We handle your privacy in strict compliance with the EU General Data Protection Regulation (GDPR) 2016/679 and the Data Protection Act 2018 (DPA), and Personal Data Protection Act (PDPA).
This Policy covers the policies and practices for how Vouch SG Pte Ltd (hereinafter referred to as “Vouch,” “we,” or “us”) handles the Personal Data of visitors to our website https://www.vouchconcierge.com/ (“Website”) and guests of Properties (“guests”) (collectively, “you,” or “your”) who use our web platform, mobile platform, or applications or products that link to this Policy (together, the “Services”). “Personal Data” is information that relates to an identified or identifiable individual.
Legal basis for processing of Information. We will process your Personal Data on either one of the following legal basis:
Information You Provide Directly to Us. When you use the services or engage in certain activities, such as registering, requesting services, or contacting us directly, we may ask you to provide some or all of the following types of information:
You can choose not to provide information to us directly, but some of this information is required to participate in some Services, such as registering or requesting services from Properties through the Vouch platform.
The best way to protect sensitive data is to not share it. Please do not enter private or sensitive information into the Vouch Services.
Information We Collect Automatically. We may collect certain information automatically through your use of our Services or other methods of web analysis, such as:
Information We obtain from other sources. Properties send Vouch guest information regarding communications, requests, maintenance, and other service delivery. Vouch may also obtain information about you from other third-party services and organizations to enhance your experience.
Additionally, Properties may use additional technologies such as in-room entertainment to send service requests, which may contain Personal Data, to Vouch.
We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, Services, applications, messaging, and tools, and to recognize you across devices.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Website or Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Data. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
Personal Data. The Personal Data we collect depends on the nature of your relationship with us:
In addition, we use the Personal Data that we collect based on the following legal grounds and as necessary and appropriate for the following purposes:
To meet our legal obligations, for example:
In exceptional situations that are listed in the 3rd and 4th Schedules of the PDPA, for example:
Anonymous and Aggregated Information. We may use your Personal Data and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the services, or other analyses.
Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the services. Anonymized or aggregated information is not Personal Data, and we may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes.
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
Properties. We share Personal Data with Properties you visit, as a byproduct of their using the Vouch platform to communicate with you. We do not control the privacy practices of these Properties, and their information practices are not covered by this Policy. We recommend that you visit the privacy policies of each Property that you visit.
Authorized Third-Party Vendors and Service Providers. We share Personal Data with third-party vendors and service providers that provide business services to us or on our behalf, such as IT services, payment processing services, to market products or services or deliver ads to you, analyze activity on the services, provide content, and help to maintain our user database and administer emails, surveys, or other communications. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. We prohibit our service providers from using or sharing your Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Corporate Affiliates. We may share Personal Data with and among corporate affiliates and subsidiaries for their internal business purposes or to provide you with a product or service that you have requested.
Business Transfers. We may share Personal Data in connection with an actual or proposed change in control, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
Legal Purposes. We may disclose Personal Data to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to prevent fraud and to protect and defend the rights, interests, safety, and security of Vouch, our users, or the public.
With Your Consent. We may share Personal Data for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services, such as Facebook, Google, or Twitter, through the services to login to the services or to share information about your experience on the services with others, these third-party services may be able to collect information about you, including information about your activity on our websites or through the services, and they may notify your connections on the third-party services about your use of the services, in accordance with their own privacy policies.
Anonymous and Aggregated Information. We may share anonymous or aggregated information within Vouch and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Vouch retains the Personal Data we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
You may inquire as to whether Vouch is Processing Personal Data about you, request access to Personal Data, and ask that we correct, amend or delete your Personal Data where it is inaccurate. Where otherwise permitted by applicable law, you may contact us as described below to request access to, receive (port), seek rectification, or request erasure of Personal Data held about you by Vouch.
Vouch informs you that you are entitled to the following rights:
Rights of Access, to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Rectification, request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Erasure, request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object, to process your personal data. where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Restriction. of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent and Opting Out, you have the right to opt out of certain uses and disclosures of your Personal Data. Please note, if Vouch collected personal data about you from our Properties or on behalf of our Properties, please direct your query to the Property directly. Vouch will support our Properties as requested within a reasonable timeframe.
If you do not wish to receive marketing communications from us, you may opt out by clicking the “unsubscribe” link within the communication.
To opt out of other Personal Data processing or to raise any objections due to any dissatisfaction with our actions to your rights, contact us at email@example.com.
Lodge a complaint with a supervisory authority while we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.
Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Cookies. You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and other technologies. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.
Interest-Based Advertising. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.
Although Vouch makes good faith efforts to provide Individuals with access to their Personal Data, there may be circumstances in which Vouch is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Vouch determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Vouch will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Data.
Vouch’s Services are not directed to children under 16 and we do not knowingly collect Personal Data from children under the age of 16 without parental consent, unless permitted by law. If you are under the age of 16, you must have your parent’s permission to access the Services. If you learn that your child has provided us with Personal Data without your consent, you may contact us as described below. If we learn that a child under the age of 16 has provided us with Personal Data, we will delete it in accordance with applicable law.
Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, we currently do not take action in response to these signals.
Vouch does not store Credit Card data nor process payments. Vouch utilizes a third-party payment gateways that are responsible for securely storing your credit card data in alignment with information security requirements specified within the PCI DSS.
How do I submit a request to delete my data? You may request to review, access, change, correct, update, withdraw your consent to, or provide feedback on our use of, personal data by contacting our data protection officer at firstname.lastname@example.org (Attn: Data Protection Officer).
Opt-out of selling or disclosing your personal information Vouch does not sell or disclose your personal information for monetary gain or any valuable consideration. Vouch provides operations software to hotels and the hotels enter and use your personal information to provide services to you and other guests.
What are the categories of personal information collected? When a hotel uses the Vouch operations software or you engage in certain activities, such as requesting services from the hotel, or contacting the hotel directly, the hotel may ask you to provide some or all of the following types of information:
What is the purpose of collecting my personal information? Vouch does not use the personal information collected by the hotels about you for its own purposes.
If you are accessing the Services from outside Singapore, please be aware that your information may be transferred to, stored, and processed in Singapore.
The data protection and other laws of the Singapore and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to help ensure that your privacy is protected.
In cases where Vouch needs to transfer Personal Data outside the European Union, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, notably, the European Commission’s Standard Contractual Clauses, as applicable). We utilize Standard Contractual Clauses to ensure that all Personal Data collected in the EU is adequately handled and protected. By using the services and providing us with information, you understand and agree that your information may be transferred to and stored on servers located outside your resident jurisdiction and in Singapore by us and the third parties with whom we share it.
Some non-European Economic Area (EEA) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have ensured that adequate measures are in place, including by ensuring that the recipient is bound by EU Standard Contractual Clauses, EU-US Privacy Shield Certification, or an EU-approved code of conduct or certification, to protect your Personal Information. You may obtain a copy of these measures by contacting our data protection officer in accordance with the “Contact Us” section below.
We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Vouch has administrative, physical and technical security measures in place to protect against the loss, misuse, and alteration of the information under our control. We utilize commercially reasonable practices to protect your data.
Contact our Data Protection Officer with privacy-related questions, complaints, or requests at email@example.com.