Privacy Statement

To provide and administer our products and/or services, manage our relationship with you, facilitate and administer any transactions, bookings, reservations and other dealings with you, respond to your enquiries and requests, and fulfil our contractual, legal and other obligations arising from or in connection with our dealings with you, we may need to collect, use, disclose, retain and otherwise process your Personal Data. This may include:

1. a)

   Identification and Contact Information: including your name, address, telephone number, email address, identification and account details;

2. b)

   Identity Verification Information: including photographs, biometric information, specimen signatures and digital or electronic signatures;

3. c)

   Account Information: including your username, account credentials, account settings, preferences and information relating to your account with us;

4. d)

   Business and Account Information: including your company name, position, contact details, account information, property details, room and inventory information, rates, availability and other information relating to your business;

5. e)

   Booking and Transaction Information: including reservation details, booking information, transaction records, payment-related information and other information relating to transactions conducted through our platform;

6. f)

   Guest Information: including guest names, contact details, booking and reservation information, stay details, preferences, payment-related information and other information provided to us by you, your customers, partners or other authorised parties;

7. g)

   Application and Communication Information: including information provided in enquiries, applications, feedback, surveys, correspondence and other communications with us;

8. h)

   Usage and Technical Information: including information relating to your use of our platform, IP address, cookies, activity logs, device identifiers, online identifiers and location data; and

9. i)

   Other Information: including any other information that we may lawfully collect, process, use and/or disclose in connection with our products and/or services or as required or permitted by applicable laws and regulations.

Your Personal Data may be collected from various sources, including:

1. a)

   Directly from you: including when you create an account, use our products and/or services, make a booking or reservation, submit an enquiry, complaints, contact us, provide feedback, or otherwise interact with us in any form including SMS, phone, mobile applications, email, mail, websites, browsers, social media and/or any other channels

2. b)

   From our customers, business partners and other authorised parties: including other sources you have consented including hotels, property operators, booking platforms, online travel agencies, travel agents and other authorised parties who provide or transmit Personal Data to us;

3. c)

   Through your use of our Platform: including through cookies, pixels, activity logs, device identifiers, IP addresses, online identifiers and other tracking mechanism;

4. d)

   From publicly available or other lawful sources: including websites, public databases and other sources lawfully available to us;

5. e)

   From government authorities and regulators: where permitted or required by applicable laws and regulations.

You may also provide us with the Personal Data of a third party through the Platform. By providing such Personal Data, you represent and warrant that you have obtained the necessary consent and/or authorisation from the relevant third party to disclose their Personal Data to us and for us to collect, use and process such Personal Data for the purposes set out in this Privacy Statement.

If you provide us with any Personal Data relating to an individual below the age of eighteen (18) (“Minor”), you represent and warrant that you have obtained necessary consent from the parent, legal guardian or other person duly authorised to provide such Personal Data on behalf of the Minor, and that you have obtained all necessary consent and/or authorisation required for the disclosure of such Personal Data to us and for our collection, use and processing of such Personal Data for the purposes set out in this Privacy Statement.

The Personal Data provided to us, collected by us or obtained from other sources, as described above may be used by us for one or more of the following purposes:

1. a)

   To provide and administer our products and/or services: including providing, operating, maintaining and administering our Websites, Apps, Platforms, software and related hospitality technology solutions, processing registrations, applications, orders, requests and other transactions, and enabling our authorised employees, personnel, representatives, agents, contractors, service providers and other persons acting on our behalf to access and process Personal Data to the extent necessary for the provision and administration of our products and/or services;

2. b)

   To facilitate bookings and reservations: including facilitating and administering bookings, reservations, amendments, cancellations, check-ins, check-outs and other arrangements relating to accommodation and related services;

3. c)

   To facilitate transactions and payments: including processing payments, deposits, refunds, invoices, receipts, charges and other financial transactions relating to our products and/or services;

4. d)

   To facilitate communications and interactions: including facilitating communications, enquiries, requests, confirmations and other interactions between accommodation providers, guests, booking partners, travel agents and other relevant parties;

5. e)

   To manage accounts and business relationships: including establishing, maintaining and administering accounts, subscriptions, profiles and business relationships with our customers, accommodation providers, business partners, suppliers and other relevant parties, and updating, maintaining, consolidating and improving our records relating to such accounts and relationships;

6. f)

   To integrate with third-party systems and service providers: including integrating and exchanging information with property management systems, booking platforms, channel managers, payment service providers and other third-party systems, platforms and service providers, including for system integration, data migration and related technical and operational purposes;

7. g)

   To provide customer support and assistance: including responding to enquiries, requests, complaints, feedback and other communications, providing technical, operational and customer support, conducting data verification and validation, and conducting customer satisfaction surveys and other service-related assessments;

8. h)

   To improve and develop our products and/or services: including monitoring, analysing and evaluating the use, performance and functionality of our products, services, Websites, Apps and Platforms, understanding how you interact with and use our products and/or services, identifying usage patterns, preferences and trends, and developing, testing, improving and personalising our products, services, features and user experience;

9. i)

   For marketing and promotional purposes: including sending information relating to our products, services, promotions, offers, events and other marketing communications, where permitted by applicable laws and, where required, with your consent;

10. j)

    For business and operational purposes: including accounting, billing, auditing, record-keeping, reporting, business analysis, market research, internal administration, planning, risk management and other purposes necessary for the management and operation of our business;

11. k)

    For security, fraud prevention and risk management: including verifying accounts and transactions, detecting and preventing fraud, unauthorised access, misuse, security incidents and other unlawful or unauthorised activities;

12. l)

    To comply with legal and regulatory requirements: including complying with applicable laws, regulations, guidelines, court orders and requirements imposed by government authorities, regulators, law enforcement agencies and other relevant authorities;

13. m)

    For legal and dispute resolution purposes: including establishing, exercising and defending our legal rights and interests, protecting and enforcing our rights and those of our customers, business partners and service providers where applicable, handling complaints, claims, disputes and proceedings, recovering amounts due and owing, and obtaining legal, professional or other advice;

14. n)

    For corporate transactions and restructuring: including in connection with any merger, acquisition, restructuring, financing, sale, transfer or other transaction involving our business, assets or operations;

15. o)

    For statistical and analytical purposes: including conducting research, data mining and analysis, analysing transactions, usage patterns and trends, preparing aggregated, anonymised and/or de-identified information, and generating reports, statistics and insights for business analysis, reporting, planning, research, development and improvement of our products and/or services, where permitted by applicable laws;

16. p)

    For credit assessment and payment risk management: including conducting credit assessments, evaluating payment and repayment behaviour, assessing creditworthiness and managing payment and credit-related risks, where applicable; and

17. q)

    For other purposes: where such purposes are notified to you at the time of collection of your Personal Data or are otherwise permitted or required under applicable laws and regulations.

We may use cookies, web beacons, pixels, tags and other similar technologies on our Platforms to enhance, personalise and improve your experience, remember your preferences and settings, understand and analyse how our Platforms are accessed and used, analyse usage patterns and trends, measure the effectiveness of our products, services and communications, and support the functionality, performance and security of our Platforms. Cookies and similar technologies may also be used to recognise your device, maintain session information, facilitate certain features and functionality, and assist us in understanding and improving the performance and use of our products and/or services. You may adjust your browser or device settings to manage, restrict or disable cookies and similar technologies. However, disabling or restricting certain cookies may affect the functionality, performance or availability of certain features of our Websites, Apps or Platforms.

In connection with the purposes set out above, we may use automated processing technologies, including artificial intelligence, machine learning and other automated tools, where appropriate, in connection with the operation, provision, administration and improvement of our products and/or services through our Platform. Such technologies may be used for purposes including analysing usage patterns and trends, personalising and improving user experiences, providing recommendations or relevant content, detecting and preventing fraud, security threats and unauthorised activities, providing customer support, automating or assisting with business and operational processes, and improving the performance, efficiency, functionality and security of our products and/or services through our Platform.

For the purposes set out above, we may process and disclose such Personal Data in accordance with our customers’ instructions and the terms governing our relationship with them, including for the purposes of providing, operating, maintaining and supporting our Platform and related products and/or services. In such circumstances, the relevant customer, accommodation provider or business partner may determine the purposes for which such Personal Data is processed, and we will process such Personal Data only to the extent necessary to perform our contractual obligations and provide the relevant products and/or services, or as otherwise permitted or required under applicable laws.

In addition, your Personal Data may be shared with:

1. a)

   Our related companies and affiliates: including our holding companies, subsidiaries, associated companies and other entities within our corporate group;

2. b)

   Our employees, personnel, representatives and agents: including our authorised employees, personnel, representatives, agents and contractors who require access to your Personal Data for the purposes of performing their duties and providing or administering our products and/or services;

3. c)

   Our service providers and third-party vendors: including technology providers, software providers, cloud service providers, hosting providers, data centres, system integrators, payment service providers, customer support providers, analytics providers, marketing service providers and other third parties engaged to support our business operations and the provision of our products and/or services;

4. d)

   Accommodation providers, customers and business partners: including hotels, resorts, accommodation providers, property managers, booking partners, travel agents and other business partners where disclosure is necessary to facilitate bookings, reservations, transactions, communications, service delivery or other dealings undertaken through our Platform;

5. e)

   Third-party systems and platforms: including property management systems, booking platforms, channel managers, distribution platforms and other third-party systems, platforms and applications which are integrated with or connected to our Platform, where necessary to facilitate the provision of our products and/or services;

6. f)

   Financial institutions and payment service providers: including banks, payment processors, payment gateways and other financial institutions or service providers involved in processing or facilitating payments, refunds, settlements and other financial transactions;

7. g)

   Professional advisers and persons providing professional services: including our lawyers, solicitors, accountants, auditors, tax advisers, consultants and other professional advisers, as well as their respective employees, agents and service providers, where necessary for the provision of their professional services to us;

8. h)

   Government authorities, regulators and law enforcement agencies: including government departments, regulatory and statutory authorities, law enforcement agencies, courts, tribunals, dispute resolution bodies and their respective officers, representatives or appointed agents, where disclosure is required or permitted under applicable laws or in connection with any legal or regulatory process;

9. i)

   Fraud prevention, risk management and debt recovery parties: including fraud prevention agencies, credit reference agencies, debt recovery agents and other persons or organisations engaged by us for the purposes of fraud detection and prevention, credit or payment risk management, debt recovery or protection of our rights and interests, where applicable;

10. j)

    Persons involved in legal proceedings or the protection of our rights: including any person, organisation or entity where disclosure is necessary to establish, exercise, protect or defend our legal rights and interests, enforce any agreement with you, investigate or prevent suspected fraud or unlawful activities, or respond to any claim, complaint, dispute or proceeding;

11. k)

    Parties involved in corporate transactions: including actual or prospective purchasers, investors, financiers, lenders, advisers, professional consultants and other parties involved in or considering any merger, acquisition, restructuring, financing, sale, transfer, assignment or other transaction involving our business, assets or operations, subject to appropriate confidentiality arrangements where applicable;

12. l)

    Persons authorised by you: including any person or entity whom you have authorised to act on your behalf or to whom you have authorised us to disclose your Personal Data in connection with your account, bookings, transactions, products and/or services; and

13. m)

    Other persons or entities: where you have provided your consent, where disclosure is notified to you at the time of collection of your Personal Data, or where disclosure is otherwise permitted, required or authorised under applicable laws and regulations.

We may transfer, store, access or otherwise process your Personal Data outside Malaysia where necessary for the provision of our products and/or services or for the purposes set out in this Privacy Statement. Where such transfer takes place, we will take reasonable and appropriate steps to ensure that your Personal Data remains protected and is processed in accordance with this Privacy Statement and applicable data protection laws, including, where required, conducting appropriate assessments and implementing contractual or other legal safeguards. We also implement appropriate physical, administrative and technical safeguards to protect your Personal Data against loss, theft, misuse, unauthorised or accidental access, disclosure, alteration, destruction or other unlawful processing.

Where AI systems are used to process Personal Data, we will take appropriate measures to promote the security, fairness and transparency of such processing and ensure that such systems are operated in accordance with applicable legal and regulatory requirements. Our employees and personnel are also required to comply with applicable data protection and confidentiality requirements and may be subject to disciplinary action for any breach of our policies.

We will retain your Personal Data for as long as is reasonably necessary to fulfil the purposes for which it was collected, including throughout the duration of our contractual or business relationship with you and, following the expiry or termination of such relationship, for such further period as may be necessary to comply with our legal, regulatory, accounting or reporting obligations, resolve disputes, establish, exercise or defend our legal rights and interests, prevent fraud or misuse, or for other legitimate business purposes or purposes set out in this Privacy Statement. Once your Personal Data is no longer required for any of these purposes, we will take reasonable steps to securely delete, destroy or anonymise such Personal Data in accordance with our internal retention policies and applicable laws.

You may request access to your Personal Data held by us and request correction of any Personal Data which is inaccurate, incomplete, misleading or not up to date, subject to applicable laws. We may require information or supporting documents to verify your identity and the nature of your request. We will process your request within the timeframe prescribed by applicable laws and may impose any applicable fees or charges permitted by law. We may refuse or limit a request where permitted or required by applicable laws.

Where the processing of your Personal Data is based on your consent, you may withdraw your consent or request that we cease or restrict certain processing by contacting us using the contact details set out in this Privacy Statement. Any withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal. We may continue to process or retain your Personal Data where permitted or required by applicable laws, including where necessary to comply with legal or regulatory obligations, fulfil contractual obligations, establish, exercise or defend our legal rights and interests, or prevent fraud or misuse. Withdrawal of consent or restriction of processing may affect our ability to provide certain products and/or services to you.

Where applicable under the PDPA and any regulations, standards or guidelines made thereunder, you may request that your Personal Data be transmitted to another data controller in a structured, commonly used and machine-readable format, subject to the applicable requirements, limitations and exceptions.

Where your Personal Data is processed through automated decision-making systems, artificial intelligence, machine learning or other automated technologies, such processing will be carried out in accordance with applicable laws and regulatory requirements. Where consent is required by applicable laws, including in circumstances involving sensitive Personal Data, we will obtain the necessary consent before carrying out such processing. Where such processing is based on your consent, you may withdraw your consent in accordance with provision provided in this Privacy Statement.

To exercise any of your rights or make any enquiry or complaint regarding the processing of your Personal Data or enquiries pertaining to how we handle your Personal Data, you may contact us at the contact point as described below and we may require additional information to verify your identity and process your request.