PRIVACY POLICY

This Privacy Policy was last updated on 25 July 2018

This website address is https://sylvankohchang.com owned and operated by Sylvan Resort Company Limited.

We are registered in Thailand, and our registered office is at 63 Moo 4 Koh Chang, Trat 23170 THAILAND.

This policy describes what happens to any personal data provided by you or collected from or about you. It applies to all data processing activities of SYLVAN Koh Chang and its subsidiaries, and by using this website or any website of SYLVAN Koh Chang, you expressly agree and accept the terms of this Privacy Policy. If you do not agree with the data practices described in this Privacy & Cookies Policy, you should not use the Websites or our Service.

We may change this Privacy Policy from time to time, in order to reflect changes in the law and/or our privacy practices. We recommend you to check this policy for changes whenever you visit our website.

Personal Data
Personal Data refers to all personally identifiable information collected and recorded about an individual. We may collect the following Personal Data:

• Personal information: name, gender, nationality, date of birth, and names of your family members, their date of birth, nationality, etc.
• Contact information: address, telephone number, e-mail, address, etc.
• Payment information: billing address, and other payment and billing information.
• Loyalty and referral program: details and partner program affiliation, marketing and analytical data.
• Accommodation information: dates of arrival and departure from our hotels, the location of the room, smoking/ non-smoking room, type of room and bed requests, preferred newspaper, etc.
• Feedback: records of your contact with us such as via the phone number, or if you get in touch with us online using our online services, details such as your mobile phone location data, IP address and MAC address, including history of any communications with us, and analysis of your interaction with us, which helps us to customize offers to you and provide information that we think are of interest or relevance to you.
• Technical information: IP address, geographic data, browser and computer system, application version, language settings and pages that have been shown to you, etc.
• Professional information: if you are applying for a position at SYLVAN Koh Chang, in addition to the above mentioned information we may collect your education, training and employment records.

We do not request any sensitive information such as religious or philosophical beliefs, political opinions, information on health, racial origin or ethnicity, sexual orientation or union membership.

We also limit the information collected in relation to children under 18 years to their name, nationality, and date of birth, which can only be supplied to us by an adult. We kindly request that parent ensure that children do not send us any Personal Data without parental consent, and if such information was sent, please get in touch with us and we will delete such information.

Collection of Personal Data

Personal Data may be requested or generated in different circumstances, including (but not limited to) the following:

• Marketing and communication activities: newsletters subscription, loyalty program registration, and participation in promotional offers, surveys, competitions, social media and SMS marketing campaigns.
• Reservations and purchasing activities: room or table reservations, check-in, and check-out, payment, submission of complaints or requests.
• Provided by third parties: information collected through marketing partners, tour operators, online reservation systems, and other third parties, which may include information provided by your travel agent, airline, credit card, and other service providers.
• Internet activities: connection to any SYLVAN Koh Chang site, online reservations, questionnaires, and social media platforms etc.
• Job or internship applications.

Purpose of Personal Data Collection
We use your Personal Data for the following purposes:

• Performing our customer service obligations: management of reservations and your stay in our properties, catering to your requests, monitoring your use of services (telephone, bar, pay TV etc.).
• Improvement of our services: assessment of our services in hotels, restaurants, and other outlets, improvement the operation of our business, and development of new products and services.
• Personalization of our services and communications: personalize content and tailor our digital customer experience and offerings, understand customers’ requirements to develop targeted marketing programs, newsletters, and promotions.
• Recruitment: recruitment of staff or interns for SYLVAN Koh Chang.
• Compliance purposes: fulfill our statutory and fiscal compliance obligations.

If you do not provide certain information to us, we will be unable to provide you with our products or services. In cases where providing some personal information is optional, we’ll make this clear.

Retention Period
We will define retention period of your Personal Data based on the following criteria:

• Reasonable business needs: for as long as we provide goods and services to you, or managing our relationship with you, managing our operations; and/or
• Reasonable statutory periods: for as long as someone could bring a claim against us or for as long we need to comply with our fiscal and legal obligations; and/or
• Other retention periods in line with legal and regulatory guidance and requirements.

Personal Data Processing
We rely on the following legal bases to process your personal data:

• Contractual necessity: all stages and activities relevant to managing services rendered to you, including inquiry, application, administration and management of accounts, reservations, requests, and complaints.
• Our legitimate interests: performance of contracts and support of our business units, affiliates, subsidiaries, member hotel owners, partners, suppliers etc.
• Compliance with legal obligations: compliance with applicable laws, prevention of fraud or money laundering, or defense against legal claims, including those in the area of labor law, social security, and data protection, tax, and other, as the case may be.
• Consent, as permitted by applicable law.

Disclosure of Personal Data
We may share Personal Data with the following third parties for the purposes listed above:

• SYLVAN Koh Chang’s (including its subsidiaries and affiliated companies) employees: to offer you the best service, we can share your personal data and give access to appropriate person within SYLVAN Koh Chang entities for certain specific categories of personal data, including but not limited to hotel staff, reservation staff, IT departments, commercial partners and marketing services, etc.
• Business partners and external service providers: including IT services, marketing services, call centers, banks and credit card issuers, legal services, consultants, and social networking sites.
• Local authorities: should it be required by local legislation or as part of internal SYLVAN Koh Chang investigations, in accordance with legal requirements.

SYLVAN Koh Chang also reserves the right to transmit any personal data in the event of sale or transmission of part or all of the company or respective assets. In any case of transmission of personal data to third parties, we will comply with our legal obligations under the applicable laws.

International Transfers
We may transfer your Personal Data across multiple jurisdictions, insofar as reasonably necessary for the purposes, and in accordance with this Privacy Policy, your Personal Data may be transferred to the following locations:

• Countries where our corporate offices and sales offices are located (e.g. Thailand); and
• Countries where our third party service providers, advisors, and consultants are located, which changes from time to time.

Where Personal Data is transferred to a country with lower level of data protection as that provided by the country in which the information was collected, SYLVAN Koh Chang will take all reasonable steps to implement appropriate safeguards (e.g. using approved contractual agreements, codes of conduct, etc.) and procedures to keep your Personal Data secure and confidential.

Security of Personal Data
SYLVAN Koh Chang has implemented the necessary technical and organizational measures, in compliance with legal requirements, with the aim of protecting the Personal Data, ensuring confidentiality in accordance with the principles laid in this policy.

Whenever information is requested on credit cards, this communication is made via secure SSL (Secure Sockets Layer) lines, when you are using a browser which allows SSL, such as Microsoft Internet Explorer or Google Chrome.

Personal Data Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. To exercise any of the following rights please submit a request to the address indicated below:

• Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is processed, and, to request access to the Personal Data. Please note that this is not an absolute right, and the interests of other individuals may restrict your right of access.
• Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data about you and where applicable, you have the right to complete such information, including by means of providing a supplementary statement.
• Right to erasure (“right to be forgotten”): Under certain circumstances, you have the right to obtain from us the erasure of Personal Data concerning you, and we may be obligated to erase that Personal Data.
• Right to the restriction of processing: Under certain circumstances, you have the right to obtain from us restriction of processing your Personal Data. In that case, your data will be marked and may only be processed by us for certain limited purposes.
• Right to data portability: Under certain circumstances, you have the right to receive the Personal Data about you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that data to another entity without hindrance from us.
• Right to object: Under certain circumstances, and at any time, you have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data by us, and we can be required to no longer process your Personal Data.

Where permitted by applicable law, you also have the right to lodge a complaint with a competent data protection supervisory authority.

You may access, correct, add to, update or delete their personal data by contacting us via email: [email protected]. Such requests will be dealt with as quickly as possible. Please note that we may request a copy of a valid identification document to confirm your identity, before making any changes.

If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed or receive any other communication from us, please follow the unsubscribe link in the relevant communication. Even after you opt-out or update your marketing preferences, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, surveys, or any questions regarding a specific reservation.