1. Introduction

Ben Thanh-RSC Limited Company (hereafter referred to collectively “Norfolk Mansion”, “us’,” our” or “we”) owns and controls this website. We recognise that protecting the privacy of our customers (hereafter referred to as “customer”, “guest”, “you”) and their Personal Information (hereafter referred to collectively as “Personal Information”) is the basis of Norfolk Mansion’s business and one of Norfolk Mansion’s social responsibilities.

Norfolk Mansion uses Personal Information in order to deliver a high level of customer service, throughout the customer journey. As part of that undertaking, we are committed to safeguarding the privacy of the Personal Information that we gather.

As one of our customers, it is important that you understand and agree that we may collect, use, and share your Personal Information in accordance with this Policy.

2. What does Norfolk Mansion do?

Norfolk Mansion, which provides residences and hospitality services under “Norfolk Mansion”, “Shang Palace”, “Terrazzo Café” brands and “Norfolk Group Privilege Club” loyalty program, is comprised of a family of companies (collectively referred to as “Norfolk Mansion”, “we”, “our” or “us”), which owns mansion.thenorfolkgroup.com site and www.norfolkmansion.com.vn (the “Website”).

This Privacy Policy contains information on how Norfolk Mansion collects, uses, and shares information collected from you as well as how such information is protected from unauthorised access. This Privacy Policy only covers the Website. Our Site is hosted in a secure environment with all the systems are configured with data encryption. We use Secure Socket Layer (SSL) technology to protect your data.

3. Effective date of Privacy Policy

The effective date of this Privacy Policy is 09 May 2020.

4. Changes to Privacy Policy

This Privacy Policy is subject to revision at any time to respond to changes regards to related laws and regulations and to social needs related to Personal Information. The revised Policy on the Website will take effect immediately. We will update the Privacy Policy on our Website, if any of the changes to this Privacy Policy affect how we handle your information.

5. Why do we collect personal data?

5.1.Collecting Personal Information

In pursuance of providing services to you, we may need to collect Personal Information. When obtaining Personal Information, for the purpose to serve your specific request, only the necessary information is collected.

5.2. How information is collected

Personal Information is obtained by the following means during your transactions with us, related to our facilities or products (such as accommodation, events, bar/restaurant facilities, the provision/sales of amenities, services) and other transactions (referred to hereafter as “transactions”).

• Directly from the customer: by telephone, in writing, from business cards, verbally, or over the Internet.
• From a person duly authorised by the customer: such persons may include those making a reservation on behalf of a customer or to introduce a customer, travel agencies, and package tour companies.
• From published information: newspapers, Internet, telephone books, publications, and other written materials.

5.3. Types of Personal Information collected

The Personal Information collected by us may include the following information: name, place of work, home/work address, credit card details, email address, telephone number, fax number, date of birth, gender, requirements regarding guest rooms, leisure activities, and other services that require relevant information to fulfill any special requirements.

5.4. Right to refuse

At all times, the customer has the right to choose whether to provide Personal Information to Norfolk Mansion. However, if a customer refuses to provide Personal Information required for certain type of service, such as name or contact information, it may not be possible for us to provide the full service as requested by customer, such as making reservation.

6. How do we use your Personal Information?

6.1. Purposes

Any information you choose to provide may be collected by us in order to process your request and send you reply. Required and optional information is clearly presented on the form we give you.

6.2. Data collection

6.2.1. Data you provide voluntarily

In order to make a reservation, book a meeting, purchase our services or subscribe to e-marketing letter, we ask you to provide information voluntarily.

6.2.2. Data we collect automatically

Your IP address, location and other technical information such as how websites interact, links click can be collected automatically. This helps us understand who visited our website, their behavior, what types of information they searched. We analyze this information to improve our content and quality of our website. We also may use cookies and tracking technology.

6.2.3. Data from third party sources

In order to process your booking or request, we may receive Personal Information from third parties (including travel agents, tour operators, OTAs, meeting planners…). These third parties either have your consent or are legally permitted.

6.3. Use of cookies

Cookies may be collected from you through our internet servers and your use of “cookies” on your device. Both “session” cookies and “persistent” cookies can be used by us on the Website.

Session cookies will be used to keep track of you whilst you navigate the Website. Session cookies are deleted from your computer when you close your browser.

Persistent cookies enable our Website to recognise you when you visit. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

Norfolk Mansion uses “Google Analytics” to analyse and generate statistical and other information about Website use by means of cookies, which are stored on users’ computers. The information generated relating to the Website is used to create reports about the use of the Website.

Google will also store this information. Google’s Privacy Policy is available at: http://www.google.com/privacypolicy.html.

If you do not want information collected using cookies, please enable your device to disable this feature. You should note that some cookies may be necessary to provide you with some features offered on the Website, so any deletion of them may adversely impact how the Website functions to you.

Norfolk Mansion will explicitly state on the Website when Personal Information is required to be collected. However, subject to applicable laws, Norfolk Mansion may collect, use and share your information with certain third parties to fulfill your request and provide you services.

7. Provision to third parties and joint use of Personal Information

7.1. Limits

Norfolk Mansion does not sell any of your Personal Information.

Third parties are not allowed to use the Personal Information for their own purposes.

Norfolk Mansion may share your Personal Information if required by law, to protect the website or the company, or if our status changes (being operated by a new company).

7.2. Scope and purposes

If Personal Information is shared with third parties for the purpose of joint use, the joint use relates to the following:

• Direct Marketing: We will send direct marketing via the postal service and by email.
• Booking online: In order to process an order, payment details are taken, and contact information collected, such as name, address, telephone number, and email address.
• Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
• Analytics: To process your Personal Information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalized or aggregated basis, to help us with our activities and to provide you with the most relevant information.
• Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
• Due Diligence: We may need to conduct investigations on potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.

7.3. Consent

We also rely on consent for lawful processing where we have no legitimate interest.

An example of this may be when you sign up to receiving marketing activities through our website. Every marketing email we send gives you the opportunity to withdraw consent by unsubscribing.

7.4. Disclosure

We may on occasion, pass your Personal Information to third parties exclusively to process work on our behalf. We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Policy and GDPR (General Data Protection Regulation).

We do not pass on information gained from your engagement with us without your consent. However, we may share your Personal Information to meet legal obligations, regulations or valid governmental request.

8. Booking engines: Roiback

Your reservations at our Norfolk Mansion is handled by a third-party vendor namely ROIBACK.

When making room reservations, you will be connected with these booking engines and furthermore, bounced by ROIBACK’s Privacy Policy. Any information you provide is part of the reservation process and it will be shared with our properties.

9. Legal basis

We will ask for your consent when we collect Personal Information to process a contract or a request from you. We will advise you which part of your Personal Information is mandatory and which part is optional.

10. Retention Policy

We will keep your Personal Information for the duration of your contract. In the event we have none-ongoing transaction with you we may retain your Personal Information for five (05) years to meet any legal obligations. After five (05) years, we will delete it completely.

11. Your rights as a data subject

You have the following data protection rights as following:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

12. Security of Information

We take security of your Personal Information seriously by using technology and system appropriate to the risk. However, we cannot guarantee that the information on the internet is fully secured nor will it be on our own system.

13. Age Consent of Website User

Norfolk Mansion does not collect any Personal Information from children under 18 years of age. If we know that we collected it, we will delete the information immediately.

14. Miscellaneous

Our website may link to other websites of third parties, OTAs or affiliates and it is not bound by this Privacy Policy. You will be subject to the Privacy Policy of those sites.

Please contact us using the below information if you have any queries.

15. Norfolk Mansion information center

Ben Thanh – Norfolk Mansion Company Limited
Address: 17-19-21 Ly Tu Trong Street, District 1, Ho Chi Minh City, Vietnam, 700000
Telephone: (+84 28) 3822 6111
Email: sales@norfolkmansion.com.vn