Privacy Policy

1 General

This Privacy Policy applies to all EVT Group businesses in Australia and New Zealand, including our cinemas, hotels, resorts, the State Theatre, the Thredbo Alpine Resort, and our Cinebuzz and EVT Stays loyalty programs.

1.1. This privacy policy (“Privacy Policy”) sets out the basis on which the hotel owner, Phoenix 35 Pte Ltd and the hotel manager, EVT Hotels Asia Pte Limited, and their affiliates and subsidiaries (collectively, “us”, “we” or “our”) may collect, use, disclose, or otherwise process the data, whether true or not, about you who can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access (“Personal Data”) of our QT Singapore hotel guests, customers, vendors, suppliers, partners, contractors or users of our Services (as defined below). We respect your privacy and are committed to handling your Personal Data in accordance with the Personal Data Protection Act 2012 of Singapore, as may be amended from time to time (“PDPA”).

1.2. This Privacy Policy governs the use of this website, accessible at  https://qthotels.com/Singapore  (“Website”) and our related mobile and web software applications for the QT Singapore hotel (collectively, our “Apps”) and as well as all QT Singapore hotel related products and services offered or provided by us, whether via the Website or at the QT Singapore hotel (collectively, “Services”). By accessing, visiting, or using the Website or our Apps, contacting or interacting with us, submitting information to us, purchasing or obtaining any Services from us, or providing any product or service to us, you agree to be bound by the terms of this Privacy Policy and are deemed to have notice of this Privacy Policy.

2. Types of Personal Data We Collect

2.1. This Privacy Policy applies to the Personal Data in our possession or under our control, including Personal Data in the possession of third parties which we have engaged to collect, use, disclose or process the data for the purposes stated in Clause 4.1.

2.2. Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).

2.3. At various points during your guest journey, we collect Personal Data in accordance with law, in order to provide you the Services. We may collect and process the following types of Personal Data about you:

2.3.1. Name;
2.3.2. Age;
2.3.3. Gender;
2.3.4. Email address;
2.3.5. Mailing address;
2.3.6. Telephone number;
2.3.7. Financial information (such as bank and credit or debit card details or other payment data);
2.3.8. Language preference;
2.3.9. Date and place of birth;
2.3.10. Nationality, passport, visa or other government-issued identification data;
2.3.11. Details of your booking made through any booking engine;
2.3.12. Membership or loyalty program data (including travel partner program affiliations);
2.3.13. Employer details (for business-related bookings);
2.3.14. Prior guest stays or interactions, goods and services purchased, special amenity or services requests;
2.3.15. Travel itinerary, tour group or activity data;
2.3.16. Internet or Wi-Fi activity information, including but not limited to information regarding your use of the Website or Apps, such as your IP address and session ID;
2.3.17. Information about your “stay preferences”, including but not limited to:
(i) your interests and other relevant information that we learn about you during your stay, including any feedback about our Services that you tell us about;
(ii) specific health and dietary restrictions or personal needs;
(iii) your important dates, such as anniversaries and special occasions; and
(iv) details about who you usually travel with, their relationship to you, and your marital status.
2.3.18. We may also collect (i) biometric data, (ii) data about your family members and companions, names and ages of children, and/or (iii) images, video and audit data, via security cameras located in public areas in our property and body-worn cameras carried by our security personnel.

2.4. If you provide any Personal Data about any other individuals to us (such as making a booking for another individual), you represent and warrant that you have the authority to do so and you permit us to collect, use and disclose such Personal Data in accordance with this Privacy Policy.

2.5. If you provide the Personal Data of a minor to us, you represent and warrant that you are the parent or legal guardian of such minor, and hereby consent to the collection, use, and processing of the minor’s Personal Data in accordance with this Privacy Policy.

2.6. If you are a minor or not of legal age, please inform and seek the consent of your parent or guardian, before you provide your Personal Data to us. If you are a parent or guardian and have reason to believe that your child or ward has provided us with their Personal Data without your consent, please contact us to request for deletion of his or her personal data.

3. How We Collect Your Personal Data

3.1. We collect your Personal Data in different ways, which include but are not limited to the following:
3.1.1. when you visit or connect with us through our Website, our pages on social media or through our Apps;
3.1.2. when you contact us for queries;
3.1.3. when you request us to contact you;
3.1.4. when you access or purchase our Services or request any other form of assistance;
3.1.5. when you enter into an agreement or contract with us in relation to our Services;
3.1.6. when we generate or derive information about you based on our analysis of the data we collect, or from combining such data with other data or information in our possession, such as data provided to us by any of our Business Partners. “Business Partner” refers to any partner, collaborator, individual or organisation who has entered into an agreement with us to manage a business or to share responsibilities or resources for the purposes of a business venture or collaboration;
3.1.7. when you register for an account (“Guest Account”), whether such account is created on the Website to facilitate purchases, reservations or bookings, our Apps or via any of our Business Partners’ websites, which are then redirected to the Website;
3.1.8. when you apply to be a member of our loyalty programs, respond to our promotions, subscribe to our mailing list;
3.1.9. when you use your loyalty program number to receive or register for certain third party services. This could include businesses such as airlines or car rental providers. You may choose to link your loyalty program number to your social media account, which will enable us to disclose your Personal Data to those third parties. If you do not wish for us to disclose your Personal Data in this way, please do not provide your loyalty program number to third parties;
3.1.10. when you report a problem with the Website or our Apps;
3.1.11. when you register for, attend or participate in our events, programmes, surveys, contests, or games, whether held in-person or virtually, and your images are captured via photographs or videos taken by us or our service providers;
3.1.12. when you use the spa, restaurant, health club, concierge or other outlet at our property;
3.1.13. when you use an internet-connected device at our property which is connected to the property’s Wi-Fi network; and
3.1.14. when you provide your Personal Data to us for any other reason.

4. Purposes of the Collection, Use, and Disclosure of Personal Data

4.1. We collect, retain, use, and process your Personal Data for the following purposes:
4.1.1. undertaking any dealings or transactions with you, including but not limited to booking and guest registration;
4.1.2. performing obligations in the course of or in connection with providing Services to you;
4.1.3. performing check-in or check-out services, including processing payment, providing advice about services available during your stay and making arrangements with third party providers;
4.1.4. facilitating access to our property’s Wi-Fi network;
4.1.5. facilitating in-room dining services and recording guest preferences related thereto;
4.1.6. facilitating housekeeping services and recording guest preferences related thereto;
4.1.7. handling any guest requests and processing queries, complaints, or feedback from you;
4.1.8. assessing eligibility for age-restricted goods, as requested, including alcohol and in-room adult entertainment;
4.1.9. communicating with guests about conferences or other event planning (“Events”), including but not limited to the reservation of the Events, the planning and preparation for the Events, and the billing and recovery of amounts owed;
4.1.10. facilitating guest reservations for our spa, beauty and fitness services and other facilities, and providing the activities with the appropriate adjustments for guests, including any requested personalisation;
4.1.11. facilitating guest reservations for any restaurant or in-room dining and, in connection therewith, honouring dietary requirements and providing a personalised service based on past reservations or orders;
4.1.12. facilitating any child-related services requested by guests, including but not limited to babysitting and use of the kids club (if applicable and available from time to time), coordinating reservations, bookings or dining services in accordance with guest preferences;
4.1.13. registering users in the loyalty program and associated activities, including but not limited to determining guest eligibility for the loyalty program, administering the loyalty program and providing a consistent and personalised service based on past usage and guest preferences, and notifying guests of changes to the loyalty program;
4.1.14. providing marketing services to guests and prospective guests including communicating with guests and potential guests about Services that may be of interest to them and personalised advertisements for products on third-party websites;
4.1.15. verifying your identity;
4.1.16. managing your relationship with us;
4.1.17. internal record-keeping;
4.1.18. processing billing, payment, or credit transactions, including but not limited to payment for bookings, reservations, your use of our Services or that of third-party providers’ services or facilities;
4.1.19. administering customer care services to our guests, whether in response to a request, query or complaint made in person, through the Website or the Apps, by phone, by email or via social media;
4.1.20. monitoring, responding to, handling and recording any accidents which take place at our property and facilitating in-house doctor services or requesting assistance from the emergency services as appropriate;
4.1.21. monitoring our property through CCTV or other method in order to be able to respond to accidents or other incidents;
4.1.22. sending you advertising and/or promotional material for our Services, special offers, marketing events, initiatives, membership and loyalty programs, and other promotions;
4.1.23. conducting joint marketing with other service providers;
4.1.24. ensuring the content of the Website and our Apps is presented in the best way for a user and the user’s computer or mobile device;
4.1.25. maintaining or improving the Website and our Apps including the content, appearance, design, utility, and performance thereof;
4.1.26. improving, enhancing, or developing new products and services or new methods of processes for our business operations;
4.1.27. conducting research in relation to our Services and the needs of our guests;
4.1.28. identifying products or services that may be suitable for you and/or personalising or customising such products and/or services, including customising pages for you;
4.1.29. notifying you of updates to the Website or our Apps;
4.1.30. performing statistical analysis of your behaviour and characteristics in order to measure interest in and use of our Services and various features of the Website and our Apps, and providing such information in anonymised form to advertisers together with anonymised information as to the number of users that have been exposed to or clicked on their banners;
4.1.31. complying with legal processes, complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority, meeting national security or law enforcement requirements, enforcing the terms and conditions applicable to the provision of our Services to you, protecting our operations and the rights, privacy and safety of EVT, our guests, visitors and other relevant individuals;
4.1.32. conducting investigations and proceedings in the event of any disputes, possible fraud, misconduct, unlawful action, or omission;
4.1.33. enforcing any legal or other rights we may have in any manner that we see fit;
4.1.34. any other purposes for which you have provided the Personal Data;
4.1.35. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
4.1.36. any other incidental business purposes related to or in connection with the above; and
4.1.37. any other specific purpose which we may inform you of in writing from time to time, but for which we will seek your separate consent.

4.2. We may disclose your Personal Data:
4.2.1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you;
4.2.2. to other members of our group for the purpose of, inter alia, providing a consistent and personalised service to guests and for the purposes or completing reservations with another property within our group;
4.2.3. to third party service providers, agents and organisations we have engaged to provide any of the Services or perform any of the functions listed in Clause 4.1 above on our behalf, including but not limited to on-property service providers (including the spa, restaurant, health club or concierge), external professional service providers, travel providers, travel insurance providers, service providers that we partner with to provide services via the use of your loyalty program number (such as airlines, car rental, restaurant reservations) or linked accounts (such as when you log into your Guest Account using your social media account), email service vendors, website hosting, automated chat functionalities, cloud service providers, payment service providers, IT, customer service, marketing and auditing and delivery service providers;
4.2.4. to our suppliers, partners or contractors in connection with services they perform for us or pursuant to our agreements with them;
4.2.5. to enforce or apply our terms or other contractual rights or pursue any action or remedies;
4.2.6. to investigate fraud or comply with a court order or legal process served on us;
4.2.7. where required under the law to the relevant authorities, statutory boards, or law enforcement agencies;
4.2.8. to any other party whom you give your consent for us to disclose your Personal Data; and
4.2.9. any other purpose permitted under applicable laws.

4.3. The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

4.4. In certain circumstances, we may need you to provide your Personal Data where it is necessary to conclude a contract with you, or to comply with legal requirements and other contractual obligations. Failure to sufficiently provide such Personal Data, under such circumstance, may be deemed to be a failure to comply with legal requirements or contractual obligations, or may result in us being unable to conclude a contract with you, as the case may be. In such event, we may not be able to provide you with the information or any of the Services that you request from us, or to accept your application for registration of a Guest Account.

5. Cookies

5.1. Cookies are small data files that are stored by your computer’s web browser. A cookie file may contain certain information about your usage of the Website, such as a user identification code or IP address, or the number of times you have visited.

5.2. We use cookies to allow us to gather statistics on and better understand how you use the Website, enable the efficient operation of the Website, and improve the use of the Website.

5.3. By using the Website, you consent to our use of cookies and similar technologies.

5.4. You may be able to refuse or disable cookies by adjusting your web browser settings. Please refer to the instructions provided by your web browser. Please note that certain functionalities on the Website may no longer function for you if you choose to refuse or disable cookies.

6. Retention of Personal Data

6.1. We will retain your Personal Data for so long as it is necessary to fulfil any of the purposes for which it was collected, and to satisfy our business, compliance, and legal purposes, including archival, audit, accounting, or reporting requirements as required or permitted by applicable laws.

6.2. In order to determine our retention period for Personal Data, we will consider:
6.2.1. the length of our relationship with you (for example the length of time from when you first create an account or purchase any of our Services);
6.2.2. any legal obligation applicable to us (for example the length of time for which we must retain a record of any transaction completed by us); and
6.2.3. whether it is reasonable to retain it to protect our legal position (considering, for example, the statute of limitations, litigation or regulatory investigations).

6.3. We do not sell your Personal Data to any third party.

6.4. In some circumstances, we may anonymise your Personal Data so that it will no longer identify you.

7. Protection of Personal Data

7.1. We will put in place reasonable security measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction.

7.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage can be completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

7.3. You are responsible for keeping your login information and password for your Guest Account confidential.

7.4. We are not responsible for the personal data policies, procedures and practices of any entities outside our group, or any third-party service provider or social media platform provider to which our Website may link to. The inclusion of a link to a third-party website on our Website does not imply endorsement of such linked site.

7.5. If you believe that your use of the Website is no longer secure, you can notify us through the “Get in touch” section on our Website.

8. Withdrawal of Consent

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

8.2. You may, at any time, withdraw your consent in relation to the collection, use, disclosure, and retention of your Personal Data, by writing to the Data Protection Officer at the contact details provided in Clause 12 below.

8.3. 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, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it or such longer period that we may notify you of.

8.4. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Clause 12 below.

8.5. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

9. Access to and Correction of Personal Data

9.1. If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request to our Data Protection Officer at the contact details provided in Clause 12 below.
9.2. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable laws).

10. Accuracy of Personal Data

10.1. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete, and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing at the contact details provided in Clause 12 below.

11. Transfer of Personal Data outside of Singapore

11.1. We are a global organisation, and transferring data internationally is essential to our provision of our Services to you, so that you experience high-quality service wherever you are located. By making a reservation, visiting, or staying at the QT Singapore hotel using any hotel service, you understand that we may transfer your Personal Data globally and accordingly, subject to applicable law, we may transfer your Personal Data collected in connection with the Services to recipients in countries where data protection standards may differ from those in the country where you reside, including to countries outside Singapore. Before transferring any Personal Data outside Singapore, we will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to that under the PDPA.

12. Data Protection Officer

12.1. If you wish to access your Personal Data, correct any Personal Data in our possession, withdraw your consent for the collection, use, and disclosure of your Personal Data, or if you have any queries or feedback on this Privacy Policy, please contact our Data Protection Officer in the following manner:

Attention: Data Protection Officer
Email Address: [email protected]

13. Variation of Privacy Policy

13.1. We may amend this Privacy Policy from time to time, without any prior notice to you. The amended Privacy Policy will supersede the earlier versions of the Privacy Policy and will apply to Personal Data provided to us previously. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of the Website, our Apps or our Services constitutes your acknowledgement and acceptance of such changes and notice of this Privacy Policy.

14. Applicable Law

14.1. This Privacy Policy shall be governed by the laws of Singapore.

Updated May 2024