Privacy Policy

Personal Data Protection is important to us

Your privacy and the protection of your Personal Data is important to us. This Privacy Policy (“Policy”) outlines how we manage the Personal Data we hold. The Policy applies to all departments of by Xynez LLP (Reg. No. T11LL2018C), and/or its related corporations and affiliates (referred to hereunder as “”, “Xynez”, “we”, “us” or “our”) collectively or singularly as the context requires, recognise the importance of protecting Personal Data.

We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

We collect Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose. We do not collect Personal Data randomly or indiscriminately without purpose.
We do not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data.

You agree and consent to us, collecting, using, storing, processing, disclosing and sharing amongst ourselves your Personal Data as data controllers, and disclosing such Personal Data to our authorised service providers and relevant third parties as data controllers and/or data processors as appropriate in the manner set forth in this Policy. By accessing and using any websites of, interacting with us, or providing your data to us, and subject to your rights at law, you accept and agree to these terms and conditions without any limitation or qualification.

Please note that depending on the jurisdiction in which your Personal Data is being collected, used, disclosed or processed by us, different country-specific addenda may apply. If your Personal Data has been collected, used or disclosed by us in a particular country, you should check the terms of the country-specific addenda to see if there is a country-specific addendum applicable to you and the collection, use, disclosure and processing of your Personal Data. The terms set out in the addenda are in addition to the terms set out in this Policy and form a part of this Policy.

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data. may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our websites. Please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, nothing in this Policy establishes any joint and several liability on the part of This Policy forms a part of our Terms and Conditions. In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Terms and Conditions, the Privacy Policy shall prevail. All defined terms contained in the Terms and Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1. Your Personal Data
1.1. “Personal Data” refers to any data or information about you from which you 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. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):
a) your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
b) information about your use of our websites and services, including cookies, IP addresses, subscription account details and membership details;
c) your employment history, education background, and income levels; and
d) your payment related information, such as your bank account or credit card information, and your credit history.

2. Collection of Personal Data
2.1. Generally, we collect your Personal Data in the following ways:
a) when you submit forms relating to any of our products or services, or submit any online queries;
b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us;
c) when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online forms (such as any “Contact Us” forms on our websites), reservation chat, social media platforms and emails;
d) when you use or purchase our services or products;
e) when you establish any online accounts with us;
f) when you request that we contact you;
g) when you respond to our request for additional Personal Data;
h) when you ask to be included in an email or other mailing list;
i) when you respond to our promotions and other initiatives;
j) when you respond to our market surveys;
k) when you submit a job application or a scholarship application;
l) when we receive references from business partners and third parties, for example, where you have been referred by them;
m) when you submit your Personal Data to us for any other reason; and
n) when you browse our website. Please refer to the Cookie Policy below at paragraph 6 for more information.
2.2. We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes.
2.3. If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.

3. Use and Disclosure of Personal Data
3.1. Our business is to understand and meet your needs and provide you with the products and services that you require. To do this effectively, we need to collect a range of Personal Data about you.
3.2. In general, we use and disclose your Personal Data for the following purposes:
a) to provide you with the products or services that have been requested;
b) to help us review, develop, improve, manage the delivery of and enhance our products and services, including analysing future customer needs, conducting market research and data analytics;
c) to communicate with you and respond to your queries, requests and complaints;
d) to provide ongoing information about our products and services which may be of interest to you;
e) to handle disputes and conduct and facilitate investigations and proceedings;
f) to protect and enforce our contractual and legal rights and obligations;
g) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
h) to manage our infrastructure and business operations and to comply with internal policies and procedures;
i) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any entity related to; and
j) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
3.3. In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
a) If you have a membership account with us:
(i) to process your application for the account;
(ii) to maintain your account with us;
(iii) to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;
(iv) to provide you with the goods and services which you have signed up for;
(v) to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) to resolve complaints and handle requests and enquiries;
(vii) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) to process your Personal Data in relation to any of the purposes stated above.
b) If you download or use any of our mobile applications (apps):
(i) to process your application for subscription services if they are provided in the apps;
(ii) to maintain your account with us;
(iii) to verify and process your personal particulars and process payment requests in relation to provision of goods and services connected to the app;
(iv) to provide you with the goods and services which you have signed up for;
(v) to communicate with you changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) to resolve complaints and handling requests and enquiries;
(vii) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) to process your Personal Data in relation to any of the purposes stated above.
c) If you are a vendor, a prospective vendor or a contractor:
(i) to evaluate your proposal and to conduct background checks on you;
(ii) to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
(iii) any other purpose directly relating to any of the above.
d) If you submit an application to us as a candidate for employment:
(i) to process your application including pre-recruitment checks;
(ii) to provide or to obtain references for background screening/vetting;
(iii) to collect information about your suitability for the position applied for;
(iv) to organise training and staff development programs;
(v) to assess your performance;
(vi) to administer benefits and payroll processing;
(vii) to provide you with tools to facilitate or as required for you to do your job;
(viii) to communicate with you to comply with our policies and processes, including for business continuity purposes; and
(ix) any other purposes relating to the aforesaid.
e) If you are an existing employee,’s Employee Personal Data Protection Policy would also apply to you.
3.4. The above purposes are not exhaustive, and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.
3.5. When you apply for or hold a co-brand product which is offered jointly by us and our co-brand partner(s), we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the co-brand partners for offering, marketing and promoting to you any products, services, offers or events which the co-brand partner thinks may be of interest to you.
3.6. Where you have provided us with specific consents, we may also use and disclose your Personal Data for the following purposes:
a) providing services and extending benefits to you, including promotions, loyalty and reward programmes, and sending you industry market updates (e.g. in lifestyle related industries such as yachting etc), newsletters (e.g. on yachting) and other information on our products, services, offers or promotions which may be of interest to you;
b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or third parties;
c) administering contests, competitions and conducting lucky draws, including, where necessary, announcing the results of these contests, competitions and lucky draws and identifying and contacting the winners; and
d) conducting market research to understand and determine customer locations, preferences and demographics for us to develop special offers, promotional and/or marketing programmes.
3.7. In relation to particular products or services or in your interactions with us, we may also notify or have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.8. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:
a) other divisions or entities within or Xynez LLP;
b) our joint venture/ alliance partners;
c) our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
d) any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not;
e) insurers or insurance investigators and credit providers;
f) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
g) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the Xynez group;
h) our professional advisors such as our auditors and lawyers;
i) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
j) anyone to whom we transfer or may transfer our rights and obligations;
k) banks, credit card companies and their respective service providers; and
l) any other party as may be consented to by you, as specified by that individual or in the applicable contract.
We require that organisations outside or Xynez LLP which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.
3.9. In carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers. Some of these related corporations and third party service providers may be located in countries outside Singapore that may not afford an adequate protection to personal data or have protections in place which are similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected.

4. Keeping Your Personal Data Accurate and Up-To-Date
4.1. We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

5. Telemarketing Policy
5.1. Our Telemarketing Policy relates only to individual users of Singapore telephone numbers and was developed to comply with the Do Not Call (“DNC”) provisions under the PDPA. Our Telemarketing Policy applies to or Xynez LLP unless we have notified you otherwise in writing.
5.2. We aim to comply with the DNC provisions and your choices to receive promotional and marketing messages:
a) If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages via SMS, fax, calls and other means (as applicable) to your telephone number.
b) However, if you have previously consented to our sending you such messages to your Singapore telephone number(s), we will continue to do so until you withdraw such consent, regardless of your DNC nominations.
c) Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS or fax about products and services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages.

6. Cookie Policy
6.1. The following sets out the “Cookie Policy” for our websites.
6.2. A cookie is a small file containing a string of characters that is sent to your computer when you visit our websites for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website, your browser will read the cookie and relay the information back to the website or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
6.3. What do we use cookies for?
a) We use cookies to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
b) We use cookies to make our websites easier to use and to better tailor our products and services to your interests and needs. Cookies may also be used to help speed up your future activities and experience on our websites.
c) When you interact with us on our websites, we may collect for the purposes of analysis statistical information from which individuals cannot be identified (“Aggregate Information”), such as number of users, their frequency of use, the number of page views (or page impressions) that occur on the websites and common entry and exit points into and out of the websites.
d) We use such statistical information to understand how people use our websites and to help us improve their structure and contents. We cannot identify you personally from this information.
e) We may use cookies that are necessary in order to enable our websites to operate, for example, cookies that enable you to log onto secure parts of our websites.
f) We use cookies to track you as you navigate the websites and to enable the use of any e-commerce facilities.
g) We use cookies to personalise the website for you, including targeting advertisements which may be of particular interest to you.
6.4. Some of the cookies (non-exhaustive) that are used on our website includes:
a) Google Analytics (_utma, _utmb, _utmc, _utmz)
These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the site from and the pages they visited.
b) Session cookies
These cookies are used to make the websites easier for you to use, and to enable you to navigate from page to page within each website more easily. These cookies are automatically deleted once you close your browser.
6.5. As we use Google Analytics on the website, a service provided by Google Inc, you should also review the Google Analytics security and privacy principles available at We use Google Analytics cookies to collect information about how visitors use our websites and the total number of times a visitor has been into our website. We use the information to improve the website and enhance the experience of our online visitors. You can, at any time, opt-out from the use of Google Analytics by either changing the settings on your browser accordingly or by clicking at the following link:
6.6. We use the cookies of third party social networking platforms and websites to enable you to interact with these platforms and websites to share information about our websites through them (e.g. through “Like” or “Share” buttons or through comment boxes, etc.). The social networking platforms in question will have access and use the information in these cookies for their own purposes and we invite you to consult their respective privacy and cookie policies.
6.7. Information stored in cookies on the website is used exclusively by us, except those saved by Google Analytics, which is used and maintained by Google and us, for statistical purposes. Our third party ad-servers, if any, may also use the information stored in the cookies to customise your website experience. We do not have any direct control over the content of these adverts.
6.8. The way which cookies can be managed depends on your browser. The following links provide information on how to configure or disable cookies in each browser:
a) Google Chrome:
b) Mozilla Firefox:
c) Internet Explorer:
d) Safari:
e) Safari for iPhone:
f) Chrome for Android:
6.9. If you do not agree to our use of cookies as set out in this Cookie Policy, you should delete or disable the cookies associated with our website by changing the settings on your browser accordingly. This may also impact your user experience while on our websites.

7. Third-Party Sites
7.1. Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

8. Withdrawal of Consent
8.1. You may withdraw your consent given for any or all purposes set out in this Policy in writing by contacting our DPOs in accordance with paragraph 11 below. If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our products or services to you. Without prejudice to the foregoing, you agree and acknowledge any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to us in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information.

9. Management and Security
9.1. We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the PDPA. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of the PDPA very seriously.

10. Third Party Modules
10.1. Our website uses the Google Maps API from Google Inc. By using our website and/or such functionality built into the website, you agree to be bound by and comply with Google’s Privacy Policy available at or such other URL as Google may provide from time to time.

11. How to contact us
11.1. If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please contact our Data Protection team at email address [email protected]

12. Governing Law
12.1. This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.

13. Review of the Policy
13.1. This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.
13.2. In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.

April 1, 2018