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Updated as of 5 December 2023

ONE°15 Privacy Policy

At ONE°15, We respect Your privacy and aim to comply with the requirements of the Personal Data Protection Act (“PDPA”).

This privacy policy (this “Privacy Policy”) explains how ONE°15 Marina Club (the “Club”) collects and uses the Personal Data of individuals (“You” or “Your”), and the measures that We take to secure Your Personal Data.

For the purpose of this policy, the terms We”, “Us or Our shall, unless otherwise indicated, refer to the Club.

This Policy is applicable on You when You access and use Our website, use Our services and facilities or visit the Club. By accessing and/or using Our website and/or facilities in the Club, You signify Your acceptance of the Policy and expressly consent to Our collection, use, disclosure, and retention of Your Personal Data as described in this Policy. 

Collection, Use and Disclosure

ONE°15 Marina Club is a waterfront lifestyle destination that offers world-class comprehensive marina facilities (Our “Services and Facilities”) at the Sentosa, Singapore.

We collect Personal Data from individuals who seek to be a Member of the Club (“Members”), guests that uses Our Club’s facilities (“Guests”), visit Our website and the Club (“Visitors”) and apply for a position in the Club (“Applicants” and “Employees”).

Notwithstanding any other provision in this Policy, You agree that the Club shall be entitled to use and disclose any information and feedback arising from Your use of Our Services and Facilities, subject to such information and feedback being anonymised and such use and disclosure being in compliance with applicable privacy laws including but not limited to the Personal Data Protection Act 2012 of Singapore (“PDPA”), and the European Union (EU) General Data Protection Regulation (“GDPR”).

What is Personal Data?

Personal Data refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which an individual, company, association or body of persons, corporate or unincorporated, has or is likely to have access. Examples of Personal Data are Your name, NRIC number or FIN number, address, telephone numbers, email addresses, photographs or video images.

In the event of Our activities in the EU, the definition of Personal Data shall also include Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data or biometric data processed for the purpose of uniquely identifying a natural person such as facial images or fingerprints, data concerning health or data concerning a natural person’s sex life or sexual orientation, criminal convictions and offences, and other information defined as Personal Data under GDPR such as internet protocol addresses and cookie identifiers (insofar as such information is capable of identifying individuals either directly or indirectly).

What Personal Data We collect

When You use Our Services and Facilities, We may collect, amongst others, the following Personal Data:

  • Your name, Your spouse and Your children/dependents Personal Data including but not limited to Name, NRIC, passport or other identification number, nationality, gender, date of birth, race, marital status, residential address, email address, telephone number(s), Bank account/credit card details, photographs, video recordings, audio-visual information films, employment history, financial information, education background and any other information relating to You which You have provided us in any forms You may have submitted to Us, or in other forms of interaction with You, Your spouse and Your children/dependents.
  • Your next of kin, emergency contact person Personal Data, including but not limited to Name, NRIC, passport or other identification number, telephone number(s), residential address and email address.

Apart from any Personal Data provided by You, We collect Your information automatically when You access or use the website, including:

  • Log in Information: We may collect information about Your use of the site, including the type of browser You use, the times at which You accessed Our site, the pages of Our site that You viewed, Your IP address, and the page You visited prior to visiting Our site.
  • Device Information: We may collect information about the computer or mobile device (“Device”) that you used to access our site with, including the hardware model of the device and the version of the operating system used, unique device identifiers (including but not limited to the IP address, IMEI number, the address of the device’s wireless network interface, and/or mobile phone number used by the device) and information relating to which mobile network Your device was on.
  • Location Information: We may collect information about Your device’s location each time you access or use one of our mobile applications.  You may turn off location services for Your device at any time, but this may turn off some of the useful features that Our mobile application offers.
  • Information Collected by Cookies, Web Beacons and Other Tracking Technologies: We and/or Our service providers use cookies, web beacons and other various technologies to collect information about Your visit to Our site.  Cookies are small data files that are stored in Your hard drive or otherwise in Your device’s memory that help us see which areas and features of Our site are popular and count visits, thus allowing Us to improve Our site and Your experience when You visit it.  Web beacons are electronic images that may be used when You use Our services or when You receive Our emails that help deliver cookies, count visits and understand Your usage of Our Site and Our services. They help Us assess the effectiveness of Our campaigns and how We may better improve Our site and services for You.

Apart from any Personal Data provided by You, We may also collect certain non-personal and/or technical information through third-party sources, platforms (such as social networking websites, databases, online marketing firms, and ad targeting firms) and other channels. This includes, but not limited to, information about Your device used to access the Club’s websites, Your web browser type and language, Your Internet Protocol (IP) address and geographic data associated with the IP address etc.

Where Personal Data is submitted by You on behalf of another individual or concerns another individual other than Yourself (or, in situations where You represent Your company or organisation and submit the Personal Data to Us), You represent and warrant to Us, that all the necessary consents (procured in accordance with all applicable data protection legislation) have been obtained from the relevant individuals and that You have retained proof of these consents, such proof to be provided to Us upon Our request.

Consent to be bound

When You provide Your Personal Data to the Club in the manner set out below (including but not limited to the submission of an application form relating to membership or berthing to the Club or requesting to be included on our mailing list), You hereby consent to be bound by this Privacy Policy. If You do not accept any term in this Privacy Policy or do not agree to be bound by this Privacy Policy, please do not provide Your Personal Data to the Club. Please note that in such cases, the Club may not be able to process Your application or provide You with any of the services or deal with You in the manner set out below.

Where You are providing Personal Data of an individual other than Yourself, You warrant and represent to the Club that You have obtained their consent to the disclosure of their Personal Data to the Club. The Club may require You to provide written confirmation from the individual or seek confirmation directly from the individual that he or she has consented to the use of his or her Personal Data.

How will Your Personal Data be collected?

The Club collects Personal Data in the following ways:

  • You submit application form relating to Your membership or berthing;
  • You register with Us for Our Services and Facilities including but not limited to: booking to use the Club facilities, food and beverage outlets and to charter a yacht;
  • You make purchases of merchandise at Our Club;
  • You check into Our guest rooms or any of Our Club’s facilities;
  • You register as Our guest;
  • You participate in Our events, activities, surveys, lucky draws and promotions;
  • You request to be included Our mailing list;
  • You visit Our websites;
  • You attend Our events and activities as photographs and/or video recordings may be taken;
  • You visit Our Club as surveillance cameras are in use for 24 hours;
  • You communicate with Our employees, directors and committee members in meetings or through emails or telephone calls;
  • existing Members provide Us with references about You, including but not limited to the transfer of membership;
  • You respond to Our request for additional Personal Data or updates of Your Personal Data;
  • You participate in Our research and/or survey, that may be conducted by Us or Our partners/vendors;
  • You conduct construction, maintenance or repair works at the Club;
  • You apply for employment with Us;
  • You submit Your Personal Data to Us for any other reasons that are described to You, and
  • Your Personal Data is given to Us from third parties including third party social networking services when You choose to connect with those services.

What is Your Personal Data collected, used or disclosed for?

The Personal Data is collected, used, disclosed and/or processed for the following purposes (“Purposes”):

  • Processing of Your application to be a Member of the Club;
  • Management of Your membership including but not limited to fabricating of membership cards and conducting credit checks and Members’ surveys;
  • Administration of Members’ loyalty, rewards programs and lucky draws;
  • Providing and delivering Our Services and Facilities as a Member of the Club or as You have requested;
  • Providing Members access to worldwide marinas managed by the Club;
  • Processing and responding to Your queries and requests that You (or individual that You have authorised) made to the Club;
  • Providing updates on upcoming events and news about Our Club, Our Services and Facilities including general correspondence, responding to feedbacks You provided Us, marketing and advertising materials pertaining to Our Club, Our Services and Facilities, Our affiliate partners and reciprocal clubs;
  • Allowing You to register for any of Our activities and events for Yourself, Your spouse and Your children/dependents and facilitating the use Our Services and Facilities;
  • Publication in Our media platforms and Longitude;
  • Assessing the suitability of Your application for a position with Us and management of Your employment with the Club;
  • During emergencies where disclosure is required to safeguard the life or health of an individual;
  • Statistic analytical to improve the Club’s services;
  • Conducting market research and analysis to understand Members/guests preferences;
  • Compliance with internal policies, procedures, monitoring and audit reviews;
  • Carrying out billing, processing credit notes, accounting, auditing and the maintenance of proper book-keeping for the Club’s operations by the Club or the Club’s agents and service providers;
  • Maintaining the safety and security of the Club’s premises including enforcement of security checks for access to the Club;
  • Contact tracing in accordance with the recommended industry practices;
  • Investigating allegations or suspicion of fraud, misconduct and any unlawful action or omission;
  • Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities and agencies; and
  • Fulfilling any other reasonable purpose which may, in the ultimate discretion of the Club, be necessary for administrative and/or operational purposes.

Generally, We process Your Personal Data for one or more of the specific purposes identified above based on Your consent obtained. Where GDPR applies, the legal basis for Our processing of Your Personal Data could also be that it is necessary for the legitimate interests pursued by Us. These legitimate interests include providing services to You where You are Our client, managing the relationship between the Club and You and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of Your Personal Data may be a statutory and/or contractual requirement, or may be necessary in order to perform any contract You have agreed with Us or perform services that You have requested.

Third parties

Personal data that You provide will be provided to affiliate partners, reciprocal clubs and third parties in connection with any services provided by these parties (including without limitation, third party payment processing companies, mobile short-messaging-system providers, anti-money laundering watchlist database providers and the relevant authorities).  Such services would include the maintenance of Our websites or platform, monitoring platform activity, provisions of platform content or membership database, and storage of membership information. Whilst care would be taken to require that some of these third parties (to the extent possible, with relevant authorities exempted) provide an undertaking on compliance with the PDPA and applicable Personal Data protection regulations, the Club will not be able to provide any warranties on the manner or care in which these third parties maintain, protect or utilise Your personal information.

Additionally, the Club shall be entitled to collect, use or disclose Your Personal Data without Your consent if required to do so or permitted, by law.

Access Rights

You may write in to Us using the form https://bit.ly/ONE15APDPA, based on reasonable grounds, to find out how We have been using or disclosing Your Personal Data.

We are obligated under the PDPA to allow You access to Your Personal Data of the past one year, and to make any correction if there is any error or omission. Before We accede to Your request, We may need to verify Your identity by checking Your NRIC or other legal identification documents.

Please note that a reasonable fee may be charged for an access request. If so, We will inform You of the estimated fee before processing Your request. We reserve the right not to provide access to the Personal Data until You have paid the access fee.

We will respond to Your request as soon as reasonably possible. Should We not be able to respond to Your request within 30 calendar days of receiving Your request, We will inform You in writing within 30 calendar days of the time by which We will be able to respond to Your request and/or the reasons We are unable to do so.

Correction Rights

You are entitled to request to correct an error or omission in the Personal Data which We hold about You, using the form https://bit.ly/ONE15CPDPA.

We will respond to Your request as soon as practicable. Should We not be able to respond to Your request within 10 working days of receiving Your request, We will inform You in writing within 10 working days of the time by which We will be able to respond to Your request and/or the reasons We are unable to do so.

Withdrawal of Consent

The consent that You provide for the collection, use and disclosure of Your Personal Data will remain valid until such time it is being withdrawn by You in writing.

You are entitled to withdraw any consent You have provided to Us previously and to request Us to stop collecting, using and/or disclosing Your Personal Data for any or all of the Purposes listed in 1.3 above, by submitting Your request using the form https://bit.ly/ONE15WPDPA.

Please note that We are generally not obliged to forward any request for withdrawal of consent to any third party to whom We have disclosed Your Personal Data – such requests should be made directly with such third parties. Upon receipt of Your written request to withdraw Your consent, We may require reasonable time (depending on the complexity of the request and its impact on our relationship with You) for Your request to be processed and for Us to notify You of the consequences of Us acceding to the same.

We will respond to Your request as soon as reasonably possible. In general, We shall seek to process Your request within 10 working days of receiving it. Should We not be able to respond to Your request within 10 working days of receiving Your request, We will inform You in writing within 10 working days of the time by which We will be able to respond to Your request.

Please note that the withdrawal of Your consent does not affect Our right to continue to collect, use and disclose Your Personal Data where such collection, use and/or disclosure without consent is permitted or required under applicable laws and regulations. Further, We are generally not obliged to delete or destroy Personal Data after Your withdrawal of consent (but such Personal Data will continue to be protected and retained in accordance with our internal policies and applicable laws and regulations).

Accuracy of Personal Data

We will take reasonable precautions and verification checks to ensure that the Personal Data We have collected from You is reasonably accurate, complete and up-to-date. From time to time, We will do a verification exercise for You to update Us on any changes to Your Personal Data.  If You are a Member or client, it is important that You update Us if there are any changes in Your personal information.

How is Your Personal Data protected?

We are committed to protecting and respecting Your Personal Data. We take reasonable steps to safeguard Your Personal Data from loss, misuse, disclosure or unauthorised access by locking the relevant file cabinets containing the Personal Data of the Club’s Members, restricting access to Our offices, preventing unauthorised computer access, installing password-protected access by authorised users, installing firewalls and anti-virus software, restricting access to Personal Data to only staff who need such access to perform their day to day functions, requiring third party service providers to execute confidentiality agreements and conducting training for the staff.

The website may utilise automated tracking devices or software such as a “cookie”. By using the website, You are deemed to have consented to our use of such cookies. If You do not wish to receive cookies, please configure Your internet browser to erase all cookies from Your computer, to block all cookies or to receive a warning before a cookie is stored.

The website contains links to other websites which are not maintained by the Club. Similarly, other websites may contain links to this website. The Club has no control over such sites and resources, and You acknowledge and agree that the Club is not responsible for the privacy practices or contents of those websites.

The Club does not represent or warrant that the website or its contents are free of errors, infection by computer viruses, and/or other harmful or corrupting code, program, macro and such other unauthorised software. You agree not to hold the Club liable for the disclosure of any such information or other personal information that is due to any circumstances beyond the control of the Club.

Retention of Personal Data

We will not retain any of Your Personal Data under Our charge or control when it is no longer necessary for any business or legal purposes. We have a Personal Data Inventory Map that spells out how long We ought to retain each type of confidential document or Personal Data. Certain retention periods are based on statutory or regulatory requirements.

We will ensure that Your Personal Data that no longer has any business or legal use will be destroyed or disposed of in a secure manner. This applies to both paper documents and electronic data stored in databases.

Transfer of Personal Data

If there is a need for Us to transfer Your Personal Data to another country, We will obtain Your consent before transfer. 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 that in Singapore.

Do-Not-Call (DNC) Provisions and Telemarketing Activities

We will only contact You via voice call, text message or facsimile, sending you updates, information, marketing and advertising material pertaining to facilities, services, events and activities offered by the Club, affiliate partners and third parties with Your prior consent.

For Citizens of the European Union

If You are a citizen of the European Union, kindly refer to our policy on the “Rights of Data Subject under the General Data Protection Regulations (GDPR)”.

Rights of Data Subject under the General Data Protection Regulations (GDPR)

If You are a resident in the EU, you may have certain rights in relation to the Personal Data the Club hold about You.

These rights include:

  • The right of access

You have the right to be provided with full information about Your Personal Data that the Club holds, as well as certain details about how the Club uses it and with whom the Club shares it.

Before the Club accedes to Your request, the Club may need to verify Your identity by checking Your legal identification documents. The Club will try to respond to Your request within 30 days. By which time, the Club will give you an estimate of how long it is going to take to retrieve all the relevant data, and how much the Club will charge You for processing the request.

The Club may not provide You with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data the Club holds about You would reveal information about another person) or where another exemption applies.

  • The right of data portability

You may have the right to receive Your Personal Data in a structured and commonly used readable format and a right to request that the Club transmit such Personal Data to another party.

If You wish for Us to transmit the Personal Data to another party, please ensure You detail that party and note that the Club can only do so where it is technically feasible. The Club is not responsible for the security of the Personal Data or its processing once received by the third party.

  • The right of rectification

You have the right to require us to correct any inaccurate information that the Club holds about You.

  • The right of erasure

You may also have the right to ask that the Club deletes Your Personal Data, if

  • You believe that it is no longer necessary for Us to hold the Personal Data about You; or
  • You wish to withdraw Your consent from the Club to continue using and/or disclosing Your Personal Data for the above purposes. You may at any time, provide Us with written notice informing Us of Your decision to withdraw Your consent from the use of Personal Data by the Club and/or its third party service providers and/or agents.

By withdrawing Your consent, You acknowledge and agree that the Club may not be able to continue maintaining, administering or furthering Your membership effectively and/or You may miss or fail to receive relevant notices and messages relating to Your ongoing relationship with the Club.

  • The right to restrict processing

You have a right to request us to stop processing the Personal Data that the Club holds about you in certain circumstances, if

  • You believe that the Personal Data is not accurate, for the period it takes for Us to verify whether the Personal Data is accurate;
  • You wish to erase the Personal Data as the processing of the Personal Data is unlawful; or
  • You wish to erase the Personal Data as it is no longer necessary for any business purposes.
  • The right to object

You may have the right to object to the use of Your Personal Data by Us to send you promotions, special offers and marketing messages.

  • The right not to be subjected to automated decision-making (including profiling)

You may have the right not to be subjected to the use of Your Personal Data by Us where We build profiles for purposes such as promotions, special offers and marketing.

Exercising Your rights

To exercise Your rights, or if You require further information about how Your Personal Data is used by Us, please contact Our Data Protection Officer at [email protected].

Data Breach Notification

In the event whereby the Club has credible grounds to believe that a data breach has occurred (whether through self-discovery, alert from the public or notification by our data intermediaries), We will take reasonable and expeditious steps to assess whether the data breach is notifiable under the PDPA within 30 calendar days.

Changes to this Privacy Policy

As part of Our efforts to ensure that We properly manage, protect and process Your Personal Data, We will be reviewing Our policies, procedures and processes from time to time and the Club may amend this Policy from time to time.

We will provide notification of the material changes to this Policy on the Club’s websites at least thirty (30) business days prior to the change(s) taking effect.

Feedback and Data Protection Officer

Should You have any feedback or enquiries relating to Your Personal Data, please contact Our Data Protection Officer at [email protected].