At Waxpol Hotels and its affiliates and subsidiaries (collectively referred to as "Waxpol Hotels," "we," "us," or "our"), we are committed to providing exceptional services and experiences to our guests in our hotels and luxury residences around the world. We highly value your business and the trust you place in us to deliver superior service.
This policy explains the purposes for which we collect personal information, with whom we may share it, and the security measures we employ to protect your data. It also informs you about your rights and choicesregarding your personal information and how you can contact us to inquire about our privacy practices.
We encourage you to carefully read this Privacy Notice before utilizing any of our products and/or services.
In this Privacy Notice, the following definitions apply:
- Data: Personal information, including sensitive personal information and special category personal data (as defined under Data Protection Laws), collected, received, or otherwise processed in connection with your use of our hotels, website, and/or mobile application.
- Cookies: Small files placed on your device by our website or mobile application when you visit or use specific features. Cookies generally allow a website or mobile application to remember your actions or preferences for a certain period.
- Data Protection Laws: Any applicable laws related to the processing of Data.
- Partners: Select third parties (including The Waxpol Industries and proprietors, and its subsidiaries, affiliates, associate companies, and joint venture companies.) with whom we have contracts for the businesses described in this Privacy Notice.
- Service Providers: Entities that provide services to Waxpol Hotels and to whom we may disclose your Data for specific purposes under a written contract.
- Waxpol Hotels: Waxpol Hotels, a company incorporated in Kolkata with its registered office at 9 Mitter House, 71 G.C. Avenue Kolkata -700013.
- User or you: The natural person who accesses our services, websites, or mobile applications.
WHAT DATA DO WE COLLECT ABOUT YOU
Waxpol Hotels collects Data for various purposes as outlined in this Privacy Notice. This Data includes, but is not limited to, 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 patterns or trends, and other similar data.
(c) 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 information required by law enforcement agencies.
(d) 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.
(e) Your reviews, feedback, and opinions about our products, programs, and services.
(f) Loyalty program information: Your loyalty membership information, account details, profile or password details, and any frequent flyer or travel partner program affiliation.
(g) Transaction information: Date of the transaction, transaction amount, transaction history, and related details.
(h) 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.
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 provide 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 email from us or click on a link in the email. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
- Automatic Information We Collect from Other Websites: We receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement.
- 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 Waxpol Group 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.
- Information Previously Provided to Waxpol Hotel and Waxpol Group Entities: Where you have previously shared information with any of the Waxpol Group Entities and such Waxpol Group Entity is permitted to further share that information, it will share such information with us. If such information is sensitive personal information or special category personal data, the Waxpol Group Entity will only share such information with us with your consent.
You can make choices about our collection and use of your Data. For example, you may want to access, edit, or remove your Data on our website or mobile application. When you are asked to provide Data, you may decline. For more information, please see the section below, titled "Your Rights and Choices."
DATA SHARED BY YOU
Waxpol Hotels may collect your Data in several ways through 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 during your visit to our stores, website, or mobile application.
DATA THAT IS COLLECTED AUTOMATICALLY
We automatically collect some information when you visit our website or use our mobile application. This information helps us make improvements to our content and navigation. The information collected automatically includes your IP address.
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. Waxpol Hotels uses this information to measure site usage, improve content, ensure safety and security, and enhance the performance of our website or mobile application.
We may collect your Data automatically via Cookies, pixels, and similar technologies in line with settings on your browser. For more information about Cookies, please see the section below, titled "Cookies, Pixels, and Similar Technologies.
OUR USE OF DATA
Data collected by us may be used for the following purposes:
(a) To carry out our obligations arising from any contract entered into between you and us.
(b) To provide products and/or services and communicate with you about products and/or services offered by us.
(c) To enable Waxpol Group Entities and Partners to offer their products and/or services and communicate with you about such products and/or services.
(d) To process, disclose, transmit, and/or share the Data with Waxpol Group Entities and other third parties that have business or contractual dealings with us.
(e) To provide you with offers (including for financial products and/or services), personalized services, recommendations, and improve your experience on our website and mobile application.
(f) To operate, evaluate, and improve our business, website, and mobile application.
(g) To generate aggregated data to prepare insights that enable us to understand customer behavior, patterns, and trends with a view to learning more about your preferences or other characteristics.
(h) To 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 WHRL Entities.
(j) To communicate with you (including responding to your requests, questions, feedback, claims, or disputes) and to customize and improve our services.
(l) To protect against and prevent fraud, illegal activity, harm, financial loss, and other legal or information security risks.
(m) To 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 several lawful ways in which we may process your Data, which are outlined 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 to perform our obligations under this contract, including enabling us to communicate with you about such products and/or services and 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, unless such interests are overridden by your interests, fundamental rights, or freedoms that require protection of your Data. The ways in which we may process your Data for the purposes of our legitimate interests include:
(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 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.
(i) Enabling WHRL and Partners to offer their products and/or services and to communicate with you about such products and/or services.
(j) In connection with loyalty programs owned and operated by us or by other WHRL Entities.
(k) Processing, disclosing, transmitting, and/or sharing the Data with WHRL Entities and other third parties that have business or contractual dealings with us.
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."
Some of the above grounds for processing may overlap, and there may be several grounds justifying our use of your Data.
Furthermore, 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 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.
SHARING OF DATA
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 Partner.
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) Waxpol Hotels Group Entities: We may share your Data with Waxpol Hotels Group Entities for them to make their products, services and/or applications available to you, to assist them in reaching out to you in relation to their programs or campaigns and to process your queries and requests. We may also share your Data with the Waxpol Hotels Group Entities as is relevant for the purposes set out in Clause 6 above, and to facilitate the operation of our business. Their use of your Data is subject to their own privacy policies. For further information on how these Waxpol Hotels Group Entities process your Data, please review their privacy policies.
(c) Waxpol Consumer Platform: Your Data may be shared with Waxpol Hotels Group Entities and other participating entities on the Waxpol Consumer Platform operated by Waxpol Digital Limited (“WCP”) for the purposes of enrollment, offering you products, services and benefits on the WCP. Accordingly, we may share your Data with other Waxpol Hotels Group Entities, Partners, and Service Providers.
(d) 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.
(e) When WHRL acts as a Service Provider: We may process and share your Data with Waxpol Hotels Group Entities and Partners when we act as a service provider to such Waxpol Hotels Group Entities and Partners. In this case, for the purposes of relevant Data Protection Laws, we act as a processor of the Data on behalf of, and under the instructions of, the relevant Waxpol Hotels Group Entity or Partner (i.e. the controller).
(f) Protecting WHRL: 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 WHRL or a Waxpol Hotels Group Entity's intellectual property rights; (c) to protect WHRL 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.
(g) 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.
(h) Third Parties: We may also share your Data with other third parties where:
- You request or authorize us to do so;
- We need to comply with applicable law or respond to valid legal process; or
- We need to operate and maintain the security of our website or mobile application, including to prevent or stop 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 Waxpol Hotels Group Entities and Partners may have privacy practices that differ from those of WHRL. The use of your Data will be governed by their privacy statements when you provide Data on their websites.
KEEPING DATA SECURE
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.
RETENTION OF DATA
WHRL 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 exercise of your right under Clause "YOUR RIGHTS AND CHOICES" below, it may persist on backup or archival media for audit, legal, tax, or regulatory purposes.
WHERE WE STORE DATA
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.
If the GDPR/United Kingdom’s version of the GDPR applies to our processing of your Data, we will only process and/or transfer Data outside of the European Economic Area/United Kingdom where it is compliant with Data Protection Laws and the means of transfer provide adequate safeguards in relation to your Data, including for example:
(a) by way of a data transfer agreement incorporating the current relevant standard contractual clauses adopted in the European Economic Area/United Kingdom; or
(b) by transferring your Data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
(c) where it is necessary for the conclusion or performance of a contract between us and a third party and the transfer is in your interests for the purposes of that contract; or
(d) where you have consented to the data transfer.
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).