PRIVACY POLICY

INTRODUCTION

Welcome to our website which features our exclusive Song Saa Private Island (the Island).

 

Before you click through to see the pictures of our beautiful Island, we want to refer you to some of the contents on our website relating to legal matters:

  • Our Booking Terms and Conditions
  • Data Protection
  • Terms and Conditions for Use of Our Website
  • How to Contact Our Data Privacy Team

 

OUR BOOKING TERMS AND CONDITIONS

Please click here to see booking terms and conditions and cancellation policies for the Island.

 

DATA PROTECTION POLICIES

We Are Committed to Protect Your Privacy

 

THE SONG SAA GROUP

Song Saa Limited is the holding company of the Song Saa Group. It is a Hong Kong registered company and located at Workshop 2, 10/F, The Factory, 1 Yip Fat Street, Wong Chuk Hang, Hong Kong. It has several

subsidiaries and associated companies operating in Hong Kong and Cambodia. The operator of the Island is Brocon Investment Co., LTD. which is a Cambodian company. Your booking is with this company.

The Song Saa Foundation operates through two separate legal entities:

  • Koh Song Saa Foundation Organization of #10, Street 618, Khan Tuol Kork, Phnom Penh, Cambodia which is a

registered non-governmental organisation in Cambodia; and

  • Song Saa Foundation (Hong Kong) Limited whose registered office is at 10F, The Factory, #1 Yip Fat Street,

Hong Kong and is exempt from tax under section 88 of the Inland Revenue Ordinance of Hong Kong.

Where we refer to the Song Saa Group on our website, this includes all the above entities (the “Song Saa Group”), all

of whom are committed to protecting your privacy.

 

To ensure you can make informed decisions and feel confident about supplying your personal data to us, we outline our data collection practices and the choices you have concerning how the data is being collected and used.

 

Data” refers to any personal information that can be used to identify you as an individual. It can include, among other things, your name, contact number, address, age, gender, passport or other identification document details, personal financial information, frequent flyer or travel partner information.

 

We limit the collection, use and retention of your Data to the specific information we need for legitimate purposes to administer our business, to provide you with the best service and to offer services and products from the Song Saa Group that may be of interest to you. We take appropriate steps to protect your Data against unauthorised access, disclosure or alteration, and to keep such Data up to date.

 

To protect your Data, we will require that you prove your identity to us in relation to your request to access your Data, which may consist of a copy of a government-issued identification, your signature and correspondence address so we can check them against our records and satisfy ourselves as to your identity. This information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Data.

 

This statement of our Data Protection Policies is current as of 1 January 2017. All changes will be included in the latest statement of our Data Protection Policies published on this website, so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclosures of that information to third parties. We will seek your express consent to any changes to how we use or disclose your Data if requested by law but otherwise use of this website or our services following such changes constitutes your acceptance of the latest revised statement.

 

We will now explain the steps we take to respect your privacy concerns.

 

Data we collect and how we use it

 

When you want to make a reservation at the Island, we will request Data such as your name, address, telephone number, e-mail address, identity card or passport details and credit card information for payment purposes (including credit card number, code and expiry date). We will use your e-mail address to send an e-mail confirmation of your booking and a pre-arrival message summarising your confirmation details and preferences. Such pre-arrival message will include other information about the Island, the area and the weather.

 

We may also ask for your travel details (including flight number, arrival and departure dates and time, as well as country/point of origin and destination) and room preferences to prepare ourselves for your arrival and to assist you with your departure.

 

For related operations of the Song Saa Group, we may ask you for the same Data. We collect and use such Data to administer our business, and to offer various related products or services that may be of interest to you or where you indicate interest in being a patron of, or donor to, the Song Saa Foundation.

 

When you browse our website, we do not collect Data unless you voluntarily and knowingly provide it to us, for example by accessing our website from a link in an e-mail that we send to you.

 

The Data that you provide to us for making a reservation is made available to the Island for the purpose of completing your reservation request. We may also need to collect information as required by local laws such as passport numbers, type of entry visa, and driver’s license. Upon check-in, your Data will be verified by our staff and you will be requested to indicate whether you wish to opt in and receive promotional literature. At times, we may make certain Data available to strategic business partners such as mail houses and e-mail service providers for the sole purpose of mailing and dissemination of promotional materials for the Song Saa Group. Data will not be shared with third parties for their own marketing purposes.

 

When making a reservation, you will be asked to provide Data such as your name, address, telephone number, address and method of payment, room preferences and special requests. This Data will be sent in a secured environment to the Island. If you choose to provide us with your e-mail address, a confirmation and a pre-arrival message of your reservation will be sent to you by e-mail.

 

During your stay at the Island, we record your itemised spending to properly assemble your bill, which includes your room rate and other expenses billed to your room. We also record this information to comply with financial reporting requirements and those imposed by our auditors and government authorities. To ensure your future comfort and attention to your individual needs, other stay specific information may also be stored in the property management system at the Island, such as your food and beverage preferences and other special requests.

 

If you use our spa on the Island, we collect Data such as your name, contact details, and where necessary, credit card information for payment purposes when you make a spa reservation. In addition, we may also collect information relating to your health, allergies and treatment preferences before the spa treatment is commenced to ensure that your spa treatment is conducted under safe conditions.

 

Data we receive from third parties

 

This policy statement does not apply to our processing of Data on behalf of, or at the direction of, third party providers (for example, airlines, car rental companies) who may collect Data from you and provide it to us. In this situation, we would merely act as a data processor and thus advise you to review applicable third party providers’ privacy policies before submitting Data.

 

Fraudulent E-Mails

 

Please note that the Song Saa Group will never send you an e-mail requesting your credit card number or passport, personal identity card or social security number. If you receive any suspicious e-mails that looks like it is from us, but asks you for your credit card number or passport, personal identity card or social security number, it is a fraudulent e-mail, or “phishing”. We recommend that you do not reply to the e-mail or click onto any links or pop-up messages and report to the local authorities which handle fraudulent e-mails. If you believe “phishers” have gained access to your personal or financial information, we recommend that you also change your password(s), alert your credit card service provider and bank and review credit card and bank account statements to check for unauthorised charges.

 

Unsecure Communication

 

It is important to note that all e-mail communication is not secure. There is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail, for example, from the “Contact Us” section of our website. We recommend that you do not include any sensitive information including credit card details when using e-mail or using any public computers/public WIFI. Our e-mail responses to you will not include any sensitive or confidential information. Please bear in mind that no security system or system of transmitting information over the Internet is guaranteed to be secure. To be prudent, it is advisable to always close your browsers when you have finished completing a form or a reservation. Although the session will automatically terminate after a short period of inactivity, it is easier for a third party to gain access to your profile whilst you are logged onto our website and making a reservation.

 

Internal Controls

 

The Song Saa Group trains its employees and staff on the importance of Data privacy and protection. Our privacy policy is updated as required to reflect any changes in applicable laws and developments in best practice procedures. Further, we limit the number of individuals within the Song Saa Group with access to Data to those directly involved in the process of providing our services to you.

 

How we store and transmit Data

 

Your Data may be shared with companies forming part of the Song Saa Group. We have policies and procedures to limit access to Data to authorised personnel only.

 

We store certain customer information and reservation details in our systems. Our systems are secure customer databases stored on a dedicated server located in a data center in Hong Kong hosted by a third party service provider. The stored database includes Data such as guest name, address, phone numbers, position, company name and credit card information. We may also store other information such as your room, food and beverage, other service preferences and transaction history.

 

Our server resides behind firewalls to protect the Data collected from you against unauthorised or accidental access. Because laws applicable to personal information vary by country, we may put in place additional measures that vary depending on the applicable legal requirements.

 

We maintain a database of customer information which is used for marketing, promotion and research, understanding and analysing customer behaviour and customer profiling to improve our services. You will receive marketing and promotional materials if you have already given your express and specific consent in some data collection forms. You may elect to unsubscribe from receiving future e-mail promotions at any time.

 

Secure Transmission and Storage of Data

 

We treat all Data that you provide to us as confidential information. To prevent Data from unauthorised access or leakage, we have adopted and regularly monitor our group’s security and data privacy policies and procedures. We use SSL protocol – an industry standard for encryption over the Internet, to protect the Data. When you type in sensitive information such as credit card details, it will be automatically encrypted and transferred over a SSL connection. This ensures that your sensitive Data is encrypted as it travels over the Internet. You will know that you are in a secure mode when the security icon (such as a lock) appears in the computer screen.

 

The nature of our business and our operations require us to transfer your Data to other member of the Song Saa Group and to the Island in Cambodia, for the purposes mentioned in this policy. Although the data protection and other laws of other countries may not be as comprehensive as those in your own country, the Song Saa Group will take appropriate steps to ensure that your Data is protected and handled as described in this privacy statement. Therefore, we will seek to implement appropriate measures, including contractual clauses, to secure the transfer of your Data to recipients (which may be internal or external to the Song Saa Group) located in a country with a level of protection different from the one existing in the country in which your Data is collected.

 

Disclosure of Information to Third Parties

 

In addition to the required information sharing described above, we use the services of third party agents, such as e-mail service providers and mail houses for the purpose of mailing materials to our patrons. These parties are contractually prohibited from using Data for any purpose other than for the purpose specified in their respective contracts. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the sale of Data to entities outside of the Song Saa Group for any use unrelated to our group operations or use of Data by third party for their own purposes. We will implement, where necessary appropriate measures, including contractual clauses, to secure the transfer of your Data to the third party service providers located in a country with a level of protection different from the one existing in the country in which your Data is collected.

 

How we track customer usage on our website

 

Our website only uses “cookie” technology as a tracking tool. Cookies do not retain registered guests’ information provided during the online reservations or registration. Cookies identify your browser, rather than you and cannot be used by themselves to disclose your individual identity. Cookies enable us to track the number of page visits from the same computer or browser to be aggregated for statistical purposes.

 

Cookies do not corrupt or damage your computer, programs, or computer files.

 

The purpose for which cookies -- other than those which are either exclusively intended to enable or facilitate communication by electronic means or strictly necessary for the provision of an online communication service at your express request -- are used on our website is set out in a banner appearing the first time you land on our website. By continuing to browse on our website, you consent to their use.

 

You may set your browser to block Cookies, although doing so will affect your ability to perform certain transactions, use certain functionality, and access certain content on our website. Procedures for managing your settings may differ depending on your browser. Please consult the instructions for your particular browser on how to do this. For commonly used browsers, please click the links below:

Microsoft Windows Explorer
Google Chrome
Mozilla Firefox
Apple Safari

If you do not use any of the browsers listed above, choose the "Help" function, followed by "Cookies" to find out where your cookie folder is stored.

 

Our group and our third-party service providers may use pixel tags (also known as “clear gifs”, “beacon gifs” etc.), tracking links and/or similar technology to:

  • track customer response to Song Saa advertisements and website content;
  • determine your ability to receive HTML-based e-mail messages. Our e-mail service provider includes a pixel tag, which they refer to as a “coded sensor” in all of the HTML-based messages sent on our behalf. The sensor activates when the e-mail message is opened and flags the e-mail address of the user as one that is capable of receiving HTML-based e-mail messages. This capability helps our service provider to send the e-mail in a format you can read. The sensor does not collect or use any other information. If you cannot receive HTML, you will not receive a functioning sensor;
  • know how many users open an e-mail and allow our service provider to compile aggregated statistics about an e-mail campaign for us; and
  • allow us to better target interactive advertising, enhance customer support and site usability, and provide offers and promotions that we believe would be of interest to you. Your Data will not be collected apart from what you voluntarily provide us in your dealings with our group operations.

 

E-mails about Special Offers and Promotions and Opt-Out

 

With your consent, we may send you information about The Song Saa Group and its operations and activities, including special offers on accommodation, food and beverage, spa and other leisure services by post or e-mail. It is however our intention to only send you mail and e-mail communications that you may want to receive. When you opt-in or do not opt-out from receiving promotional material and provide your e-mail address to us specifically and expressly in order to receive marketing communications, we will periodically contact you via e-mail and provide information about special offers and promotions that may be of interest to you. These communications will relate to offers relating to the Song Saa Group. We typically use third party e-mail service providers to send e-mails. These service providers are contractually prohibited from using your e-mail address for any purpose other than to send e-mails related to our group operations. Data will not be shared with third parties for their own marketing purposes.

 

Unsubscribing

 

We provide you the ability to unsubscribe from all marketing communications. Every time you receive an e-mail, you will be provided with the choice to opt-out of future e-mails by following the instructions provided in the e-mail. You may also opt-out by contacting our Data Privacy Team.

 

Please allow 10 business days for us to process your opt-out.

 

How long will Data be retained for?

 

Your Data will be stored for the period of time required or permitted by law in the jurisdiction of the operation holding the information.

 

Data may be stored by the Song Saa Group as long as required for the business purpose for which these Data are processed.

 

Notifications in the event of breach

 

In the unlikely event of a Data breach, we are prepared to follow any laws and regulations which would require us to notify you of the disclosure of private information.

 

Careers

 

Our website allows individuals who wish to be considered for potential employment to attach their curriculum vitae for consideration. We will not use the Data you provide for any purpose other than to determine your qualifications for potential employment with the Song Saa Group.

 

Other Sites

 

The Song Saa Group is only responsible for the privacy statement and content of this website. Our website may contain links to other sites of third parties. We are not responsible for the data collection and use practices, privacy policy or the use of cookies on other websites that you have accessed this website from and to the non-Song Saa Group websites that you may access from this website. We advise you to review the privacy policies of such third parties before submitting personal Data.

 

Children’s Privacy

 

This website is not intended for children and minors and we do not knowingly solicit or collect Data from children and minors. As a parent or legal guardian, please do not allow your children to submit Data without your permission.

 

Legal Disclaimer

 

This privacy statement complies with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region. There is currently no similar privacy law in the Kingdom of Cambodia where the Island is based.

 

As a business with operations outside Hong Kong, we may need to disclose Data when required by relevant law or court order, or as requested by other government or law enforcement authorities. This also applies when we have reason to believe that disclosing the Data is necessary to identify, investigate, protect, contact or bring legal action against someone who may be causing interference with our guests, visitors, associates, rights or properties (including this website), or to others, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

 

TERMS AND CONDITIONS FOR USE OF OUR WEBSITE

 

These are important for both you and us. You must read them because, by using our website, you're indicating that you accept and agree to comply with them. We may amend these terms (especially if we add new products or features to our website), so check them regularly because your continued use of our website will indicate that you accept and agree to any amendments.

 

You agree to use our website in accordance with these terms and conditions, only for lawful purposes and in a way which does not infringe the rights of anyone or restrict or inhibit anyone's use and enjoyment of our website. If you don't comply with these terms, we may deny you access to our website.

 

Our website provides online booking facilities in respect of bookings at the Island. Any booking that you make will be subject to your agreement to Our Booking Terms and Conditions available on this website.

 

You may download and print content from our website only for your private, personal and non-commercial use. We do not guarantee or warrant that any material available for downloading is free from infection, viruses, trojans and/or other contaminating codes.

 

You agree to provide information that is truthful and accurate. You agree to use the enquiry and booking forms on our website to make only genuine enquiries and/or bookings for you or for other persons for whom you are authorised to act.

 

You will not use our website to send by e-card, email, post or otherwise transmit any material that is unlawful, threatening, abusive, defamatory, invasive of privacy, vulgar, obscene or profane.

 

You agree not to reproduce, distribute, modify or re-post our content on another site, frame or mirror any part of our website or link to our website without our prior written consent.

 

You grant to the Song Saa Group a non-exclusive, perpetual, irrevocable, royalty-free, worldwide licence to use (including but not limited to publishing, exploiting and modifying) any material you email, post or submit to us. For the avoidance of doubt, we will be free to use any ideas, concepts, know-how, content, text or images contained in your communications with us for any purpose whatsoever, to the fullest extent permitted by law.

 

We try to update our website regularly, so we may have to suspend access, service or functionality on our website, from time to time, without notice. If required, we may have to close our website indefinitely. We will not be liable if, for any reason, our website is unavailable at any time or for any period of time.

 

As information or data transmitted to or from our website passes over public telecommunications networks, we can't promise that the operation of our website will be secure, confidential, uninterrupted or error-free. You agree not to do anything that does or may interfere with the proper working of our website including but not limited to tampering with, or hacking into, our website or the servers on which they reside.

 

We own, or are the licensee of, the intellectual property rights in the content of our website, including but not limited to text, photos, graphic designs, images, audio, video recordings and any data entered or stored by you (the intellectual property rights in which you assign to us).

 

Song Saa is our registered trade mark.

 

Use of our website does not give you any right to use or reproduce any of its content or the trade marks on it.

 

Our website may contain links to third party sites and resources. We have no control over the contents of those sites, resources or third parties and accept no responsibility for them, or for any loss or damage that may arise from your use of them. We do not review, censor, approve, edit or endorse any information placed on third party sites or resources.

 

Our liability

 

The material on our website is provided without any guarantees, conditions or warranties, including warranties of merchantability, non-infringement of intellectual property, fitness for purpose, or accuracy or completeness of any information.

To the fullest extent permitted by any applicable law, the members of the Song Saa Group and any third parties connected to us exclude:

  • all conditions, warranties and other terms which otherwise be implied by statute, common law or the law of equity; and
  • any liability for any direct, indirect or consequential loss or damage incurred by you in connection with our website or in connection with the use, inability to use, or results of the use of our website, any sites linked to it and any materials posted on it, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable.

 

Except as expressly set out in these terms, all representations, warranties, conditions and other terms implied by statute, common law or otherwise are excluded to the fullest extent permitted by law. However, nothing in these terms is intended to exclude our or your liability for death or personal injury arising from negligence.

 

Commentary and other materials posted on our website do not amount to an offer to contract or advice on which reliance should be placed, and we do not intend that you should interpret it as such. We disclaim all liability and responsibility arising from any reliance placed on such materials by anyone visiting our website, or by anyone who may be informed of any content on our website.

 

We have technical and organisational security measures in place to prevent the loss of or unauthorised access to your personal information. While we do our best to ensure the security of your data, we cannot guarantee the security of information transmitted over the Internet.

 

From time to time, we may update and change these terms without notice. You will always find the latest version of these terms on our website. Your continued use of our website will indicate that you accept and agree to any amendments.

 

If any of these terms are held to be illegal, invalid or unenforceable by any court of competent jurisdiction, the remainder of these terms will continue in full force and effect.

 

The Hong Kong courts will have non-exclusive jurisdiction over any claim related to a visit to our website. These terms of use will be construed in accordance with, and governed by, the laws of Hong Kong.

 

You agree that any member of the Song Saa Group may rely on and enforce these terms, but otherwise we and you agree that no other third parties are to be given any rights under the Contracts (Rights of Third Parties) Ordinance.

 

You agree that we may assign or novate these terms to anyone without notice to you.

 

HOW TO CONTACT OUR DATA PRIVACY TEAM

 

If after reviewing our Data privacy policy, you have any privacy questions or concerns or would like to request access to, correction or object to the processing of your data for legitimate purposes, please contact our Data Privacy Team.

 

BY EMAIL

info@songsaa.com

 

BY MAIL

Data Privacy Team
Workshop 2, 10/F, The Factory, 1 Yip Fat Street, Wong Chuk Hang, Hong Kong 

 

Please allow 10 business days for us to process any correction of Data

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