Last Updated 1 January 2014

Our Commitment

At HPL Hotels & Resorts, we strive to deliver outstanding services and products.
We are dedicated to protect your privacy and safeguard your personal identifiable information.
We respect your privacy and adhere to the principles of applicable data protection and privacy Laws.

HPL Hotels & Resorts is committed to creating an experience that meets your needs by using the information you entrust us responsibly.
We have provided this Privacy Statement to help you understand how we collect, use and protect your information when you visit our sites.
We wish to help you make informed decisions, so please take a moment to read the sections below:


1 scope

This Privacy Statement is applicable to:

  • any data processing implemented by HPL Hotels & Resorts managed hotels
  • any HPL Hotels & Resorts booking websites, including but not limited to:

2. information we collect

HPL Hotels & Resorts collects information about our guests and visitors to our websites, so that we can enhance experience
that is relevant to one’s need. Information may be collected through processes including, but not limited to the following:

•    registering for e-newsletters or program membership
•    fulfilling hotel reservations or information requests
•    purchasing products and / or services
•    responding to communication to and from us (such as promotional offers, surveys or reservation confirmations)
•    submitting job application

Information that you submit via any of our websites shall be deemed to be collected by us with your permission. Such information may include
but is not limited to your name, contact and fax numbers, home, work and email addresses, frequent flyer or travel partner affiliation,
date of arrival and departure, travel history, details on hotel package you book, credit card details, including the three-digit code
that appears on the back of your credit card, date of birth, gender and lifestyle information such as room preferences, leisure activities
and other information necessary to fulfil special requests.

3. personal information

Unless you provide us with updated information, the last information which you provide shall be deemed by us to be current and accurate
and we shall not be responsible for information that is sent to addresses or emails that are no longer valid or current. If you wish to update any data
or information previously submitted to us, you can do so by contacting us via our websites, emails or calling us directly. In our effort to prevent
unauthorised disclosure of personal information, you may be asked to provide proof of identity or other authentication materials.

4. consent

As part of our continuous effort to keep you informed on our new product and services, we may mail, email, telephone and contact you
by any other means. Information sent to you may also include upcoming special offers, events or other relevant information
that may be of interest to you.

You may also receive mailings or other communication materials from our strategic marketing partners and /or carefully selected third parties.
You will always have the option to decline any or all of these communications by following the directions included in our emails
or other communications, or by contacting HPL Hotels & Resorts directly.

HPL Hotels & Resorts may collect and use personally identifiable information that you volunteer, or other behavioural data generated. In addition to that,
permission will be deemed given for communication from us that is necessary to fulfil transactions and services requested by you.

5. collection of information

At HPL Hotels & Resorts, we are committed to providing you with information about the collection and use of personal information collected from,
or furnished by you while using our websites, products and services. The primary uses of the data and information collected from you may
include and is not limited to:

•    sending communication materials on products and services offered by HPL Hotels & Resorts, its affiliated company,
and/or strategic business partners
•    processing a transaction such as making a hotel reservation, fulfilling a request for proposals
•    performing market research through conducting surveys to better serve your needs
•    improve the effectiveness of our websites; to know about your experience while staying with us; to develop
and execute various types of communication, advertising campaigns and/or promotion activities

You may, in certain instances, be offered the option not to submit your personal information or to decide on the type of communication
you want to receive from us. However, by not providing the information or providing inaccurate or incomplete information, this may
restrict or affect the hotel reservation process or other transactions, for which we shall not be liable in any manner whatsoever should
any reservations or other transactions fail to proceed or any attempts to use our reservation processes by you be frustrated, delayed,
or rejected, or rejected, or otherwise lead to any result which you may not have desired or anticipated.

6. processing and disclosure of information

The information you provided is added to a local or global database. During the course of processing your information, it may be necessary to transfer
the data to HPL Hotels & Resorts affiliates, other managed hotels and / or third party service providers for the purpose outlined within
this Privacy Statement. We do not sell, rent or give physical possession of this personal information to unaffiliated third parties outside
the HPL Hotels & Resorts group. HPL Hotels & Resorts may disclose your information in the following circumstances,
including but not limited to:

•    when we have received your consent or deemed consent to do so
•    when we have informed you of our intentions to do so
•    when sharing or disclosing your information is necessary in order to provide you with the products or services
you requested such as promotional offers, hotel rates proposals and e-newsletters
•    when third party service providers that perform certain business activities on behalf of HPL Hotels & Resorts require this information
to process the services required, such as credit card processing, database management services, customer support services
or guest surveys
•    In the event HPL Hotels & Resorts, its affiliate and / or its managed properties is merged with, enters into a partnership
with or is acquired by another company
•    when a hotel under our management leaves HPL Hotels & Resorts and access to your personal information is necessary to meet
contractual obligations or to facilitate business operations
•    when there is an emergency and need to safeguard the life, health or property of an individual or corporation
•    when it is necessary to comply with legal or regulatory obligations in accordance with applicable law thereof

7. security measures

We will take appropriate measure to safeguard your personal identifiable information. At HPL Hotels & Resorts, we periodically review
and enhance our technical, physical, and logical security rules and procedures. Our websites and servers have procedures in place to protect
your personally identifiable information against misuse, oss and alteration while under our management. Although we cannot promise
“guaranteed security” on or off the Internet, we safeguard your information using both procedural and technical measures such as password controls,
‘firewalls’ and the use of 128-bit encryption based on a Class 3 Digital Certificate issued by Thawte. This allows for the use of Secure Sockets Layer (SSL),
an encryption method used to help prevent interception and hacking while in transit.

8. international data transfers

At HPL Hotel & Resorts, we endeavour to provide the same level of service that you have come to expect at any of our managed properties, whether
you are in Singapore, Malaysia or Maldives. To provide this service, we have established a global network comprised of properties, offices trusted marketing partners,
service providers and reservation centers around the world. Our business and operations models require us to share your personal information with other properties,
group companies or service providers that may be located in countries situated in locations that are different from those of our guests and customers.
As data protection and other laws of these other countries may not be the same as those in your own country, it will not be possible for HPL Hotels & Resorts
to ensure that the practices adopted by us will conform to what you are used to, although we will use commercially reasonable endeavours to take the appropriate
measures to ensure that your personal information is protected and handled as described in this Privacy Statement.

9. online technologies

HPL Hotels & Resorts may use cookies or other technologies such as invisible pixels or web beacons to help us deliver content specific to your interests,
to process your reservation or request, and/or to analyse your visiting patterns.

The cookies can also help us to provide a personalised on-line experience. They provide you with the appropriate frames and content; they help us deliver
communications that are relevant and responsive to your interests and location; they deliver all requested information to you;  they also remember
your user name and password for future visits so log-in is easier and faster.

However, HPL Hotels & Resorts cookies are limited to our web sites only, and are not designed to follow you when travelling on the Internet
after leaving our websites.

Please note that in addition to HPL Hotels & Resorts cookies, various third parties may also place cookies on the hard drive of your computer.
HPL Hotels & Resorts is not responsible for the presence or absence of third party cookies, or for the technological capabilities or practices employed
by third parties in connection with third party cookies.

To our knowledge, Cookies, by themselves, cannot generally be used to disclose your individual identity. This information identifies your browser
to our servers when you visit our site. Cookies can generally be removed at any time from your computer; you need to consult your browser’s
“help” menu to learn how to delete cookies.

HPL Hotels & Resorts may also collect data by using invisible pixels (pixel tags) or web beacons that allow us to know when you visit our sites.
Information collected from pixels tags contain non-personal information, these are the domain name, the areas of the site you visit,
your operating system, the URL you came from etc, which can help enhance your online experience and understand web traffic patterns.

10. links to other websites

For your convenience and information, HPL Hotels & Resorts may provide links to other websites. Please note that we are not responsible or
liable for any content presented by or contained in any external or independent web site, including, but not limited to, any advertising
claims or marketing practices. HPL Hotels & Resorts will protect your information on HPL Hotels & Resorts owned and operated web sites
in accordance with this privacy Statement, but we cannot control and will not be responsible for the privacy policies of external
or third party web sites. This includes other web sites not controlled or authorised by HPL Hotels & Resorts.

If you provide information on third party websites, the privacy policy and terms of service on those sites are applicable.
We encourage you to read the privacy policies of websites that you visit before submitting personal information.

11. minors

At HPL Hotels & Resorts, we do not knowingly collect personal information from minors. If we discover information submitted by minors,
we are at liberty to destroy or reject such information collected, and shall not be liable for any missed opportunities. As a parent
or legal guardian, please do not allow your children to submit personal information without your permission.

12. updates on our privacy statements

In order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our guests and customers, properties,
and service providers, HPL Hotels & Resorts may amend this Privacy Statement from time to time. Therefore, we invite you to read
this Privacy Statement regularly and/or when making a reservation with any of our managed hotels.

13. contact us

Please contact us if you have any questions about this Privacy Statement and how HPL Hotels & Resorts processes your personal
identifiable information in general. You may reach us at:

HPL Hotels & Resorts
50 Cuscaden Road, #05-02 HPL House
Singapore 249724
Tel: 65 6735 2811   |   Fax: 65 6235 3216
Email: [email protected]

Concorde Hotel Singapore
Data Protection Officer
100 Orchard Road
Singapore 238840
Email: [email protected]