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Creative Leap respects your right to privacy and we place the utmost importance in safeguarding any information that is shared with us by our guests.

General Information

1. Objective and Responsibility

• This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service and the related websites, features and contents (hereinafter collectively referred to as ‘online service’ or ‘website’). Details of these processing activities can be found in section 2.
• The online service is provided by Creative Leap, (Address in Singapore) – hereinafter referred to as ‘provider’, ‘we’ or ‘us’ - who is also legally responsible under the data protection law.
• You can reach out to our Data Protection Officer under: dpo@creativeleap.com.
• The term ‘user’ encompasses all customers, interested people, employees and visitors of our online service.

Purposes and legal basis for processing personal data

We process the personal information you supply to us via our website or at our hotels for the following purposes:

• To process and facilitate bookings, including verifying your identity, taking payments and communicating with you (legal basis: performance of the contract);
• To provide you with services at our hotels under the accommodation agreement, including execution of your stay at our hotels and payment processing (legal basis: performance of a contract);
• To make contact or interact with you and to handle your requests, remarks or complaints, which you have submitted via our website, during your stay orafter your departure (legal basis: consent or legitimate interests);
• To send you our e-mail newsletter including managing your subscription to the newsletter (legal basis: consent or legitimate interests);
• To execute and manage your participation in our loyalty programme (legal basis: consent);
• To maintain, safeguard and improve the quality of our products and services, in particular by performing and analysing satisfaction surveys and guest comments, by processing your personal data in our centralised guest database enabling us to recognise you as a returning guest, to better appreciate your expectations and preferences, to improve the quality and individual character of our communication with you and to create offerings tailored to you (legal basis: legitimate interests);
• To ensure compliance with house rules, to prevent and investigate criminal activities (in particular also by video monitoring), to establish, exercise and defend against legal claims and to safeguard our interests in legal disputes, to ensure IT security and IT operation and to identify credit risks, in accordance with applicable law (legal basis: legitimate interests);
• To provide you with information relating to Capella or promotional information about products and services that may be of interest to you, as well as personalized mailings (electronic or otherwise) or other communications (legal basis: consent or legitimate interests);
• To place cookies and to use similar technologies as further set out below and the information provided to us when those technologies are used (legal basis: legitimate interests);
• On other occasions where we ask you for consent, we will use the personal data for the purpose explained at the time (legal basis: consent);
• To comply with obligations imposed by local laws or regulations such as the police and tax authorities (legal basis: legal obligation);
• In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to process your personal data, including sensitive personal data you provided through our services, where it is in your vital interest or in the interest of others, for example in the event of a medical emergency (legal basis: vital interest).
• Wherever we rely on your consent, you can withdraw your consent at any time. However, we may have other legal grounds for processing your personal data for other purposes, such as those set out above.