites or apps, or when you engage with our content on or through a social media site such as Facebook, Instagram, LinkedIn, , and YouTube.||2 years|
- How do I control cookies?
If you are using our content via a web browser, you can change your cookie preferences and withdraw your consent at any time using our [Cookie Consent Tool].
You may also set your browser to block all cookies or to indicate when a cookie is being set, although our services may not function properly if your cookies are disabled. Further information about the procedure to follow in order to disable cookies can be found on your browser provider’s website, or you may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers.
Please be aware that if cookies are disabled, not all features of the services may operate as intended.
WHAT RIGHTS DO I HAVE?
Subject to applicable laws, you may have rights in relation to your personal data. Such rights include:
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you are an EEA resident and you have unresolved concerns, you have the right to complain to an EEA data protection authority where you live, work or where you believe a breach may have occurred.
We will aim to respond to all legitimate requests as soon as we reasonably can and in any event within 30 days. If we think that it will take us longer than 30 days, we’ll let you know why and keep you updated. Where you make any requests, we might ask for specific information to confirm your identity as a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. This might include asking for further information in relation to your request to be able to speed up our response.
HOW TO GET IN TOUCH WITH US
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org, or by writing to Fusion Head Office, Floor 7, Vincom Center B, 72 Le Thanh Ton street, District 1, Ho Chi Minh City, Vietnam.
HOW LONG WILL YOU RETAIN MY DATA?
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
Where we process your financial information, we will only keep the information for as long as necessary for the purpose/s for which it is collected and up to 3 months thereafter.
Where we process personal data in connection with performing a contract, we keep the data for 2 years from your last interaction with us.
Which fusion entity is my data controller, and which affiliates might my data be shared with?
The data controller for your information is Lodgis Hospitality Holdings Pte Ltd.
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.