PRIVACY POLICY
The Kingship Hotels (“KAHLON”)
At KAHLON, its affiliates and subsidiaries (hereinafter collectively referred to as “KAHLON”, “we” or “us” or “our”), we endeavor to provide our guests outstanding services and experiences in our hotels and luxury residences around the world. We value your business and your faith in us in delivering you a superior level of service.
We recognize that privacy is important to our guests, and hence our Global Privacy Policy explains our practices regarding the personal information we collect when you visit or use our hotels, restaurants, bars, spas, salons, etc. and our website, mobile applications, or other online products and services or when you fill up a form and become a member of our loyalty programs. We shall protect your personal data, to keep it secure as per applicable privacy and data protection laws.
It also describes the purposes for which we collect that personal information, the other parties with whom we may share it, and the measures we take to protect the security of your data. It also tells you about your rights and choices with respect to your personal information, and how you can contact us about our privacy practices.
You are advised to carefully read this Privacy Notice before using or availing of any of our products and/or services.
In this Privacy Notice, the following definitions are used:
Data
personal information, including sensitive personal information and special category personal data (as defined under Data Protection Laws) about you, which we collect, receive or otherwise process in connection with your use of our stores, website, and/or mobile application.
Cookies
a small file placed on your device by our website or mobile application when you either visit or use certain features of our website or mobile application. A cookie generally allows a website or mobile application to remember your actions or preference for a certain period of time.
Data Protection Laws
any applicable law for the time being in force relating to the processing of Data.
Partners
select third parties (including Entities) with whom we have contracts for the businesses described in this Privacy Notice.
Service Providers
includes entities that provide services to KAHLON and to whom we may disclose your Data for a specific purpose pursuant to a written contract.
2. WHAT DATA DO WE COLLECT ABOUT YOU
KAHLON collects Data for various purposes set out in this Privacy Notice.
This Data includes, without limitation, the following categories:
(a) Contact information: first and last name, email address, postal address, country, phone number, and other similar contact data.
(b) Financial information: payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data.
Technical information: website, device, and mobile app usage, Internet Protocol (IP) address, and similar information collected via automated means, such as cookies, pixels, and similar technologies. This may include the information mandated by the law enforcement agencies.
(c) Product and service information: Your account membership number, registration information, and program-specific information, when you request products and/or services directly from us or participate in marketing programs.
(d) Your reviews, feedback, and opinions about our products, programs, and services.
(e) Loyalty program information: your loyalty membership information, account details, profile or password details, and any frequent flyer or travel partner program affiliation.
(f) Transaction information: date of the transaction, transaction amount, transaction history, and related details;
(g) Other information (which may include special category personal data): Age, sex, date of birth, marital status, nationality, details of government identification documents provided, occupation, ethnicity, religion, travel history, or any other personal information provided in responses to surveys or questionnaires.
3. HOW WE COLLECT DATA
We collect Data in the following ways:
Information You Give Us: We receive and store any information you enter on our website or mobile application or give us in any other way (e.g., at our outlets, stores, hotels, kiosks). Please see the section below, titled “Data Shared by You” for more information.
Automatic Information We Collect: We use “cookies”, pixels, and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled “Data That is Collected Automatically” for more information.
E-mail Communications: We often receive a confirmation (if your device supports such capabilities) when you open an e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
Information from Other Sources: We may obtain information from other sources. An example of this is when you authorize a third-party website (such as the website of another Entity) to interact directly with our website or mobile application to provide or receive information about you. In that case, we may receive information to identify your account with that website.
KAHLON may collect your Data in several ways from your use of our stores, website, or mobile application. For instance:
(a) when you register with us to receive our products and/or services;
(b) when you conduct a transaction with us or attempt a transaction at our stores, on our website, or mobile application;
(c) when you complete surveys conducted by or for us;
(d) when you elect to receive any communications (including promotional offers) from us;
(e) from the information gathered by your visit to our stores, website, or mobile application;
5. DATA THAT IS COLLECTED AUTOMATICALLY
(a) We automatically collect some information when you visit our website or use our mobile application. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
(b) Our web servers or affiliates who provide analytics and performance enhancement services collect IP addresses, operating system details, browsing details, device details, and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed, and similar information. KAHLON uses this information to measure site usage, improve the content and ensure safety and security, as well as enhance the performance of our website or mobile application.
Data collected by us may be used by us for the following reasons:
(a) carry out our obligations arising from any contract entered into between you and us;
(b) provide products and/or services and communicate with you about products and/or services offered by us;
(c) enable Entities and Partners to offer their products and/or services and communicate with you about such products and/or services;
(d) process, disclose, transmit, and/or share the Data with Entities, and other third parties which have a business or contractual dealings with us;
(e) provide you with offers (including for financial products and/or services), personalized services, and recommendations, and improve your experience on our website and mobile application;
(f) operate, evaluate and improve our business, website, and mobile application;
(g) generate aggregated data to prepare insights to enable us to understand customer behavior, patterns, and trends with a view to learning more about your preferences or other characteristics;
(h) provide privileges and benefits to you, marketing and promotional campaigns based on your profile;
(i) in connection with loyalty programs owned and operated by us or by other Entities;
(j) communicate with you (including responding to your requests, questions, feedback, claims, or disputes) and customize and improve our services;
(k) enforce the terms of use of our website and mobile application;
(l) protect against and prevent fraud, illegal activity, harm, financial loss, and other legal or information security risks; and
(m) serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by applicable law.
Where required under relevant Data Protection Laws, we may need to ensure that there is a legal basis to justify our processing of your Data. There are a number of different ways that we are lawfully able to process your Data. We have set these out below.
Where processing your Data is necessary for us to carry out our obligations arising from any contracts entered into between you and us: If you enter into a contract with us in relation to any of our product or service offerings, we may process certain Data about you in order to perform our obligations under this contract, including to enable us to communicate with you about such products and/or services and to process your payment transactions.
Where processing your personal information is within our legitimate interests: We can process certain Data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of yours which require protection of your Data. The ways in which we may process your Data for the purposes of our legitimate interests include:
(a) enforcing the terms of use of our website and mobile application;
(b) generating aggregated data to prepare insights to enable us to understand customer behavior, patterns, and trends with a view to learning more about your preferences or other characteristics;
(c) improving our website and mobile application and ensuring that they run smoothly;
(d) providing you with offers, personalized services, and recommendations and improving your experience on our website and mobile application;
(e) protecting against, and preventing, fraud, illegal activity, harm, financial loss, and other legal or information security risks;
(f) providing offers, privileges, and benefits to you, marketing and promotional campaigns based on your profile;
(g) communicating with you (including responding to your requests, questions, feedback, claims, or disputes) and customizing and improving our services;
(h) operating, evaluating, and improving our business
Where you give us your opt-in consent to process your personal information: In certain circumstances, where required under relevant Data Protection Laws, we will seek to obtain your consent before we undertake certain processing activities with your Data.
Where required under relevant Data Protection Laws (e.g. under direct marketing legislation), we will obtain your opt-in consent prior to sharing your Data with third parties and carrying out certain marketing activities (unless we are permitted by relevant Data Protection Laws to contact you without your opt-in consent in relation to goods and services which are similar to those which you have already purchased, used or interacted with).
You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in the section below, titled “Your Rights and Choices“.
Where processing your personal information is necessary for our compliance with a legal obligation: In certain circumstances, we may disclose your Data for the purposes of compliance with a legal obligation (for example, to comply with a law, regulation, or compulsory legal request). We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see the section below, titled “Your Rights and Choices“.
Some of the above grounds for processing will overlap and there may be several grounds that justify our use of your Data.
Further, where required under relevant Data Protection Laws, we will only process special category personal data (as defined under Data Protection Laws) if there is a valid legal basis, which might involve obtaining your explicit consent.
Where we use or share your Data on behalf of another entity (i.e., the controller) as part of our services offered to that entity, we do so under the instructions of that entity and that entity is responsible for ensuring that there is a legal basis for us to use or share your Data on its behalf (if the such legal basis is required under relevant Data Protection Laws).
Our website and mobile application do not offer products or services for use by minors. If you are under 18, you may use our website or mobile application only with the involvement of a parent or guardian.
We may share your Data in the following ways (and for the purposes of relevant Data Protection Laws, we may do so either as a controller in our own right or as a processor on behalf of and under the instructions of another entity in accordance with our obligations under our agreement with that entity):
(a) Partners: We may make available to you services, products, or applications provided by Partners for use on or through our website or mobile application. If you choose to use such services, products, or applications, Data related to these uses may be shared with such Partners.
Such Partners use your Data for the purposes of providing their own products or services to you. Their use of your Data is subject to their own privacy policies. For further information on how these Partners process your Data, please refer to their privacy policies.
(b) Service Providers: We may share your Data with Service Providers who may, in the course of providing their respective services, receive and process Data. Examples include storing and analyzing data, protecting and securing our systems, providing search results and links, providing customer service, credit analysis, processing your Data for profiling, user analysis, and payment processing.
These Service Providers will be required to only process Data in accordance with our instructions. The Service Providers will also be required to safeguard the security and confidentiality of the Data they process by implementing appropriate technical and organizational security measures.
(c) Protecting KAHLON: We may release Data when we believe that disclosure is reasonably necessary (a) to comply with a law, regulation, or compulsory legal request; (b) to protect KAHLON or a Entity’s intellectual property rights; (c) to protect KAHLON against harm or financial loss; (d) when we believe disclosure is necessary to protect individuals’ vital interests, or (e) in connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other companies and organizations for fraud protection, risk management, and dispute resolution.
(d) Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data (including in relation to loyalty programs) may be transferred as part of such transactions.
(e) Third Parties: We may also share your Data with other third parties where:
a) You request or authorize us to do so;
b) We need to comply with applicable law or respond to valid legal process; or
c) We need to operate and maintain the security of our website or mobile application, including preventing or stopping an attack on our computer systems or networks.
The sharing of your Data will be in line with the processes set out in this Privacy Notice.
Please note that Entities and Partners may have privacy practices that differ from those of KAHLON. The use of your Data will be governed by their privacy statements when you provide Data on their websites.
We will use technical and organizational measures to safeguard your Data and we store your Data on secure servers. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us by e-mail.
KAHLON retains Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website or mobile application, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your Data is necessary for our legitimate interests. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.
Even if we delete your Data, including on account of the exercise of your right under Clause 12 below, it may persist on backup or archival media for audit, legal, tax, or regulatory purposes.
We may transfer your Data to recipients in India, where we are headquartered, and other countries. These countries may not have the same data protection laws as the country in which you initially provided the information. If we transfer your Data to other countries, we will protect that information as described in this Privacy Notice, as disclosed to you at the time of data collection or as described in our program-specific privacy notice.
12. YOUR RIGHTS AND CHOICES
Depending on which country’s laws are applicable to you, you may have various rights in relation to the Data that we hold about you. To get in touch with us about any of your rights under Data Protection Laws, please use the contact details set in the section below, titled “How to Contact Us”. We will seek to deal with your request without undue delay, and in any event, within any time limits provided for in Data Protection Laws (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. Where we are legally permitted to do so, we may refuse your request.
You may be entitled to the following rights in relation to your Data:
a) Right to Confirmation and Access – you may ask us to confirm what Data we hold about you at any time and request us to modify, update or delete such Data. You may also request a copy of the Data we hold about you.
b) Right to Rectification – you have the right to request that we rectify any inaccurate or incomplete Data that we hold about you, including by means of providing a supplementary statement.
c) Right to be Erasure – you have the right to request that we “erase” your Data in certain circumstances.
d) Right to Restrict Our Use of your Data – you have the right to request that we restrict our processing of your Data in certain circumstances, for example, if you dispute the accuracy of the Data that we hold about you or you object to our processing of your Data (including where we process your Data for our legitimate interests, where permitted under applicable law).
e) Right to Object – this right enables you to object to us processing your Data where we do so for certain reasons.
f) Right to Data Portability – you have the right to request that we transfer your Data to another third party. This right of data portability only applies to certain types of Data.
g) Right to Withdraw Consent – where we have obtained your consent to process your Data for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your Data for this purpose.
h) Right to File Complaints – you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.
To get in touch with us about these rights, or for more information about managing your Data and promotional communications, please use the contact details set out in the section below, titled “How to Contact Us”.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.
We take steps to ensure that your Data is processed according to the provisions of this Privacy Notice and the requirements of applicable law.
To ensure that your Data receives an adequate level of protection, we have put in place appropriate written contracts with Entities, Partners, and Service Providers that we share your Data with.
If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) 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 Notice will not be affected.
15. COOKIES, PIXELS, AND SIMILAR TECHNOLOGIES
Our website and mobile application may place and access certain Cookies on your device. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device. We also use pixels and similar technologies to analyze traffic on our website and mobile application to improve your experience of using them.
When you first visit our website and mobile application, you will be presented with a pop-up screen informing you of our use of Cookies and asking you to provide your consent for such use. The pop-up screen may not reappear for all your subsequent visits to our website and mobile application, but you may adjust your web browser software if you do not wish to receive Cookies or web beacons, but this may prevent you from taking advantage of some of the features of our website and mobile application. Please refer to your browser instructions or help pages to learn more about these functions
16. CHANGES TO THIS PRIVACY NOTICE
Our business changes constantly and our Privacy Notice will change also. We may e-mail periodic reminders of our notices and conditions unless you have instructed us not to, but you should check our website and mobile application frequently to see recent changes. The updated version will be effective as soon as it is accessible. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
To request to review, update, or delete your personal information or to otherwise reach us, please submit a request by emailing us at info@kingshiphotels.com You may contact us for information on Service. We will respond to your request within 30 days.
We request our guests to read this policy document carefully before sharing their personal information with us. By visiting our web sites, the guests accept the practices described in this policy document.
This user data protection summary describes the collection and usage of personal information and data, in accordance with GDPR (General Data Protection Regulation).
If you have any queries regarding this Privacy Notice, please contact us at info@kingshiphotels.com.
The Kingship Hotel reserves the right to change the privacy policy from time to time and guests are requested to visit our website frequently to learn about the recent changes.
Personal information collected by the Kingship Hotel
We may collect the following personal information: Guest name and contact information; date of birth; how they prefer to be addressed in communication from us, preferred modes of communication; job designation and business address; spouse name, anniversary, credit card details, including the three-digit code that appears on the back of credit card, dates of arrival and departure from our hotels / restaurants / other outlets, guests preferences when they stay or dine at The Kingship Hotel, transaction history at The Kingship Hotel offers guests may have availed of from third party marketers in response to a communication from the Kingship Hotel. We may also record details on guests who have stayed or dined with other guests at the Kingship Hotel, including their names and contact details.
Besides the above, we may also collect the following:
- If you choose to reserve a room online we record your arrival and departure dates, number of guests in the group, details of guest rooms and tariff details.
- When you make a request for a proposal from our meeting planners, by visiting our websites.
- When you contact us with your questions or comments.
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not allow children to submit personal information without prior permission. We do not knowingly collect information related to your racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or political affiliations unless it is volunteered by guests themselves. We may use any health-related information provided by guests only to serve them better and meet their specific needs when they stay or dine at the Kingship Hotel.
How does the Kingship Hotel use the personal information collected from its guests
We use guests’ personal information to provide them with the services requested from The Kingship Hotel, to help them make room reservations, to provide them with information about conferences and events at the Kingship Hotel, to send them promotional material on our services by email, direct mail and phone, to conduct surveys from time to time, to make offers sourced from third parties, as per guests’ stated preferences or usage pattern exhibited at the Kingship Hotel.
Information collected regarding their preferences when guests stay or dine at The Kingship Hotel will be disseminated across. The Kingship Hotels ensures that guests enjoy a similar level of service and satisfaction across all the hotels in the chain.
The guests have a right to modify or restrict (stop any active) processing of their personal information for any marketing-related activities. The guests may opt out of our database by using the “Unsubscribe” option at the footer of our online e-mailers, or by sending an email to info@kingshiphotels.co.
How does the Kingship Hotel share the personal information collected from its guests, including with third parties
To ensure that you enjoy the same level of service across all The Kingship Hotel and Resorts, owned or franchised around the world, we may share your personal information with hotels within The Kingship Hotel. While doing so, The Kingship Hotel will ensure that guests’ personal information is handled as per this policy.
• If a corporate credit card is used, the billing information may be shared with employer.
• With third parties:
o We may use the services of third party service providers to provide certain products and services like credit card billing, reservations services, call centre services, mass mailings, for which it is necessary to provide personal information. These parties are contractually prohibited from using the personal information for any purpose other than those specified by The Kingship Hotel. We may provide information that is non-personal, to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. The Kingship Hotel expressly prohibits the sale or transfer of any information to any party outside of The Kingship Hotel by such service providers.
o From time to time The Kingship Hotel may partner with other companies to provide co-sponsored or co-branded promotions, products and services and may share guest information with our co-sponsor. For example, we may co-sponsor some sweepstakes, prize draws, competitions or contests on our site with other companies or we may provide prizes for sweepstakes and contests sponsored by other companies. If guest enter one of these sweepstakes or contests, we share this information with our co-sponsor or the third party sponsor.
• In the event of a merger, consolidation, sale, liquidation or transfer of assets, The Kingship Hotel in its sole and absolute discretion may transfer, sell or assign information collected, including without limitation, non-personal information and personal information, to one or more affiliated or unaffiliated third parties.
• The Kingship Hotel with or without prior notice to its guests, may have to share some guest information in order to comply with applicable laws or respond to governmental inquiries or requests from public authorities or to comply with valid legal process, to protect the rights, privacy, safety or property of The Kingship Hotel, its guests, employees or the public or to permit us to pursue available remedies or limit the damages that we may sustain or to respond to an emergency.
Non-personal or anonymous information collected by The Kingship Hotel
Information that does not personally identify a guest is referred to as non-personal or anonymous information. When guest visit and interact with the sites info@kingshiphotels.com or third parties with whom The Kingship Hotel has contracted to provide services, non-personal information, like, list of website pages visited by guest, could be collected. Technology like cookies could be used to help deliver content as per guest preference, to help guest process their reservations or other requests. While this cannot be used to disclose their identity, this information will identify the browser used by guest to our servers when they visit our site. To remove the cookies at any point from a computer, guests can delete them using their browser.
We also may collect data by using web beacons, clear GIFS, pixel tags or similar means, which will tell us when guests visit our site. Non-personal information like the domain name, the areas of the site guest visit, their operating system, browser version, and the URL they visited from, can be identified, which can be used to enhance their online experience by understanding their web usage patters.
From time to time, we may allow third party advertisers to advertise on our websites. These third party advertisers may use technologies like cookies, pixel tags to track which ads the browser used by guest has seen and which site pages they may have visited. The Kingship Hotel has no control over the use of this technology or the resulting information and is not responsible for any actions or policies of such third parties.
We may use or disclose non-personal information for any purpose from time to time. For instance, we may embed e-mail addresses with images. In such cases where we combine non-personal information with personal information, the combined information will be treated by us as personal information per this policy.
Links to websites of third party marketers
If our websites contain links to third parties’ websites, please do note that we will not be responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. For information provided by guests on third party sites, the privacy policy and terms of service on those sites will be applicable and it is advisable to read the privacy policies of websites that the guests visit before submitting personal information.
Data Security
The Kingship Hotel will take the necessary measures to:
- Protect guests’ personal information collected against unauthorized access, disclosure, alteration or destruction.
- Keep the guests’ personal information up-to-date, consistent with applicable law.
- When guests transact online, we seek to protect their personal information that they provide. However, do note that no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.
- Ensure that our affiliates and service providers take reasonable measures to maintain the confidentiality of personal information about guest.
- We have a system in place to check for data security breach and notify the relevant authorities, of any such activities.
How long does The Kingship Hotel retain your personal information
The Kingship Hotel will retain guests’ personal information for the period necessary to fulfil the purposes outlined in this policy document, unless a longer retention period is required or permitted/mandated by applicable law.
To ensure your security
- For your own privacy we advise guests not to include sensitive personal information in any emails they may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.
- We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow children to submit personal information without prior permission.
