Sarment Pte. Ltd. with a place of business at 3 Fraser Street, Duo Tower, Level 8 Regus, Singapore 189352 (“we“, “us“, “our“) are committed to protecting and respecting the privacy of our members and other users of our Services. In order to provide the best possible service and experience, we will collect, use and disclose personal data about you, and this privacy notice (“Notice“) explains how and why we do so when you use the website www.keyyes.com (“Website“), the Keyyes app (“App“) or any of the services we offer accessible through the Website or App or otherwise (collectively referred to as “Services“). Please read this Notice carefully so you are aware of our practices regarding your personal data, before becoming a member or using any of our Services.
2. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS ABOUT YOU?
Our business ambition is to provide our members with an efficient, tailored and unique experience. When using our Services we collect and process the following personal data (including, where applicable, sensitive personal data) about you. Information is either collected directly from you or is automatically collected through your use of the Services:
- Identity information – name, address, gender, date of birth, personal contact details (including email address and telephone number), access to your calendar and/or itinerary and, if provided by you, photograph images. This information includes details you provide to us when you register to become a member, update your profile or preferences, subscribe to or use any of our Services, search for a Service within the App, make in-App purchases or share data via the App’s interactive or social media function, or contact us to report a problem with one of the Services. In the case of the latter, we will indicate whether providing certain data is mandatory and, if you do not provide such data, we may not be able to respond to your enquiry;
- Technical information – which will include the IP address, browser type and version, time zone setting, browser plugin types and versions, operating system and platform, and when using a mobile device the type of mobile device you use, unique mobile device identifiers (such as, IP address, IMEI number, the address of the device’s wireless network interface, or mobile phone number used by the device), mobile network information, your mobile operating system, and time-zone settings;
- Location information – geo-location data to determine your current location;
- Background information – details about your interests and preferences, information about your family, friends and your travel/dining companions, and any feedback, questions or recommendations you provide, and details of other membership schemes you subscribe to such as frequent flyer numbers and loyalty scheme numbers; and
- Special categories of personal data – details you provide us with your explicit consent, such as food allergies and health data.
We may receive information about you from other sources such as:
- our partners (who are organisations such as hotels, restaurants and luxury goods providers with whom we have a business relationship and whom we engage to fulfil the Services provided to you);
- our enterprise clients (who are organisations with whom you have an existing relationship with and who may have referred our Services to you, for example, your bank);
- through data gathered from your publicly-searchable social media and online activities, and your preferences through your use of our Services; and
- from our third party service providers. These are organisations who provide services to us, so that we can deliver our Services to you, and may include our sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers.
Any information we collect may be combined with other information we collect from you.
If you provide us with information about other people (such as family members, friends and your chosen supplementary members), you confirm that you have their consent to provide us with that information.
We use third party analytics tools, log files and other methods, and cookies on our Website and App when you sign up to become a member via our Website or App or you otherwise use our Website or App, to collect usage and activity information and to distinguish you from other users of our Services and for other purposes, including (with your consent, where required by applicable law) marketing purposes. Cookies are small text files containing small amounts of information which are downloaded and may be stored on any of your internet enabled devices. We will process cookies in accordance with our separate Sarment cookie and identifier policy which contains details of the types of cookies collected and the purpose for which we use them.
In order to use our Services, you must provide us with the information requested on the member registration pages (except those preferences marked as voluntary), otherwise we will not be able to process your membership application or provide the full range of functionality of our Services. You are able to set and disable certain in-App permissions via your device settings. Our App does not recognise browser or device-level do-not-track requests.
3. HOW WILL YOUR PERSONAL DATA BE USED?
Your personal data will be used by us in connection with the following purposes:
For the performance of our agreement with you:
- to provide the Services, including allowing us to make recommendations and reservations at restaurants and bars compatible with your dining and wine preferences and where you are staying, make recommendations and purchases and facilitate delivery of selected luxury products. The App may also (if enabled) allow you to communicate with other members of the App;
- to provide you with access to the content accessible through our Services;
- to communicate with you and provide you with information about the Services, and inform you of any changes to the Services;
- to monitor your use of the Services, in order for us to better understand your preferences and manage your relationship with us; and
- to respond to any queries or complaints that you raise.
For our legitimate commercial interests, in order:
- to review the Services we provide to you, and carry out analytics and report on our engagement with you;
- to confirm, update and improve our membership records to maintain a quality, accurate and rich database;
- to operate, evaluate and improve our Services and overall business (including by means of analysing your use of the Services, which information we use to improve our Services and to give you a better user experience (e.g., we analyse what web pages you visit, which Services you use and like, how you use these Services, which enables us to create personal profiles and to assess what may be interesting to you, which recommendations we can give you when you use our Services (such based for example on your previous use of our Services)). Creating such personal profiles of our members and other users also enables us to send you marketing materials that directly relate to your use of our products and Services, if you have chosen to receive such materials;
- to generate aggregated statistics about the users of our Services;
- to facilitate our business operations, to operate company policies and procedures;
- to enable us to merge, sell, acquire, or transfer assets; and
- for other legitimate business purposes permitted by applicable law.
For use of information based on your consent, so that we can:
- keep you updated about our Services, and the services provided by our partners, including tailored and customised content based on the information that we collect from you and direct marketing communications (see above); and
- we may use the above mentioned ‘Special categories of personal data’ for the purposes set out in this Notice but we will only do so after we have received your consent thereto.
To comply with legal obligations to which we are subject:
- if we are obliged to disclose information by reason of any law, regulation or court order and/or to protect our interests and legal rights.
If, at any time, you prefer not to receive direct marketing communications from us in any form, you will have the ability to unsubscribe from such communications by selecting a link at the bottom of every communication that is sent to you by us. Alternatively you may also update your settings within your Membership Profile at any time, or you may contact us and we will deal with your request promptly.
4. AUTOMATED PROFILING
In order to ensure the content displayed through our Services is specifically customised for you, we will carry out profiling using automated processing to evaluate, analyse and predict your preferences, personality type and interests. We will use personal data collected from you directly, or through the use of the Services to complete automated profiling in order to communicate and highlight the types of Services which may be of interest to you, relative to your previous choices and current location. Automated profiling is a critical feature of the Services, and is necessary in order for us to deliver the Services to you and provide you with tailored Services.
5. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?
In order to provide you with a seamless experience, we will share your personal data with the following persons:
- our affiliates (see “Our Affiliates” below): for the purpose of managing and administering our business and to provide you with the Services including information which might be of interest to you;
- our partners: who require the information in order to facilitate the Services to you. We will only share your personal data with our partners to the extent they are required for our partners to facilitate the Services to you (e.g. we may share your address with a partner so that they can deliver products you have purchased through our Services to you);
- our enterprise clients: for the purpose of improving their existing relationship with you;
- entities who may or do acquire any rights in us: for the purpose of a business sale or re-organisation;
- our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts: for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- third party service providers: who need to know the information in order to provide us with services so that we might provide the Services to you. This may include our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, data storage, provide information technology and marketing services, customer services and for data analytics;
- law enforcement and Government and regulatory bodies: in order to comply with any legal or regulatory obligation or court order; and
6. YOUR CALIFORNIA PRIVACY RIGHTS
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting our Data Protection Officer. Please allow up to thirty (30) days for a response.
7. WHERE WILL WE STORE YOUR PERSONAL DATA?
The data we collect from you will be transferred to, and stored at, locations in and outside of Singapore, and so may be transferred to and stored outside of, your country of residence. It will also be processed by our personnel and the employees of our partners, clients and third party service providers, who operate outside of Singapore. These persons may also be engaged in order to provide the Services to you, including fulfilling requests, confirming reservations or processing your payment details. Your personal data will only be transferred to locations outside of Singapore where we are satisfied that adequate levels of protection equivalent to those in Singapore are in place to protect any personal data held in that location.
8. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
We take your data security very seriously.
For users outside the US: we have reasonable technical and organisational security measures in place and invest appropriate resources to protect your personal data from deliberate or accidental manipulation, destruction, loss, misuse, unauthorised access, disclosure, copying and modification. We take reasonable steps to ensure that our systems, and those of our affiliates, partners, clients and third party service providers, are appropriately secure for processing your personal data, and that the risks of your personal data being unlawfully used, amended, deleted, lost or stolen are minimised. We ensure that we have in place appropriate contractual agreements with third parties to ensure adequate safeguards are in place, and that such third parties will act at all times in compliance with applicable personal data protection laws.
For users in the US: we have implemented security measures to protect your personal data from deliberate or accidental manipulation, destruction, loss, misuse, unauthorized access, disclosure, copying and modification.
9. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We take steps to periodically review the information we collect, and we will destroy or anonymise any personal data if it is no longer needed for the purposes for which it was collected (as set out in this Notice) or otherwise after you cease to be member or cease using your account, or longer if required for any other legal purposes.
10. CHANGES TO THIS NOTICE
We may amend this Notice from time to time. Thereafter every time you use our Services, please read and check this Notice to ensure you are aware of the conditions which apply at that time. In case we make significant changes to this Notice, we will inform you thereof.
11. YOUR RIGHTS, FURTHER INFORMATION AND TO CONTACT US
You may have the right under applicable data privacy laws to request access to personal data we hold about you and information about how we have used that data (including, where applicable under applicable laws, the legal basis); to correct any errors or omissions in your personal data; to rectification; to erasure; to object against profiling; and to data portability.
You may also have the right under applicable data privacy laws to withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time; however, you may be unable to access some of the features of our Services if you entirely withdraw your consent to the terms of this Notice. Due to the nature of the App, you will be unable to access any of the features of the App if you entirely withdraw your consent to the terms of this Notice.
To make these requests, or if you have any questions or complaints about how we handle your personal data , or would like us to update the data we maintain about you and your preferences, please contact our Data Protection Officer by emailing DPO@keyyes.com or writing to our address set out above (or (if in Hong Kong) to 15/F, The Pemberton, 22-26 Bonham Strand, Sheung Wan, Hong Kong).
For users in the EU: please contact our Data Protection Officer by emailing DPO@keyyes.com for details of our EU representative for GDPR purposes.
12. OUR AFFILIATES
Sarment Holding Pte. Ltd.
Sarment Holding Limited
Keyyes Pte. Ltd.
Sarment Pte. Ltd.
Sarment China Limited
Sarment France Sarl
SWTC Pte. Ltd.
SWTC Japan KK
Sarment IP Holding Pte. Ltd.
Sarment (Macau) Limited.