SUJÁN Luxury Hospitality Private Limited is a company incorporated under the laws of India, having its registered office at 1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110 016 along with its subsidiaries i.e. (a) Desert Friendly Camps Private Limited having its registered office at 1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110 016 and (b) Forest Friendly Camps Private Limited having its registered office at 1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110 016, hereinafter referred to as “We” or “Us” or “Company” or “SUJÁN”.
We own, operate and manage a chain of luxurious camps and palaces in India under the ‘SUJÁN’ brand. “Properties” that SUJÁN operates in India are SUJÁN Sherbagh, SUJÁN JAWAI, SUJÁN The Serai and SUJÁN Rajmahal Palace. We understand the need to respect the privacy of the esteemed guests who communicate with us and/or visit our hotel properties.
2. GOVERNING LAW
This Policy applies to all Guests, Visitors, and other individuals who provide their personal information to SUJÁN. All such Guests, Visitors and other individuals are hereinafter referred to as “You”.
- The nature of information we collect about you directly or through third parties.
- The sources from where your information is collected
- The manner in which your information is collected
- The purpose of collecting your information
- The manner in which your information is stored, used and processed by SUJÁN
- The rights you have under applicable laws regarding such information collected by SUJÁN
- The process to contact SUJÁN for any issues regarding the collection or use of your information
5. CATEGORY OF INFORMATION COLLECTED AND USED
Your Information collected by ‘SUJÁN’ primarily consists of: Personal Information and sensitive Personal Information [Collectively referred to as “Information” or “Your Information”].
(A) Personal Information
Personal Information means any information about you from which you can be identified. It does not include data where the identity has been removed [anonymous data].
When you enter into a transaction or communicate with SUJÁN, we may collect Personal Information from you such as:
6. HOW WE COLLECT YOUR INFORMATION
We collect Information about you through the following means:
7. WHY WE COLLECT YOUR INFORMATION
SUJÁN will collect adequate, relevant and necessary Information of yours, and will process such information fairly and lawfully for the purpose it is collected. Most commonly, SUJÁN will use your Information in the following circumstances:
8. FAILURE TO PROVIDE INFORMATION
If you fail to provide certain Information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
You hereby accept and agree that we shall not be held liable in any manner whatsoever if we are unable to perform our services or if there is a deficiency in our services to you due to your failure to provide such information.
You agree that he/she shall not file or initiate any complaints, legal proceedings or claims against SUJÁN and/or our employees, directors, associates, etc. in this regard.
You further agree to indemnify and hold SUJÁN and/or our employees, directors, associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against SUJÁN in this regard.
9. CHANGE OF PURPOSE
We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Information for any additional purposes, we will notify you and we will explain the legal basis which allows SUJÁN to do so.
You agree that we do not need any additional or further consent from you to use your Information in accordance with this policy to carry out our legal obligations or exercise specific rights.
11. INFORMATION SHARING AND DISCLOSURE
We may disclose your Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors; or to any member of our company, including our subsidiaries and partners insofar as reasonably necessary for the purposes set out in this policy and for the purpose of providing services to you.
In addition to this, we may disclose your Information:
to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that information.
SUJÁN ensures that our third party service providers employ industry standard security measures to ensure the security of information through legally binding terms and conditions. Except as provided in this policy, we will not provide you Information to any other third party.
12. TRANSFER OF INFORMATION OUTSIDE INDIA
Unless stated otherwise, we store and process your Information in India. There may, however, be occasions when we need to transfer your Information outside India in order to enable SUJÁN to use the information in accordance with this policy.
Such transfer of information may be to a country which does or does not provide the same level of data protection as in India. In these circumstances we will take appropriate steps to ensure that your Information is adequately protected.
Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as SUJÁN, so that your Information is adequately protected.
You expressly agree to the transfer of his/her information described in this Section.
13. DATA SECURITY
We are committed to protecting your Information and thus implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
Appropriate physical, electronic, and managerial procedures have been put in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information collected from you.
We strive to keep your personal information protected and take reasonable effort to safeguard that proper security and technical controls are applied to ensure data security.
14. DATA RETENTION
We will only retain you Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your Information so that it can no longer be associated with you, in which case we may use such information without a further statement to you.
15. REMOVAL OF INFORMATION
You may at any time ask SUJÁN to delete your Information. We will consider and where necessary comply with your request in accordance with applicable law, as explained above. Please note that after deleting the information, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
We may, however, need to retain certain Information of yours for recordkeeping purposes and/or to complete any transactions that you began prior to requesting removal of the information. For instance, when you make a purchase or reservation, or participate in a promotion, he/she may not be able to change or delete the Personal Information provided to SUJÁN until after the completion of such purchase, reservation, or promotion.
There may also be residual information that will remain within our databases and other records, which will not be removed. In addition to this, there may be certain Information of yours which we may be unable to delete due to legal reasons.
16. WITHDRAWAL OF CONSENT
You may at any time revoke or withdraw your consent to provide your Information to SUJÁN by using the applicable contact details set out at the end of this policy. In case of withdrawal of consent, SUJÁN may not be able to provide the same level of servicing to you as SUJÁN will not be aware of your preferences.
17. REVIEW OF INFORMATION
You can contact SUJÁN at any time requesting access to your Information for reviewing or requesting amendment to certain information that you consider to be incorrect or wrong. SUJÁN shall process such requests from you in accordance with applicable law.
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Next of kin and emergency contact information
- Bank account details, credit card or debit card details
- CCTV footage.
- Information about your use of our information and communications systems.
- Your Photographs
- Your travel arrangements and purchase history
- Your passport number and nationality
- Dietary preferences, allergy and information about how you use our services and information about how you access our websites
- Behavioural or demographic attributes, when tied to personal identifiers
- Social media account ID or user ID, profile photo and other data you make available publicly or to SUJÁN from your social media accounts, publically available platforms or other sources
- Where you have requested specific medical assistance from SUJÁN, such as the provision of a wheelchair, medical assistance; or
- Where such information has been passed onto SUJÁN by a third party, where you have given that third party consent to do so, such as the travel agent through which you made a booking or from other hotels for your onward journey, where the processing of such sensitive Personal Information is required for the processing of your service request; or
- Where such information is required under applicable laws.
- Whenever you use our services [whether services provided directly by SUJÁN or by other companies or agents acting on our behalf - for example through a booking agency, travel agent or corporate account];
- When you stay with SUJÁN or checks-in;
- When you use our website or makes reservations or bookings through our website or do an online chat with our reservation agent;
- When you interact with SUJÁN via email or social media platforms such as Facebook, LinkedIn, Instagram or Twitter;
- When you book through third parties [such as travel agents etc.]. to use our services.
- Where we need to perform the contract we have entered into with you;
- Where we need to comply with a legal obligation;
- To enable you use of the services available at our hotels;
- To send statements, invoices and payment reminders to you, and to collect payments from you;
- To send non-marketing commercial communications to you;
- To send you email notifications that you has specifically requested for;
- To send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you. However, you can inform SUJÁN at any time if you no longer requires such marketing communications;
- To provide third parties with statistical information about our users but those third parties will not be able to identify any individual user from that information;
- To deal with enquiries and complaints made by or about you relating to services provided;
- To improve and customise our services in accordance with your preferences;
- Where we need to protect your interests,
- Where it is needed in the public interest or for official purposes or to fulfil a legal obligation. For instance, requests made by law enforcement agencies, courts or tribunals.
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights including providing information to others for the purposes of fraud prevention and reducing credit risk;
- to the purchaser or prospective purchaser of any business or asset that we are or are contemplating selling; and
- The policy is subject to modification from time to time. If we decide to change our policy, we will post those changes here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone.
- We may also notify you in other ways from time to time about the processing of your Information.
19. GRIEVANCE OFFICER
In accordance with the Indian Information Technology Act 2000 and the rules notified thereunder, the contact details of the Grievance Officer are provided below: