Privacy Policy

INTRODUCTION

This privacy policy (“Privacy Policy”) is issued by Ventive Hospitality Limited and its subsidiaries, affiliates, associate companies and joint venture companies (collectively referred to as “VHL”, “VHL Group”, “we”, “us” or “our” in this Privacy Policy).

Protecting data privacy: This Privacy Policy explains the collection, management and disclosure your information (whether through our website, our hotels, our social media pages, or in any other formats) and the choices you have about how we use your information. You are encouraged to review the privacy policy whenever you provide your information by visiting www.VHL.co.in or at the hotels or through other offline channels to make sure that you understand how your personal information will be used and retained. From time to time, specific additional rights may apply in accordance with applicable law.

Please read this Privacy Policy before using www.VHL.co.in or using/availing any of our products and/or services or submitting any personal information. This policy will be updated as required, for the purposes of reflecting changes in information collection, activities performed or any applicable regulations.

APPLICABILITY

This Privacy Policy is applicable to:

1. Any Person who accesses and uses www.VHL.co.in including but not limited to external legal entities in any form or manner;
2. Our customers who visit or stay at our properties;
3. Third party service providers/stakeholders or their representatives;
4. Employment candidates, current and former employees; and
5. Third parties seeking opportunities to associate with or work with VHL.

“Person” shall mean any individual, joint venture, company, corporation, partnership (whether limited or unlimited), proprietorship, trust or other enterprise, Hindu undivided family, union, association, government (central, state or otherwise), or any agency, department, authority or political subdivision.

INFORMATION WE MAY COLLECT

VHL collects your personal information in accordance with the law. The information we collect may vary by territory/country or by your preferred method of interaction with us. The categories of personal information that we may collect (from our customers / website visitors / third party services providers) include:

• Contact and identification information including first and last name, email address, postal address, country, phone number, other similar contact data, professional title, employer or professional affiliations, passport and visa information and information from other government IDs.
• Payment and Credit Information: We may collect credit card and other payment method details.
• Other information: We may collect information such as your age, sex, date of birth, marital status, nationality, occupation, ethnicity, religion, travel history or any other personal information provided in responses to surveys or questionnaires.
• Technical information: We may collect information such as website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
• Audio and Visual Information: We may record our customer service calls and security footage at our properties, which may include your voice and/or image; and

Any information that you submit, including any personal information relating to other people to us or to our service providers in connection with the services, you represent and warrant that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Most of the personal information we process is the information that has been provided to us by you knowingly. Personal information may also be inferred on the basis of the information provided by you or personal information received from a third party, such as a recruitment agent or background check vendor. 

Please note that if you do not provide certain information, certain objectives outlined herein may not be accomplished throught the website and you may not be able to use certain tools and systems which require the use of such personal data.

The use of this website and services provided herein, shall be deemed to be valid consent by you to allow us to use and process the personal information. We reserve the right to discontinue our services or our engagement for which the information is sought should you at any time withdraw such consent.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect the above-referred categories of personal information from the following categories of sources:

• Data provided to us directly by any party
• We receive and store any information you enter on our website or third-party hotel booking websites or give us in any other way (e.g., at reception, kiosks).
• We use cookies and related technologies to passively collect personal information from and across your devices when you interact with our website, emails, or other online content or when your device connects to, or is detected by, the wireless networks at our properties.
• From social media: If you post to one of our pages on a social media site, we may receive contact and identification information, stay and purchase information, internet and network activity, and any other personal information contained in your social media posts or profile.

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HOW WE USE YOUR PERSONAL INFORMATION

Any of the information we collect from you may be used in one of the following ways:

• carry out our obligations arising from any contract entered into between you and us;
• fulfil other purposes as disclosed to you in accordance with applicable law or with your consent;
• provide you with information about the services and sending you information about materials, newsletters, events, conferences and offers;
• provide products and/or services and communicate with you about products and/or services offered by us;
• conduct market research, customer satisfaction and quality assurance surveys;
• process, disclose, transmit, and/or share the information with third parties which have business or contractual dealings with us;
• administer general record keeping;
• meet legal and regulatory requirements or compliance obligations;
• provide privileges and benefits to you, marketing and promotional campaigns based on your profile;
• communicate with you (including to respond to your requests, questions, feedback, claims or disputes) and to customize and improve our services;
• enforce the terms of use of our website;
• prevent, detect, and investigate fraud, cyber incidents, or other illegal or harmful activity;
• for any emergency and incident response ensuring the security of on-site services, responding to, handling, and documenting on-site accidents and medical and other emergencies (including facilitating in house doctor services), actively monitoring properties to ensure adequate incident prevention, response, and documentation (including CCTV), requesting assistance from emergency services, and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.); and
• to otherwise support your relationship with VHL.

DISCLOSURE OF INFORMATION

From time to time, we may use and/or disclose your personal information in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we disclose your information to third parties. When you consent to this Privacy Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such third parties for the purpose and to the extent stated in this section and as described in the part (How We Use Your Personal Information) above.

HOTEL OPERATOR USE OF CUSTOMER DATA

Our hotel operators at various properties process customer information and other data. Please read the privacy policy of the respective hotel operators to understand how your information may be processed by the respective hotel operators.

COMMITMENT TO DATA PRIVACY & SECURITY

In order to provide confidentiality and security of the information provided by you, various technical, physical and organizational security measures have been put in place to protect against any unauthorized access, disclosure, damage or loss of your information. While collection, transmission and storage of information can never be guaranteed to be completely secure, we take steps to ensure that reasonable security safeguards are in place to protect your information. 

Only required, selected or authorised employees, business partners, vendors and other third party providers may have access to your information. VHL takes reasonable measures to ensure that our third party service providers employ industry standard security measures to ensure the security of information through legally binding terms and conditions.

LINKS TO OTHER SITES

Our websites and applications contain links to websites that are maintained and/or controlled by nonaffiliated parties. In some instances, these websites may be co-branded and display our logos or other trademarks. This Privacy Policy and our responsibility arising from it is limited to our own information collection practices. VHL shall not be responsible for the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. We encourage you to review the privacy policies of each of these websites as their privacy policies may differ from ours.

RETAINING YOUR INFORMATION IN OUR SYSTEMS

Your information may be stored for as long as is reasonably required for the purposes explained in this Privacy Policy. Transactional records (which may include your information) may be stored for longer periods if necessary to meet legal, regulatory, tax or accounting needs. We will also retain information if we reasonably believe there is a prospect of litigation. There is a data retention policy which we apply to the records we hold.

In addition, even after deletion of information, including on account of exercise of your right herein  below (Withdrawing consent and restriction of processing), the information may persist on backup or archival media for audit, legal, tax or regulatory purposes. 

VHL reserves the right to decline access to your information under certain circumstances. If your information is not disclosed to you, you will be provided with the reasons for this non-disclosure.

WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING

Where we have obtained your consent to process your personal information for certain activities, you may request to withdraw consent to personal information processing or you may review, update, correct or delete your personal information collected through the website or other channels unless we consider that there is an alternative legal basis to justify our continued processing of your personal information. Subject to the aforesaid, you may request to withdraw consent as mentioned above or you may review, update, correct or delete your personal information by e-mailing us at datacompliance@ventivehospitality.com

SEVERABILITY

If any court or competent authority finds that any provision of this Privacy Policy (or part thereof) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

GRIEVANCE OFFICER

You may, at any time, contact our Grievance Officer directly with all questions and suggestions concerning data protection.

Email: datacompliance@ventivehospitality.com

PRIVACY POLICY FOR EMPLOYEES AND PROSPECTIVE EMPLOYEES

1. Collection of information and data from employees: VHL may collect personal information from employees or prospective employees, which may include: 

• Information provided in the Curriculum Vitae;
• residency and work permit status;
• taxpayer identification number, banking details;
• sick pay, pensions, insurance and other benefits information (including the gender, age, nationality and passport information for any spouse, minor children or other eligible dependants and beneficiaries);
• date of hire, date(s) of promotions(s), work history, technical skills, educational background, professional certifications, language capabilities and training courses attended;
• Name, email, phone, emergency contact details, blood group;
• height, weight and clothing sizes, photograph, physical limitations and special needs.
• records of work absences, vacation entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, selection and development assessments, and disciplinary and grievance procedures;
• where permitted by law and proportionate in view of the function to be carried out by an employee or prospective employee, government ID and address proof, the results of background checks, driving licence number, vehicle registration and any other related information.
• information required to comply with laws, the requests and directions of law enforcement authorities or court orders;
• acknowledgements, agreements regarding our policies;
• information captured on security systems, including Closed Circuit Television (“CCTV”) and key card entry systems and other security and technology systems, to the extent permitted by applicable law including, in certain jurisdictions, biometric information.
• emails, correspondence and other work product and communications created, stored or transmitted by an employee using our computer, network or communications equipment; and
• date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment; 

2. In addition to the above, any of the information we collect from our candidates for employment, employees or former employees, may be used in one of the following ways:

• evaluate applications for employment;
• manage all aspects of an employee’s employment relationship, including, but not limited to, payroll, benefits, corporate travel, performance appraisal, disciplinary and grievance processes etc.;
• maintain sickness records and occupational health programs;
• investigate and respond to claims against VHL, its staff and its guests;
• administer termination of employment and provide and maintain references;
• maintain emergency contact and beneficiary details; and
• comply with applicable laws, including judicial or administrative orders regarding individual employees. 

We may retain information of former employees for as long as it is necessary and in all cases for no longer than permitted by our retention schedule and applicable law.

All other terms and conditions of the Privacy Policy shall be applicable.