This privacy policy has been compiled to better serve those who are concerned with how Showsuite Pte Ltd (UEN 201610536Z) and/or its related companies (collectively referred to herein as “Showsuite”, “us”, “we”, “our”) collects, uses, discloses or shares their Personal Data (as defined below). In this privacy policy, “you”, “your”, “yours” or words to similar effect refers to any person using our website, software applications or any of our products or services.

Personal Data

”Personal Data”, refers to data, whether true or not, that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this privacy policy carefully to get a clear understanding of how we collect, use, protect, share, disclose or otherwise handle Personal Data.

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Your Consent to Showsuite’s Collection, Use, Disclosure or Sharing of Your Personal Data

By interacting with us, submitting information to us, signing up for or using our services, you agree and consent to Showsuite and its representatives or agents (collectively referred to as “Showsuite”, “us”, “we” or “our”) collecting, using, disclosing and sharing your Personal Data and the Personal Data of any other individual which you may provide to us, for the purposes and in the manner set forth in this privacy policy,

You also agree that our collection, use, purposes and disclosure of Personal Data in the manner set out in this privacy policy is reasonable to enable to provide the various products and services contemplated hereunder.

If you are providing us with the Personal Data of another person, you represent and warrant that you have the consent of that person.

What personal information do we collect from the people that visit our blog, website or app?

You may be asked to enter your name, email address, mailing address, phone number, identification card number, gender, property information, passport number or other details to create a user account, help you with your experience and assist with the booking process.

When do we collect information?

We collect information from you when you register on our site, subscribe to a newsletter, respond to a survey, book a property or make an offer, fill out a form or enter information on our site or using our app.

How do we use your information and what are the purposes for which we collect, use and disclose Personal Data?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site or app features in the following ways:

• To personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To administer a contest, promotion, survey or other site feature.
• To quickly process your transactions and process orders or requests.
• To send periodic emails regarding your order or other products and services.
• To send information, respond to inquiries, and/or other requests or questions.
• To perform or fulfill any contract you may have with us.
• To verify your identity and/or the identity of any other individual on whose behalf you may be acting.
• To make or obtain payments from you, where applicable.
• To analyse and improve our internal operational processes and to develop business strategies, policies and procedures.
• To conduct surveys, research and statistical analysis.
• To detect, monitor and prevent fraud, or unlawful or improper activities.
• To monitor or record phone calls and customer interactions for quality assurance, training, performance evaluation and identity verification purposes.
• In connection with any claims, actions or proceedings and/or to protect and enforce our contractual and legal rights and obligations.
• To meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies (including but not limited to responding to regulatory queries, and conducting audit checks, due diligence and investigations).
• To notify you about news or developments about us or our products and services, including updates to our End-User License Agreement, this privacy policy and other policies and codes of conduct.
• To promote new, revised or complementary products or services; market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
• For any other purposes which are reasonable and appropriate.

In relation to particular services or in your interactions with us, we may also 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.

Do we use 'cookies'?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognise your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services.

We use also cookies to:

• Understand and save user's preferences for future visits.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

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. You do this through your browser settings. Since browsers can be a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, some features will be disabled. Some of the features that make your site experience more efficient and may not function properly.

However, you will still be able to browse the site but certain features like, Favourites, History, Book Now, Make-An-Offer and Select may not be available.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, except for any data processors we may use from time to time, if any.

We ensure that third party service providers provide sufficient guarantees that they comply with all applicable law, including the General Data Protection Regulation.

If Showsuite is involved in a merger, acquisition, or sale of all or a portion of its assets, we reserve the right to transfer or assign the information we have collected from you as part of such merger, acquisition, sale or change of control, and you will be notified via email and/or a prominent notice on our website or app of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Third-party links

We offer third-party products or services and may promote third party products and services.

Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users https://support.google.com/adwordspolicy/answer/1316548?hl=en

Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

Demographics and Interests Reporting

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together for our internal data and statistics

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act (“CalOPPA”)

CalOPPA requires commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personal Data from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website. Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.

Updates to This Privacy Policy

This privacy policy may be updated from time to time for any reason. We will notify you of any changes to our privacy policy by posting the new policy on this site and informing you via email or other means. You are advised to consult a copy of this privacy policy (which will be made available on our website) regularly for any changes, as continued use is deemed approval of all changes.

You agree that your continued use of our site or any apps after we publish or send a notice of our updated privacy policy means that the collection, use and sharing of your personal data is subject to the updated privacy policy. Access to, Correction and Portability of Personal Data

You can change your Personal Data by logging in to your account.

In addition, you can also contact our Data Protection Officer using the following contacts:

Email: feedback@showsuite.com

Address: 1 Kallang Junction, Vanguard Campus, Level 6, Singapore 339263

if you:

• have any questions or feedback relating to Personal Data or our privacy policy;
• would like to obtain a copy of your Personal Data in a commonly used electronic format so that you may transfer it to another organisation;
• would like to withdraw your consent to any use of your Personal Data as set out in this privacy policy;
• would like us to delete your Personal Data;
• would like to know what Personal Data of yours is in our possession or control and how we have used or disclosed the same; or
• would like to obtain access and make corrections to your Personal Data records.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you.

Please note that there may be circumstances under applicable law that requires us to refuse your request. We may also charge a reasonable amount for complying with your request.

Security

We protect your Personal Data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches and we cannot ensure or warrant the security of your personal information.

Retention of Personal Data

We will cease to retain documents containing Personal Data, or remove the means by which the Personal Data can be associated with particular individuals as soon as it is reasonable to assume that (i) the purpose for which the Personal Data was collected is no longer being served by retention of the Personal Data, and (ii) retention is no longer necessary for legal or business purposes.

Storage and Transfer of Your Information

We store Personal Data using cloud storage services of third party service providers, which may be in Singapore or overseas.

We ensure that third party service providers provide sufficient guarantees that they comply with all applicable law.

Where relevant, we will ensure that your rights under any applicable law will be the same even if such information is transferred to and stored outside of Singapore. You agree that we may transfer and store your Personal Data outside of Singapore, provided all the requirements of applicable laws are complied with.

How does our site handle Do Not Track signals?

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It's also important to note that we do not allow third-party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not specifically market to children under the age of 13 years old, and require users of our site and apps to be at least 21 years of age.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email.

Within 7 business days
We will notify you via in-site notification

Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address for the purposes stated in this privacy policy.

To be in accordance with CANSPAM, we agree to the following:

Not use false or misleading subjects or email addresses.

Identify the message as an advertisement in some reasonable way.

Include the physical address of our business or site headquarters.

Monitor third-party email marketing services for compliance, if one is used.

Honour opt-out/unsubscribe requests quickly.

Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at unsubscribe@showsuite.com and we will promptly remove you from ALL correspondence.

Last updated: [October 2020]