1. Scope

This Privacy Policy (‘Privacy Policy’) applies to personal data that we collect from you when you make a booking (including and not limited to the booking made for accommodations, treatment at one of our spas, events and screenings, restaurants) or visit any of our properties (for booking of accommodation, spa treatment, event and screening, restaurant or any other reason whatsoever), or use any of the services at one of our properties, spas or other facilities.

This Privacy Policy provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including but not limited to the Information Technology Act, 2000 or any other legislation applicable in India, for the time being in force.

• ‘Personal data’ as used in this Privacy Policy means any information that relates to you and from which, you can be identified.

• This Privacy Policy supplements the website Privacy Policy provided on the relevant website, you interact with when you make a booking.

• By submitting your personal data, you hereby certify that you have gone through the terms of this Privacy policy and you accept the same.

2. Data controller

The data controller responsible for your personal data (as provide by you) is the Espire Hospitality Group company with whom you make a reservation (‘Company’, ‘we’, ‘us’ and/or ‘our’)

3. The personal data that we collect

We collect the following personal data about you when you make a reservation:

• Contact information, such as your first and last name, mailing address, email address, and telephone number;

• Language preference;

• Credit card number or other payment account details, billing address, and other payment and billing information (‘Payment Information);

• Records and copies of your correspondence, if you contact us;

• Guest-stay information, including the properties where you have stayed, date of arrival and departure, and goods and services purchased;

• Depending on the type of reservation, we may also ask for your gender and date of birth, important dates, such as birthdays, anniversaries and special occasions, names of any guests travelling with you and any preferences (such as meal preferences and health conditions) which you advise us when you make your reservation; or which we learn about you during your visit at one of our properties.

Other information

When you visit the relevant reservation website, we will automatically collect certain information, including through cookies and other technologies. Please read the Privacy Policy made available on the relevant website for information on the types of data that we collect in this context.

Sensitive data:

In some cases, in connection with your reservation, we may need to collect personal data that is considered sensitive data by the law, such as information about your health (for example, allergies or other health conditions). On such occasions, we will only use your personal data for the purposes, which we will explain at that time and we will seek your consent for the said use. Depending on the circumstances, and processing of sensitive data about you, it may also be necessary to protect your or a third party’s vital interest or for reasons of public interest in the area of public health.

If you submit any personal data about other people to us or our service providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to collect and use such data in accordance with this Privacy Policy.

Some of the personal data we request is necessary for us to perform our contract with you and/or to comply with our legal obligations and if you do not wish to provide us with such personal data, it will affect our ability to provide the services you request to us. If the provision of your personal data is purely voluntary, we will inform you accordingly. In case you do not wish to provide us required information, there will be no implication upon you of this policy

4. Where we obtain personal data from

We collect your personal data in the following ways:

4.1 When you make a reservation

We collect personal data that you provide to us directly when you make a booking through our websites, by email or phone, or communicate with us. If you need to get in touch with our customer service team, or reach out to us through other means (such as through social media), we will collect your personal data from there.

4.2 Property visits

We collect personal data when you visit our properties or use on-property services and facilities, such as restaurants, concierge services, SPA’s etc.

4.3 Third Party Service Providers

You may make a reservation for our services through third-party service providers such as online restaurant-reservation or travel-fare aggregator websites. When you use some of these websites, you provide you’re the reservation details to such third-parties, who in turn forward your such details to us to finalise and administer your reservation. When you make a reservation on a third-party website, we advise you to please also take the time to read their privacy policy/notice, if you wish to understand how these parties may process your personal data.

You are under no legal obligation to furnish any personal data about you, and the furnishing such data is at your discretion and at your own free will. However, if you do not furnish certain information about you, we may not be able to provide our services to you.

5. How we use your personal data

We use your personal data in the following ways:

• To complete and administer your reservation and stay, including processing your payment, ensuring that your room is available, and provide you with related customer service, including sending confirmations or pre-arrival messages, assist you with meetings, events or celebrations etc. Such use of your data is necessary to perform our contract with you or, before a reservation is completed, to take steps at your request prior to entering into a contract.
• As necessary for our legitimate interests or those of a third party to which we are transferring your personal data, the same include the following:

• Our reservation website may allow you to create a user account. We use the information you give us to administer this account, allowing you to do a number of useful things such as managing your reservation, taking advantage of special offers, make future reservations easily and manage your personal settings etc.;

• To communicate with you in relation to your reservation and stay, including and not limited to respond to and handle any requests you have made, to send you administrative information, such as security alerts, or send you a questionnaire or invite you to provide a review about your experience with us. If you have not finalised a reservation online, we may contact you with a reminder to continue with your reservation. We believe that this additional service benefits you as it allows you to carry on with a reservation without having to fill in your reservation details again;

• To conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our customers and our communications, including and not limited to, by creating customer profiles to enable personalised direct marketing communications;

• To provide you postal communications which we think will be of your interest;

• To administer this website, to better understand how visitors interact with our websites and ensure that our website is presented in the most effective manner for you and for your computer/device;

• If you ask us to delete your data or to remove the same from our marketing lists and we are required to fulfil your request, but we shall keep the basic data to identify you and prevent further unwanted processing;

• To share personal data among our affiliated businesses for administrative purposes and in relation to our sales and marketing activities

• We may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, for commercial, statistical and market research purposes, including conducting research on demographics, interests and behaviour. We sometimes ask our customers to take part in market research. Please see the information provided when you are invited to participate in market research in order to understand what personal data is collected and how your personal data is used further;

• For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our website, network and information systems secure;

• To, (a) respond to requests from competent authorities; (b) enforce our house rules, where applicable; (c) protect our operations or those of any of our affiliated businesses; (d) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and for enforcing or defending legal rights, or preventing damage;

• As necessary to comply with applicable laws and regulations;

• Our Company and our affiliated businesses may provide you, or permit selected third-party service providers to provide you, with information about goods or services, events and other promotions we feel may interest you. We (or such third-party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.

As used in this Privacy Policy, ‘Legitimate Interests’ means the interests of our Company and our affiliated businesses in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see ‘Your Data Protection Rights’ section below).

6. Disclosure of your information

We share your personal data with third parties in the following situations:

Service providers

Our Company, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed ‘Payment Information’), (ii) credit reference agencies to protect against possible fraud, (iii) providers of software management solutions for spa and wellness businesses, (iv) reservation platforms, (v) hosting and other information technology and related infrastructure service providers, (vi) web analytics providers, (vii) providers of digital advertising services and (viii) providers of CRM, marketing and sales software solutions.

Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Espire Hospitality Group affiliated businesses

We operate on a global scale. In order to provide the services, you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including to offer products and services to you. Our affiliated businesses will only use your data for the purposes for which we originally collected it.

Business transfers

If we sell our business or our company assets are acquired by a third-party personal data held by us about our members, membership applicants or customers may be one of the transferred assets.

Administrative and legal reasons

If we need to disclose your personal data: (i) To comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process; or (ii) To enforce our Terms & Conditions, house rules or other applicable contract terms that you are subject to; or (iii) To protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

7. Payment information

Any credit/debit card payments and other payments you make through our website will be processed by our third-party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.

We may arrange that card or payment data you submit in connection with your reservation is stored for the purpose of processing any future payments that you make. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted. You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details for the purpose of making any future purchases or reservations.

8. Personal data transfers

Your personal data may be transferred to and stored in countries other than the country in which the information was originally collected, for the purposes described above. Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the country in which the information was originally collected Where we transfer your personal data to countries outside of the country in which the information was originally collected, we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable laws, such as implementing standard contractual clauses for data transfers. We have implemented data transfer agreements pursuant to applicable data protection law in order to implement appropriate safeguards for the transfer of personal data to Espire Hospitality Group Resorts & Spa group and affiliated companies in countries outside the country in which the information was originally collected.. If you would like to receive more information on the safeguards that we implement, including copies of relevant data transfer contracts, please contact us as indicated below.

9. Tracking and Do Not Track disclosures

Please be advised that parties other than the Company may collect personal data about the online activities of the users of this website over time and across different websites when a consumer uses this website. We shall not be responsible for any use / misuse of such data by such other party.

Do Not Track (‘DNT’) is a privacy preference you can set in most browsers. If you enable DNT on your browser, we will honour your request not to be tracked across the internet. For more information, including how to turn on DNT, visit allaboutdnt.com.

10. Children

The website is not directed to children who are under the age of 18 years or another legal age determined by the laws of the country where you live (whichever is higher). The Company does not knowingly collect personal data from minors. If you have reason to believe that a child under the applicable legal age has provided personal data to the Company through the website, please contact us and we will endeavour to delete that information from our databases.

11. Security

Where we have given you (or where you have chosen) a password or login which enables you to access certain restricted parts of our website, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or login details with anyone else.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100 percent guarantee the security of personal data that you provide to us online.

12. Personal data retention

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for six years after expiration or termination of your membership. We retain information submitted through our website and the other websites we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means. Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

13. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable laws, we will notify you of any material or substantive changes to this Privacy Policy.

14. Cookie Policy

We use cookies for tracking purposes.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser (like Internet Explorer) settings. Each browser is a little different from the other browser, so look at your browser’s help menu to learn the correct way to modify your cookies.

If you disable cookies, some features will be disabled that make your site experience more efficient and some of our services will not function properly.