Our business is built on the trust our customers place in us. We respect our customers' privacy, and we are committed to safeguarding and keeping any information relating to them, confidential.
We process personal data based on your consent according to the applicable clauses of the PDPA, which you are free to give or refuse. You are free to revoke your consent for us to hold this information at any time. If you change your decision, it will not affect the lawfulness of processing based on consent before its withdrawal.
What information do we collect?
- We collect information you share with us when you register on our site, place an order, subscribe to our newsletter, respond to a survey, or fill out a form. You may be asked to provide: name, e-mail address, mailing address, phone number, country of residence, passport issuing country or credit card information.
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except were permitted or authorised by law).
- We retain your personal data for only as long as is necessary for our business and limit the use of your personal data to that use which is essential to perform reasonably expected services or as required by law. Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., race, religious, ethnicity, medical or health information, sexual orientation etc.).
What do we use your information for?
- Any of the information we collect from you may be used in one of the following ways:
We may disclose your personal data
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you
- verifying your identity.
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
- managing your relationship with us.
- sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, membership and rewards schemes and other promotions.
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
- any other purposes for which you have provided the information.
- 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; and
- any other incidental business purposes related to or in connection with the above.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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)
- where such disclosure is required for performing obligations during or in connection with our provision of the goods or services requested by you; or
- to third party service providers, agents, and other organizations we have engaged to perform any of the functions listed above.
How do we protect your information?
We use a secure server and are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration
Sensitive credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential. After a transaction, sensitive credit information (credit cards, financials, etc.) will not be stored on our servers.
Do we disclose any information to third parties?
We disclose your personal information to the following parties and in the following circumstances:
To third parties only if you are staying in one of our accommodations and would like us to arrange further services e.g., airport transfers, private chefs.
To allow third party vendors, consultants and other service providers to perform services on our behalf.
To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities.
To cooperate with regulatory bodies and government authorities.
To third parties in order for us to pursue available remedies, or limit damages that we may sustain.
To a third party in the event of any reorganisation, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
To include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
What are your legal rights?
You have the right to:
Request 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
Request correction of the personal data that we hold about you. 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.
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 processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios
Request the transfer of your personal data to you or to a third party. 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; we are relying on consent to process your personal data. Should you wish to withdraw your consent, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Opt-out; You can ask us to stop sending you marketing messages at any time by following the opt-out unsubscribe links on any marketing message sent to you or by contacting email@example.com. Where you opt-out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of arrangements or other such transactions
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful, but you do not want us to erase it
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still place orders by contacting firstname.lastname@example.org.
Terms and Conditions
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at https://www.elitehavens.com/terms.aspx.
For any other general matters you can further contact us at:
Private Homes and Villas PTE. LTD.
100 Tras Street,
#16-01 100 AM
This policy was last modified on 7 September 2023