ProMark Strategies (referred to as the “Company”, “we”, “our” or “us”) is committed to the protection of your Personal Data and takes the matter of protecting your privacy as high priority.

This Privacy Statement explains general terms on how we collect, use and protect the privacy of your Personal Data. Please note that the Privacy Statement is streamlined to common principles of data privacy in most jurisdictions although there may be some slight variations due to local requirements.

The types of Personal Data that we collect directly from you or from third parties depend on the circumstances of collection and on the nature of the service requested or transaction undertaken. It may include (but is not limited to):

1. personal information that links back to an individual, e.g., name, gender and date of birth;

2. contact information, e.g., address, phone number and email address;

3. payment information, e.g., credit or debit card information, including the name of cardholder, card number and expiry date;

4. technical information, e.g., IP address; and

Where another person makes reservations on your behalf, you undertake and will ensure that you have authorized the disclosure of your Personal Data and consent to the terms and conditions of this Privacy Statement. Where you are booking on behalf of another person, you represent and warrant that you have the consent of those persons to provide their Personal Data.

This Privacy Policy covers any Personal Data provided to us (but is not limited to):

1. communications with you via telephone, fax and email;

2. when you visit our website;

3. when you contact us in person;

4. when we contact you in person;

5. when we collect information about you from third parties;

From our website, we collect your Personal Data in the following ways:

1. IP Address

   We use your IP address to help diagnose problems with our server, and to administer our website. IP addresses are not linked to personally identifiable information.
   
   

2. User Feedback Form

   Our Customer Care Feedback Form requires you to update us your personal data (e.g. your name, telephone number, mailing address and email address) so that we have the correct information. We use your contact information form to send you information about promotion for your membership. Your contact information is also used to contact you where necessary. Demographic and profile data are also collected at our site. We use your Personal Data to tailor your experience in the hotel that we think you may be interested to your preferences.

We will use your Personal Data for the following core purposes:

1. to enable us to provide our services and perform our services to you;

2. to facilitate your dining and accommodation booking and arrangements with hotels;

3. to remind you to use your membership benefits. This is an optional service. You can choose not to receive these emails at any time by following the link at the bottom of each such email;

4. for business development purposes such as statistical and marketing analysis, customer surveys or to help us in any future dealings with you, for example by identifying your requirements and preference; and/or

5. to comply with any legal or regulatory requirements.

We may use your personal data for the following ancillary purposes (including but is not limited to):

1. to communicate promotions, offers, product, services and information on products and activities, offers to upgrade or other notifications in relation to your membership; and/or

2. marketing/cross-marketing and communicating with you in relation to products and services offered by us and our service partners.

You may request to obtain information of your Personal Data, limit the processing of your Personal Data and also update or make amendments to your Personal Data as below:

1. for mobile app members, you may login to your mobile app account and update your Personal Data; or

2. for every other customer, you may forward your request to the contact person as detailed below at the final clause.

We will endeavour to provide the information back to you as soon as practicable. However we also reserve the right to validate all requests for the authenticity of the request. We may refuse to comply with data access request in circumstances as provided by the law. If we are not able to comply with your request, we will notify you of the reasons.

Please note that it is obligatory for the Company to process your Personal Data for the Core Purpose as stated above, without which we will not be able to make dinning and accommodation arrangements for you. If we do not have your consent to process your Personal Data for the Ancillary Purposes, we will not be able to keep you updated about our future, new and/or enhanced services and products.

Nevertheless, you may stop receiving promotional activities by:

1. unsubscribing from the mailing list; or

2. sending a request to privacy@promarkstrategies.com

We will not trade or sell your Personal Data to third parties. Your Personal Data shall only be disclosed or transferred to the following third parties appointed or authorised by the Company, who may be located within or outside your country of residence for the fulfilment of the Purpose:

1. our partner hotels which we market their loyalty membership;

2. our other affiliates and subsidiaries;

3. credit card verification providers;

4. data warehouse;

5. IT service providers;

6. legal bodies as permitted or required by law such as in compliance with a warrant or subpoena issued by a court of competent jurisdiction; and/or

7. customs, immigration or other regulatory authorities applicable to you.

We will store the Personal Data in the country in which we are based i.e. Malaysia. However, the Company may have back up and storage servers, which are located overseas. Additionally, the Company will secure the storage in following ways in compliance with the security measures prescribed under the law, its regulation and standards:

1. register all those who are allowed access;

2. control and limit access based on necessity;

3. maintain proper record of access and transfer of Personal Data;

4. ensure all employees of the Company protect confidentiality;

5. conduct awareness programmes to all employees (if necessary) on responsibility to protect Personal Data;

6. establish physical security procedures;

7. bind third parties involved in processing of Personal Data; and

8. do not transfer or store Personal Data unless with written consent from Senior Management of the Company.

We will not retain your Personal Data longer than necessary for the fulfilment of the Purpose. However, relevant Personal Data may be retained subject to the conditions below:

1. as and when required under legislation or where legal actions have arisen and are pending; or

2. commercial/operational purposes

The Company shall take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted when no longer required for the Purpose.

Please note that this Privacy Statement may be amended from time to time in accordance to applicable laws and regulations and such variations may be applicable to you. The latest version of this Privacy Statement will be made available to all customers. You may access it from the link at the bottom of each such email.

On the email, we may include link(s) to other companies or organizations websites (collectively, “Third Party Sites”). This Privacy Notice does not apply to such Third Party Sites as those sites are outside our control. If you access Third Party Sites using the links provided, the operators of these sites may collect your personal information. Please ensure that you are satisfied with the privacy statements of these Third Party Sites before you submit any personal information. We try, as far as we can, to ensure that all third party linked sites have equivalent measures for protection of your personal information, but we cannot be held responsible legally or otherwise for the activities, privacy policies or levels of privacy compliance of these Third Party Sites.

If you still have inquiries or complaints in relation to our handling of your Personal Data or our Privacy Policy or wish to access, update or amend your Personal Data as mentioned above, please email us at:

Email Address     : privacy@promarkstrategies.com