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PRIVACY POLICY

Updated as of 5 May 2022

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 the ONE°15 Marina Club (the “Club”) collects and uses your personal data, 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.

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.

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 information.

How will your personal data be collected?

The Club collects personal data in the following ways:

  1. when you submit an application form relating to membership or berthing
  2. when you update or amend your personal particulars
  3. when you are registered as a guest
  4. when existing members provide us with references about you e.g. transfer of membership
  5. when your image is captured by our appointed photographer or videographer
  6. when you interact with us such as via emails, letters, telephone calls, and face-to-face meetings
  7. when you make purchases of merchandise
  8. when you make a booking to use the Club facilities or F&B outlets, or to charter a yacht
  9. when you participate in our events, activities, surveys, lucky draws and promotions
  10. when your image is captured on our CCTV system
  11. when you apply for a job at the Club
  12. when you conduct construction, maintenance or repairs works at the Club
  13. when we obtain your personal data from third parties in certain situations with your consent
  14. when you visit our website
  15. when you submit your personal data to us for any other reasons
  16. when you check in to our guest rooms

What is your personal data collected, used or disclosed for?

The Club collects, uses and discloses your personal data for the following purposes, including but not limited to:

  1. processing membership forms
  2. fabricating of membership cards
  3. complying with internal policies and procedures
  4. administering loyalty and rewards programs
  5. responding to your queries and requests from you or individuals you have authorised
  6. sending you updates, information, marketing and advertising material pertaining to facilities, services, events and activities offered by the Club, affiliate partners, reciprocal clubs and third parties with your prior consent
  7. contacting you about feedback you have provided
  8. conducting members’ surveys, lucky draws and credit checks
  9. publishing your photographs in our media platforms and Longitude
  10. facilitating the use of our services, facilities and participation in our events and activities
  11. facilitating the employment of staff by the Club
  12. maintaining the safety and security of the Club’s premises with the use of CCTV cameras
  13. preventing, detecting and investigating crime such as fraud
  14. the performance of financial/operational services for the Club by agents or third-party service providers
  15. providing members access to worldwide marinas managed by the Club
  16. enforcement of security checks and provision of access to the Club
  17. other purposes of use, for which we have obtained your consent, express or implied

By providing your personal data to the Club, you hereby consent to the Club collecting, using or disclosing the personal data for the purposes stated above.

We Collect your information automatically when you access or use the Site, including:

  1. 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.
  2. 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.
  3. 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.
  4. 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.

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.

Accessing and Making Correction to Your Personal Data

You may write in to us, 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 document. We will try to respond to your request within 30 days. By which time we will give you an estimate of how long it is going to take to retrieve all the relevant data, and how much we will charge you for processing the request.

Accuracy of your 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 utilize 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 unauthorized 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 Document Retention Policy 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.

How do you withdraw your consent or update your personal data?

Should you not want 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. Please contact our Data Protection Officer at dpo.sc@one15marina.com for the withdrawal of your consent for the use of your personal data.

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 Club reserves the right to supplement, vary or amend this Privacy Policy from time to time without further notice. Changes to this Privacy Policy will be posted on www.one15marina.com and the date at the top of this Privacy Policy will be revised. It is your responsibility to review this Privacy Policy to ensure you are aware of any changes made by the Club.

If you would like to access, correct, amend or delete any personal data we have about you, register a complaint, or simply want more information, please contact our Data Protection Officer.

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 full information about your personal data that the Club hold, and certain information about how the Club use it and who the Club share it with.

Before the Club accede to your request, the Club may need to verify your identity by checking your legal identification document. 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 hold 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 are 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 that the Club correct any incorrect information the Club hold about you.

  • The right of erasure

You may also have the right to ask that the Club delete your personal data, if

  1. you believe that it is no longer necessary for us to hold the personal data about you
  2. 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 require us to stop processing the personal data the Club hold about you in certain circumstances, if

  1. you believe the personal data is not accurate, for the period it takes for us to verify whether the personal data is accurate
  2. you wish to erase the personal data as the processing of the personal data is unlawful
  3. 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, 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, 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 dpo.sc@one15marina.com

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 intermediary), we will take reasonable and expeditious steps to assess whether the data breach is notifiable under the PDPA within 30 calendar days.

Feedback and Data Protection Officer

Should you have any feedback or enquiries relating to your personal data, please contact our Data Protection Officer at dpo.sc@one15marina.com