This website (“Website”) is owned and operated by One Stop Hospitality Solutions Pte. Ltd., a Singapore private limited company.

This Privacy Policy applies to data collected on this Website. Our Website is intended for use by individuals who are over 16 years of age. The terms “we”, “us”, “our” and “Upgrading.cc” refer to One Stop Hospitality Solutions Pte. Ltd. and its subsidiaries and corporate affiliates (collectively, the “One Stop Hospitality Solutions Companies”).

The term “you” refers to the customer visiting the Website and/or booking an upgrade reservation through us on this Website, or through our customer service agents

What information we collect from you

We receive and store any information you enter on our Website or give us in any other way. This includes information that can identify you ("personal information"), including without limitation your first and last name, telephone number, postal and email addresses, fax number, and, if you make a reservation through our Website, credit card information (such as credit card number, cardholder name, and expiration date).

We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources and add it to our account information. Examples of information we may receive include: updated delivery and address information, purchase history, and demographic information. To the extent that we linked such third-party sourced personal information with the information that we have collected about you on our Website, we will treat the combined information as personal information under this Privacy Policy.

Calls to and from our customer service help desk may be recorded or monitored for the purpose of quality control and for staff training. Call recordings will be maintained as long as reasonably necessary and will then be deleted. Any personal information obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

Generally, Upgrading.cc collects, uses and discloses your personal information for the following purposes (“Primary Purposes”):

1. responding to your queries and requests and contacting you for follow up and similar services, if necessary
2. measuring interest in and improve our products, services, and Website;
3. customizing your experience with this Website managing the administrative and business operations of Upgrading.cc and complying with internal policies and procedures;
4. matching any personal information held which relates to you for any of the purposes listed herein;
5. resolving complaints and handling requests and enquiries;
6. preventing, detecting and investigating crime, responding to queries from enforcement agencies, and analyzing and managing commercial risks;
7. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
8. organizing promotional events and providing promotional offers;
9. conducting investigations relating to disputes, billing or fraud and preventing potentially prohibited or illegal activities;
10. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Upgrading.cc (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
11. enforcing our Terms of Use; and as otherwise described to you at the point of collection;
12. facilitating and completing the provision of travel products and services, including providing you with travel confirmation, travel notifications and updates;
13. facilitating daily operations of our travel products and services (including but not limited to managing your account, billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
14. processing of payment instructions, direct debit facilities and/or credit facilities requested by you;
15. enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
16. resolving disputes, collecting fees, or troubleshooting problems;
17. generating internal reports (including but not limited to annual, operational and management reports);
18. processing referral payments and commission fees to our external partners;
19. administering fee adjustments, refunds and waivers;
20. analysing your use of our travel products and services so as to help us improve, review, develop and efficiently manage the travel products and services offered to you;
21. and purposes which are reasonably related to the above or necessary for the above.

Furthermore, where permitted by law,

1. Upgrading.cc may also collect, use and disclose your personal information for the following “Additional Purposes”:
   1. analytics and tracking, including facilitating the sale of analytical data conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to Upgrading.cc's travel products and services, and to improve our service delivery and your customer experience at our touch points;
   2. providing additional travel products and services and benefits to you, including special offers, promotions, loyalty and reward programmes from Upgrading.cc;
   3. matching personal information with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of travel products and services by Upgrading.cc;
   4. leads generation and management for marketing Upgrading.cc's travel products and services; administering contests, competitions and marketing campaigns, and personalizing your experience at Upgrading.cc’s touchpoints;
   5. communicating to you advertisements involving details of our travel products and services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling);
   6. organizing promotional events and corporate social responsibility projects; and
   7. purposes which are reasonably related to or necessary for the above.

In relation to particular travel products and 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 information. If so, we will collect, use and disclose your personal information for these Additional Purposes as well, unless we have specifically notified you otherwise.

You have a choice to withdraw your consent in respect of the collection, use or disclosure of any of your personal data. You may contact us using the following contact details:

Attention to	:	Barry Chew [Data Protection Officer]
Email	:	customers@upgrading.cc
Telephone number	:	+65 9731 6168
Mailing Address	:	531A Upper Cross Street #04-95, Hong Lim Complex, Singapore 051531

Please be aware that once we receive confirmation that you wish to withdraw your consent for the collection, use and disclosure of your personal data, it may take some time for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/ communication during this period of time. We may also be required to obtain, access and/or use your personal information in order to provide you with products or services which you require or have requested. In the circumstances, if you withdraw your consent to any or all of the Basic Purposes, we may not be in a position to continue to provide our services to you.

Please take note that withdrawing your consent will not affect the lawfulness of any processing that we or our processors conducted prior to your withdrawal, nor will it affect processing of your information conducted pursuant to lawful processing grounds other than consent.

Email Communications

We want to make it easy for you to take advantage of travel-related opportunities on our Website. One way we do this is by sending you email messages that contain information about your travel-related interests. For example, if you search for a hotel upgrade on our Website and have saved your upgrade or otherwise not yet booked your travel, we may send you an email message reminding you about your saved hotel upgrade or about other similar upgrades from the hotels. We believe these email messages will provide you with useful information about travel-related special offers available through our Website. Please note that you will have the opportunity to choose not to receive these email messages in any such email we send. Please note that while we will not send you further emails from the list that you have elected to unsubscribe from, we may continue to contact you to the extent necessary to provide the products and/or services that you have requested, pursuant to our Terms of Use and other agreements. With whom we share your information

Upgrading.cc will take all such reasonable precautions as may be necessary to protect your personal information against unauthorized disclosure. Subject to the provisions of any applicable law, your personal information may be disclosed, for the purposes listed above (where applicable), to the following:

Suppliers, such as hotel who fulfil your upgrade reservations. Throughout this Website, all services provided by a third-party supplier are described as such. We encourage you to review the privacy policies of any third-party travel supplier whose products you purchase through this Website. Please note that these suppliers also may separately contact you as necessary to obtain additional information about you, facilitate your travel reservation, or respond to a review you may submit.

Third-party vendors who provide services or functions on our behalf, including banks, credit card processing, business analytics, customer service, marketing, promotions, distribution of surveys or sweepstakes programs, and fraud prevention. We may share your personal information with telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, interoperability, system operation and maintenance and billing between service providers. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of our Website or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

Business partners with whom we may jointly offer products or services, for example financial institutions, credit card services, telecommunications providers or travel-related services, as well as commercial shops and retailers in relation to providing rewards and benefits. You can tell when a third party is involved in a product or service you have requested because their name will appear with ours. If you choose to sign up to these optional, jointly-offered services, we may share information about you, including your personal information, with those business partners so that they can contact you directly by email or post about the products and services that you have signed up to receive. Such personal information may include your contact information as well as other information necessary to provide the travel product or service you have requested. Those third party business partners will not use your personal information for direct marketing purposes, except when permitted to do so by applicable law. However, please note that we do not control the privacy practices of these third-party business partners.

In the event that we share your personal information with such third party processors, we take steps to protect your information by requiring these third party processors to enter into a contract with us that requires them to use the personal information we transfer to them in a manner that is consistent with this Privacy Policy and applicable privacy laws.

Referring websites

If you were referred to this Website from another website, we may share some information about you with that referring website so that they can contact you directly by email or post about their products and services. We have not placed limitations on the referring websites use of your personal information and we encourage you to review the privacy policies of any website that referred you to this Website.

Companies within our corporate family

With your prior specific consent, we may share your personal information with our corporate affiliates in the leisure and travel sector and their respective employees. This sharing enables us to: provide you with information about products and services, both leisure- and travel-related, which might interest you; address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our travel products and services; activate, deactivate, install, maintain and operate our systems and/or services.. To the extent that our corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy.

Companies providing services to Upgrading.CC Companies, such as insurance, auditing, legal or consultancy services, as well as agents, contractors or third party service providers who provide operational services to Upgrading.CC, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services.

Others, including any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Upgrading.CC Companies; and any other party to whom you authorize us to disclose your personal information.

We also may share your information: Where required by local or foreign law in the good faith belief that disclosure is necessary to comply with applicable laws or legal processes.

When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities covering both local and foreign investigations; and upon request from law enforcement agencies in your jurisdiction, for example in order to protect and defend the rights, property, or safety of the Upgrading.CC Companies, their websites, or users of their websites; and in connection with our Terms of Use and other agreements.

In connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors this Website receives or the most popular hotels upgrades. This information does not contain any personal information and is used to develop content and services we hope you will find of interest and to audit the efficacy of our advertising.

How you can access your information

You can access, correct and update your contact information by visiting the My Account page on this Website. You can close your account by contacting us at the email address listed below or by going to My Profile after logging in.

Please note that after you close an account, if we no longer hold such information, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time.

Please also note that we may retain certain information associated with your account, including for analytical purposes as well as for recordkeeping integrity for a period of time, after which we will ensure such information is securely destroyed. Information we may retain includes, for example, accounting data, data for auditing purposes and transactional information and/or information required to be retained for compliance with law.

If you do not hold an account with us or wish to contact us in relation to any personal information that is not displayed in your account, you have the right to ask us to access, correct, delete or modify the information that we hold about you by emailing us at the email address listed below. You have the right to request to access the personal information that we hold about you free of charge. However, if the request affects the rights and freedoms of others or is manifestly excessive, we reserve the right to refuse such request or charge a reasonable fee to cover the administrative costs of providing such information to you.

You also have the right to add or update information and close your account as described above. When you register as a member on this Website, you will be given a choice as to whether you want to receive email messages from us about upgrading newsletters, special offers, as well as email messages about products and services of selected third parties. Whether registered as a member or not, you also will be given the opportunity to unsubscribe from messages in any such email we send.

Please note that we reserve the right to send you other communications, including service announcements, loyalty program updates, administrative messages, and surveys relating either to your account or to your transactions on this Website, without offering you the opportunity to opt out of receiving them.

The more options portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Please note that if you refuse to accept cookies from this Website, you will not be able to access portions of our Website.

Cookies and other Web technologies

We automatically collect some information about you and your computer when you visit this Website. For example, we will collect your IP address, Web browser software (such as Firefox, Internet Explorer or Safari), and referring website. We also may collect information about your online activity, such as trips viewed and purchases made. One of our goals in collecting this automatic information is to help customize your user experience.

As a member or visitor to this Website, you will be assigned a permanent cookie file on your computer's hard drive. When you access the My Inbox or My Profile areas of this Website, reserve or purchase travel, we may require you to sign in as a member, using your Member ID and password. Once you sign in as a member, we record the Member ID and the name on the member account in the cookie file on your computer. We may also record your password in this cookie file as encrypted data if you checked the box entitled "Save this password for automatic sign-in." Your Member ID, password, and the name on your member account is stored in the cookie file as encrypted data, so no one can view the information it contains by obtaining unauthorised access to your computer. Permanent cookie files remain on your computer's hard drive until you manually delete the file.

Using the mobile phone and tablet Apps (the “Mobile Apps”) When you use our Mobile App, we collect and use information about you in the same way and for the same purposes as we do when you use this Website. In addition to this, we also use some other information that we collect automatically when you use our Mobile Apps. Specifically:

We collect information about Mobile App functionality that you access and use. This allows us to identify those areas of the Mobile App that are of interest to our customers so that we can refine and continuously improve the Mobile App. The information we collect for this purpose does not enable us to directly identify you.

When you use a Mobile App, you can choose to allow access to your current location – provided by your mobile device using GPS or similar technologies – in order to identify nearby hotels, airports, or other travel service providers. If you choose to allow access, this location data may be collected anonymously as part of search requests logged by our servers. You can switch off the Mobile App’s access to your location at any time through your phone settings menu.

Transfer of personal information to other countries

Without limiting the generality of the foregoing, you authorise Upgrading.CC to transmit your information outside of Singapore in the manner and for the purposes described in this Privacy Policy on the understanding that such transfers will be in accordance with the Personal Data Protection Act 2012 and the transfer shall only be made to countries with comparable if not stricter personal data protection laws than Singapore.

Upgrading.CC is based in Singapore and your personal information may be transferred to, and be processed in Singapore and other third party countries. Whenever we transfer your personal information out of Singapore, we will take steps to protect your personal information by requiring these third parties to enter into a contract with us that requires them to use the personal information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws in the region.

Third-Party Sites

Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

External links

If any part of this Website links you to other websites, those websites do not operate under this Privacy Policy. We recommend you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.

Minimum Age

The minimum age of using our products, services, and Website is 16 and we will not knowingly collect the personal information from children under this minimum age without their parent’s consent. Insofar as certain countries require a higher age of consent for the collection of personal information, we will require parental consent before an account can be created on our Website.

Governing Law

This Privacy Policy shall be governed in all respects by the laws of Singapore.

Changes to this Privacy Policy

We may update this Privacy Policy in the future. We will notify you about material changes to this Privacy Policy by sending a notice to the email address you provided to us or by placing a prominent notice on our Website. Any changes we may make to our Privacy Policy in the future will be posted on this page. We may contact you where appropriate. Please check back frequently to see any updates or changes to our Privacy Policy.

Termination

Upon the closing of your account or as soon as it is reasonable to assume that the retention of your personal information is no longer necessary for the performance of Primary Purposes, we will cease to collect and/or store your personal information.

How you can contact us

If you have questions about either this Privacy Policy (or your travel planning or purchases) or any complaints about the processing of your personal information, please contact The Upgrading.CC Team at customers@upgrading.cc.. You can also contact your local data protection authority for further information or to file a complaint. We will do our best to respond to your request within 24 hours. This Privacy Policy is effective as of 14th May 2018.

In addition, if you are a resident of the EEA, you also have the right to complain to the local data protection authority within the EEA (DPA). You can find the details of your local DPA here.

One Stop Hospitality Solutions Pte. Ltd.
(Company Registration Number: 201633161K) 531A Upper Cross Street #04-95, Hong Lim Complex, Singapore 051531