1.    GENERAL

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1.1.    This Privacy Policy (“Privacy Policy”) is provided by Subhome Management Sdn Bhd (Company No. 1057310-P) (“SubHome”) and its associates,

subsidiaries and affiliates who operate SubHome (collectively referred to as “we”, “our” and “us”).

1.2.    This Privacy Policy describes how and when we collect your personal information, what that information may be used for, who uses it, when it may be

disclosed to other parties, how you can access your details and seek correction of your details, the control your own personal information and how you can contact us.

1.3.    By visiting SubHome’s website (“Website“), you are deemed to have read and agree to be bound by this Privacy Policy. If you are a resident of the

European Union (EU), please see Appendix A for additional information regarding SubHome’s use of your personal information.

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2.    NOTICE

2.1.    This Privacy Policy serves as a notice pursuant to the Malaysian Personal Data Protection Act 2010.
2.2.    We may vary or update this Privacy Policy from time to time. We will notify you of these changes to our Privacy Policy on our Website. Please check

our Website regularly for updates to our Privacy Policy.

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3.    INFORMATION COLLECTION AND USE

3.1.    We may collect and hold personal information/data (“Personal Information”) about you or someone else whom you are making a booking for or

traveling with (“Third Party”), that is, information that can identify you or such Third Party, including without limitation full name, postal and email address, other contact details, identification details, payment details, booking and travel information, and other information relevant to providing you with the services you and/or the Third Party are, or someone else you know is, seeking, which we receive from you through our Website, call centre, social media sites, walk-in or distribution channels, including online travel agencies. You agree that you have obtained the consent of such Third Party to provide us with their Personal Information and to view or change their information. You agree to indemnify us in the event we suffer any loss or damage as a result of your failure to comply with the same.

3.2.    You are responsible for ensuring that the Personal Information you provide us is accurate, complete and not misleading and that such Personal

Information is kept up to date.

3.3.    We may collect Personal Information in one or more of the following circumstances or for one or more of the following purposes:

i.    to process your booking and for other operational and administrative purposes, including without limitation, processing bills and payments,

travel notification, manage your account;

ii.    to provide you or someone else you know customer support and services;
iii.   to undertake various activities that are required by law;
iv.   for administrative, operational, marketing, planning, product or service development, troubleshooting and research requirements;
v.    to send you information on products and services, and special or promotional offers, newsletters or customer survey forms and questionnaires;
vi.   as part of a program you have joined (e.g. loyalty program) or purchase you have made;
vii.  to resolve disputes or enforcement of our terms and conditions available at our Website (Please refer to Terms and Conditions); and
viii.  for any purpose made known to you at the time at the time of collection of your Personal Information (collectively referred to as “Purposes“).

3.4.    At any time you may opt-out of receiving marketing communications from us by contacting us (see the CONTACT US section below) and we will

ensure that your name is removed from our mailing list.

3.5.    We use general, aggregated information to generate statistics and measure site activity to improve the usefulness of customer visits. Such

information does not include Personal Information.

3.6.    We may disclose your information:

i.    to our related companies, affiliates, advisors, contractors, vendors or service providers for the purposes of operation and maintenance of our Website or our business, for cross-promotional purposes and to otherwise provide customer support and services to you;
ii.    to owners and operators of our Properties or our business partners and investors;
iii.    to other third parties with whom we have commercial relationships, for marketing, advertising and related purposes, unless you have indicated that you do not wish for us to disclose to such third parties for marketing and advertising purposes;
iv.    social media websites; and
v.    as required or authorised under law or provided in co-operation with any governmental authority.

3.7.    If you fail to provide us with Personal Information stated in paragraph 3(a) above, we may not be able to perform and/or carry out any of the

Purposes.

 

4.    MARKETING AND PROMOTIONAL COMMUNICATIONS

4.1.    We may use the Personal Information provided to send you information on products and services, and special or promotional offers, newsletters or

customer survey forms and questionnaires unless you have indicated that you do not wish to receive such materials.

4.2.    You may opt out of receiving any communications from us at any time by clicking on the “unsubscribe link” on the relevant email communications or

contact us with your request (see the CONTACT US section below).

 

5.    SECURITY OF YOUR PERSONAL INFORMATION

5.1.    We will take reasonable steps to protect any Personal Information we receive from you via our Website from misuse and loss and from unauthorised

access, modification or disclosure. We may hold your information in either electronic or hard copy form or retain third parties to hold that information on our behalf. Where required by applicable laws, Personal Information will be destroyed or de-identified when no longer needed.

5.2.    By providing us with Personal Information or using our services or our Website, you consent to the transfer, storage and processing of Personal

Information to where our servers, central database and system facilities are located and/or operated, which may be outside your country of domicile or the location where you access our Website to provide Personal Information, and which may include, among others, Malaysia, the United States of America and the United Kingdom.

5.3.    However as the Website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of

transmission of information you communicate to us and you do so at your own risk.

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6.    LINKS TO OTHER WEBSITES

6.1.    Our Website may contain links to websites operated by third parties (“Third Party Websites”). We are not responsible for the privacy practices or the

content of Third Party Websites. Third Party Websites are responsible for informing you about their own privacy practices.

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7.    ACCESS AND CORRECTION

7.1.    You may request access to any Personal Information we hold about you or any Third Party whose Personal Information you had provided at any time

by contacting us (see the CONTACT US section below). Where we hold information that you are entitled to access, we will endeavour to provide you with suitable means of accessing it (e.g. by emailing or mailing it to you).

7.2.    If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may request amendment of it. We will

consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the Personal Information stating that you disagree with it.

7.3.    In accordance with the Malaysian Personal Data Protection Act 2010, and to the extent not limited by any other applicable law, we may:

i.    charge a fee for processing your request for access or correction to the Personal Information; and
ii.    refuse to comply with your request for access or correction to the Personal Information and give you a reason for our refusal.

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8.    COOKIES

8.1.    We use cookies in our Website to:-

i.    maintain your session and required details when you browse our Website or during registration or the booking process (session cookie);
ii.    collect website usage data for statistical/analytics purposes (analytics cookie); and
iii.    direct you to the correct landing page based on your geo-location (geo-targeting cookie).
iv.    You may instruct your browser, by changing its setting, to stop accepting cookies or to prompt you before accepting a cookie from the websites

that you visit. Note that our Website will not function properly if the cookie setting is disabled.

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9.    CONTACT US
If you have any questions about our Privacy Policy, or any concerns or a complaint regarding the treatment of your privacy by us, including but not limited to the Malaysian Personal Data Protection Act 2010, please contact us at:-

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Telephone Number: +603-8213 6279
Email Address: contactus@subhome.my
Correspondence Address: Mercu Summer Suites, Level 2, No 8, Jalan Cendana, Kampung Baru, 50300 Kuala Lumpur, Federal Territory of Kuala Lumpur.

 

In the event of any inconsistency between the English version and other language versions of this Privacy Policy, the terms of this English version shall prevail.

 

 

 

APPENDIX A

 

ADDITIONAL PROVISIONS APPLICABLE TO EU RESIDENTS AND THE PROCESSING OF THEIR PERSONAL INFORMATION PURSUANT TO THE GENERAL DATA PROTECTION REGULATION (EU) 2016/679 (“GDPR”)

 

This Appendix A highlights certain rights that EU residents may have in relation to the processing of your personal information pursuant to the GDPR.

 

1.    WHY DO WE PROCESS YOUR PERSONAL INFORMATION?

1.1.    Provide our services to you – When you make a reservation with us, we will process your personal information , including without limitation, your full

name, postal and email address, date of birth, nationality, passport and visa information (including obtaining scanned copies of passport/visa during check-in time), contact information, payment and credit card information, booking and travel information, and other information that will be relevant in order for us to complete your reservation/booking request, sending you reservation confirmations, registering you for memberships (where applicable), customising our accommodation, services and facilities to your preferences (including access to our WiFi), earning and redeeming loyalty points/rewards (where applicable), and keeping proper records of your transactions with us.

1.2.    Provide our marketing and promotional items to you– We may send you information and updates on our Properties, including the latest newsletters,

promotions or deals, competitions, responses to your inquiries, updates on our website, or changes to our terms and conditions and policies.

1.3.    Enhance the provision of our services – From time to time, we may perform market researches in the form of surveys in order to find out about your

stay experiences, your thoughts on our products and services and how we can improve and further develop our services to better serve our guests. We may also perform analytics and/profiling, advertising campaigns and even promotional activities in relation to our products and services.

1.4.    Work with third parties to provide our services to you – We may also process your personal information when we work with third parties including

but not limited to, travel agents, group travel organisations, airline operators, credit card companies, third party loyalty programs or any other parties that may be involved in the process of making your travel arrangements.

1.5.    Maintain your safety and security– When you stay with us, we may require your personal information for identification and verification purposes

especially in the implementation of our security systems in our Properties or facilities.

1.6.    Others– For any other purposes mentioned at paragraph 3(c) of the Privacy Policy or any other purposes made known to you at the time of collection

of your personal information or as required by applicable laws.

1.7.    Please note that we will only process your personal information on one or more of the following legal principles:

i.    That you have provided your consent;
ii.    The processing of your data is necessary for the performance of your instructions to us;
iii.    To comply with our legal obligations (i.e. to keep tax records);
iv.    The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are

overridden by your interests or fundamental rights and freedoms.

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2.    HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?

2.1.    We will retain your personal information for the duration that shall be necessary to achieve the purpose for which such information was collected,

which shall usually be during the duration of our contractual relationship and for any period thereafter as permitted by applicable laws (i.e. until you have withdrawn your consent for us to retain your personal information).

 

3.    WHAT RIGHTS DO YOU HAVE?

3.1.    Access, Correction and Erasure: You have the right to obtain a copy of your personal information from us, receive information on how your personal

data is being processed, request for updates or corrections on your personal information, and also the right to request for erasure/deletion of your personal information.

3.2.    Right to object to the processing of your data: You have the right to request for us to cease processing your information for direct marketing

purposes, including profiling. We will no longer process your personal data unless we are able to demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedoms for the establishment, exercise or defence of legal claims.

3.3.    Right to restrict the processing of your data: You have the right to request for us to restrict the processing of your data, (i) while we are in the

process of verifying the accuracy of your data and subsequently updating your personal data; (ii) where the processing is unlawful and you oppose the erasure of your data and request to restrict the processing of the data instead; (iii) where we no longer require your data, but you may require for us to retain the same for the establishment, exercise or defence of legal claims; or (iv) where you have submitted an objection to processing pending the verification whether our legitimate grounds override your interests, rights and freedom.

3.4.    Right not be subjected to automated individual decision-making, including profiling: With your consent, we are able to process your data and make

automated decisions, including profiling, in order to be able to offer certain benefits based on your characteristics. However, you have a right to request for human intervention and can request for us to not subject your data to automated decision-making/profiling.

3.5.    Right to data portability: You have a right to request for us to provide your personal data (which we obtained based on your consent) to a third party

in a structured, commonly used and machine-readable format.

3.6.    Right to withdraw your consent: You are entitled to withdraw your consent to any processing that we conduct on your personal information.
3.7.    To do any of the above, please contact us at contactus@subhome.my (other details and contact information are available at paragraph 9 of our

Privacy Policy).

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4.    TRANSFER OF YOUR PERSONAL DATA

4.1.    As SubHome is active internationally, we may transfer your personal data abroad if required for the purposes as highlighted above at paragraph 1 of

this Appendix. When we make such transfers, we will ensure that we provide appropriate safeguards in accordance with the GDPR.

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5.    MISCELLANEOUS

5.1.    In the event of any inconsistency between our Privacy Policy and the additional provisions here in Appendix A, the terms in Appendix A shall prevail

for EU residents.

5.2.    If you have any concerns with our personal data policies or the exercise of your rights, you may contact us at contactus@subhome.my.

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