Overview. CDL Hospitality Trusts ("CDLHT") is a stapled group comprising CDL Hospitality Real Estate Investment Trust ("H-REIT"), a real estate investment trust, and CDL Hospitality Business Trust ("HBT"), a business trust.

This Privacy Policy (“Policy”) applies to personal data collected by M&C REIT Management Limited (acting as manager for H-REIT) and/or M&C Business Trust Management Limited (acting as trustee-manager for HBT) (collectively, the “Managers”), whether through this website (“Site”) or otherwise.  Please read this Policy to understand how the Managers may collect, use and disclose your personal data.

Consent. By accessing this Site and/or providing personal data (whether through this Site or otherwise), you hereby acknowledge that you have read this Policy and that you consent to the collection, use and disclosure of your personal data by the Managers in accordance with this Policy.  If you do not consent to the terms of this Policy, please do not access this Site or provide your personal data.

Collection of Personal Data. The Managers collect personal data that you voluntarily provide when you use this Site or otherwise.  At various places on the Site, certain personal data may be requested such as your full name, email address, country of residence, profession, job industry and other personal information. You may choose to provide your personal data in order to access or use certain features or services of the Site, such as receiving email alerts. Where possible, fields of information which are required and fields which are optional will be indicated. You can always choose not to provide information, but you may not be able to use a particular service or feature on the Site.

In addition, the Managers collect information that is sent automatically by your web browser, computer, mobile or tablet device.  This may include your IP address, the address of the web page you were visiting when you accessed our Site, date and time of your visit and other information.  Please check the settings of your browser and/or device if you want to know what information is automatically sent or if you wish to change your settings.  Please also refer to the section on “Use of Cookies” below.

Use of Personal Data. Personal data collected by the Managers may be used:

1. 4.1to provide products or services to you;
2. 4.2to communicate with you;
3. 4.3to improve our products or services;
4. 4.4to advise you of other products and services, which may be of interest to you;
5. 4.5to conduct marketing research, user profile and statistical analysis;
6. 4.6to verify and process your personal particulars and payments;
7. 4.7to process, record, execute, monitor, and/or archive your requests and transactions;
8. 4.8to customise your online experience according to your chosen interests and preferences and enhance your current and future visits to the Site;
9. 4.9to update our records;
10. 4.10to detect and protect us against error, fraud and other criminal activity;
11. 4.11to comply with law, the requests of law enforcement and regulatory officials, or orders of court;
12. 4.12to enforce our legal rights and remedies; or
13. 4.13for such other purposes as may be notified to you on or before collection or use of the data.

Disclosure to Third Parties. Your personal data will not be disclosed by the Managers to any other third party, unless the Managers have obtained your consent, or the Managers are under either a legal or regulatory obligation or any other duty to do so.  Notwithstanding the foregoing, the Managers may disclose your personal data to the individuals and entities listed below:

1. 5.1any entity within the CDLHT group, including their managers or trustees;
2. 5.2any third party service provider which hosts or manages data from this Site;
3. 5.3lawyers;
4. 5.4auditors;
5. 5.5any other agents, service providers or subcontractors acting for or on behalf of the Managers; or
6. 5.6government or regulatory authorities,

to the extent required in the normal course and scope of our business as a real estate investment trust, and where required or permitted by applicable law, statute, stock exchange regulation or by-law, regulatory or governmental order or court order.

Cross-border transfer. Your information will not be transferred to third parties outside Singapore except in accordance with the requirements prescribed under the Personal Data Protection Act (No. 26 of 2012) (“PDPA”).

Retention. Personal data provided by you will be retained as long as the purpose for which the data was collected continues.  Thereafter, the Managers will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect CDLHT's or the Managers' interests.

Security measures.

1. 8.1The Managers put in place reasonable security arrangements (which shall at least be equivalent to industry standard practices) to protect your privacy and personal data, in such manner and to such extent as we deem reasonably appropriate to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, there is no such thing as "perfect security" and the Managers do not warrant or guarantee in any way, and you should not expect, that your personal information or private communications will always remain private and/or safe from any abuse or misuse by third parties.
2. 8.2The Managers do not represent or warrant that there will not be, and hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any personal data held or maintained by us.

Linked Sites. The Managers may provide links to other sites ("Linked Sites") that may be of relevance and interest to you.  The Managers have no control over, and are not responsible for the privacy practices or the content of such Linked Sites, and you hereby waive any claim against us with respect to the Linked Sites.

Use  of Cookies.  In order to improve our products and services, we collect data anonymously by way of “cookies.”  Cookies help us measure the number of visits, average time spent, page views and other statistics relating to your access to this Site.  This information allows us to better administer the Site and provide a more tailored and user-friendly service to our Site visitors.  Cookies are small data files that are sent to your browser from our Site and are stored on your computer’s hard drive.  Each time you visit our Site from the same computer, the cookie will be retrieved from your computer, enabling our Site to recognise your computer as having previously visited our Site and thereby increase the functionality of our Site on your computer.  Our cookies cannot be used to get data from your hard drive, to get your email address or any other data that can be traced to you personally.  Most web browsers can be set to notify you when you receive a cookie or to prevent cookies from being sent; if you use these features, you may limit the functionality we can provide you when you visit our Site.

Access & Correction of Data.   You may request to access or correct your personal data that is in the control or possession of the Managers, or enquire about the ways in which your personal data may have been used or disclosed by the Managers within a year of the date of your request by contacting us at dataprotection@cdlht.com.

To enable us to process your request efficiently, please provide the following information:

• your name, contact number, email address and address;
• details of the personal data that you would like to access or correct;
• relevant time frames and dates, where applicable; and
• any other information that may enable us to locate your data and process your request.

We will endeavour to respond to your request as soon as possible. You agree that we may need to check and verify your identify and may contact you for further information.

We reserve the right to charge a minimal fee for processing your request, depending on the nature of your request. If applicable, we will inform you of the applicable fees and payment must be received by us before we proceed further with your request.

We reserve the right to refuse to provide access to your personal data, or correct your personal data, where this is required or permitted under the PDPA, its related subsidiary legislation, or any other applicable law.

Complaints, Feedback & Enquiries. Please direct any complaints, feedback or enquiries you may have regarding the collection, use and/or disclosure of your personal data by the Managers to:

The Data Protection Officer
Email: dataprotection@cdlht.com

Please provide the name, contact number, email address and address of the person submitting the complaint, feedback or enquiry. Please also provide the relevant details pertaining to such complaint, feedback or enquiry such as the relevant time period, our employees or personnel involved, or copies of relevant documents, if applicable.

We will endeavour to review and respond to all complaints, feedback and enquiries in a timely manner.

Right to amend Policy. The Managers reserve the right to amend the prevailing Privacy Policy at any time and will place any such amendments on this Site.

Governing Law. This Policy is governed by and shall be construed in accordance with Singapore law including without limitation the provisions of the Evidence Act (Chapter 97), Electronic Transactions Act (Cap. 88) and the PDPA, without giving effect to any principles of conflicts of law.  By accessing this Site and/or providing personal data (whether through this Site or otherwise), you submit to the non-exclusive jurisdiction of the Singapore courts.