The Paul Resorts and Hotels Network (also referred to herein as “TPRH” or “Network”) is a set of related Internet sites for hotel, resort and accommodation properties owned and operated by The Paul Resorts and Hotels Pvt Ltd (“TPRH”, “we” or “us”). We have the goal of creating an amazing vacation experience for you, and as such are committed to your privacy. This privacy policy describes what information we collect on our Network and in the use of our Products and Services, how we use that information, and what options we offer you to control your personal information.

We will need to process your personal information in order to offer you our Products and Services. By using the Network or purchasing our Products or Services, you confirm that you have read and understood this privacy policy (“Privacy Policy”) including how and why we use your information and that your use of the Network is subject to the applicable Terms of Service and this Privacy Policy. If you do not want us to collect or process your personal information as described herein, you have several choices including limiting the information we collect on you, or not using the Network, or our Products and Services.

Usage of our network is at your sole discretion and by using the Network or purchasing our Products and Services, you acknowledge that TPRH will use your information in India as well as any other country where TPRH operates. This privacy policy has been updated to comply with the EU’s General Data Protection Regulation (GDPR) and this policy describes how we protect personal information that is transferred outside of the EU. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to countries to which we are permitted by law to transfer personal information and we will continue to ensure that your personal information is appropriately safeguarded.

HOW WE COLLECT INFORMATION ON YOU

In the course of providing you access to the Network, as well as Products and Services, TPRH collects and receives personal information in a few ways. Often, you can choose what information to provide, but sometimes we require personal information from you to carry out certain activities such as booking rooms. This section details the ways in which we collect information from you and how that information is received.

Booking Reservation& Contact Forms

In order to book your stay at our properties, we require your personal details. This requires a name associated with your account, an email address at which we can contact you, mobile number and additional information including a contact address, a billing address, and your credit card information to help confirm your booking. We may collect some of the above personal details through contact forms on Network websites in order to get in touch with you about packages or other Products and Services.

Information Collected Automatically

TPRH receives and records information from your browser or mobile device when you visit the Network such as your Internet Protocol (IP) address or unique device identifier. Cookies and data about which pages you visit on our Network allow us to operate and optimize the Products and Services we provide to you. This information is stored in secure logs and is collected automatically. We may combine this browser information with other information we collect about you. This information is used to keep the Products and Services secure, analyze and understand how our Products and Services are used, optimize such usage, and provide advertising across the Network as well as certain Products and Services to personalize your experience.

Location Information

When you use the TPRH Network, we collect location information about you including your IP address, your location, browser information, and how you came to the TPRH Network. This information is collected for various purposes, including advertising, analytics and to serve content as it relates to certain Products or Services, as well as to provide you with localized content, recommendations, and marketing. You may revoke our permission to collect some of this data, including your location and browser information through your Browser Settings, but this may limit functionality in some cases. We share this information with certain third-parties in order to provide you with our Products and Services.

Information from Third Parties

We may share personal information with third parties who provide services to TPRH, such as payment processors, email delivery services, and advertising service providers. When TPRH shares your personal information and other collected information with third party service providers, we require that they use your information only for the purpose of providing services to us and that their terms are consistent with this privacy policy.

Advertising and Marketing Partners

When you interact with TPRH, we and authorized third parties place cookies on you and your account activity as described in more detail within our Cookies Policy. We use this information to serve you certain advertising content. Similarly, we market our Products and Services to you and communicate important information and product opportunities to you. If you do not wish to receive these marketing communications from us, you can tell us and remove yourself from our marketing communications via the unsubscribe and opt out options in our email communications and your Browser Cookies Settings. You may refer our cookie policy on our this or any of our network website for more details

Analytics Information

TPRH uses data analytics to ensure site functionality and to optimize our Product and Service offerings to you. We use web browser and mobile analytics to allow us to understand Network functionality. In doing so, we record information including, for example how often you visit the Network, Network performance data, errors and debugging information, and the type of activity you engage in while on the Network or in your use of our Products and Services. We may on occasion share this information with third parties for research or product and services optimization.

Billing Information

For Products and Services requiring payment, we collect a billing name, phone number, and email address. We also collect a billing address for invoicing purposes. If you elect to pay by credit card, TPRH may engage a third party to securely process your payment. All payment processing is done through a PCI DSS compliant third party. If customers are paying by a credit card, their card details are vaulted through a third party payment gateway. TPRH will store an encrypted token along with the last four digits of the credit card and the expiration month and year of the card and will not store or retain any other billing information about you.

WHAT INFORMATION WE COLLECT ON YOU

TPRH partners with third parties to enable advertisements on their platforms. These partnerships provide third parties access to the anonymous cookie information collected by us. In providing this opportunity, TPRH and its third party partners may collect and use your personal information to tailor your advertising experience to suit your interests and skills.

Our advertising products and services require us to collect certain personal and non-personal information on you, which includes:

• Data from advertising technologies like cookies, web beacons, pixels, ad tags, and browser/device identifiers
• Information you have provided to us directly including your name, email address and phone number.
• Usage analytics including your visits to the Network, browsing and search history
• Information from our advertising partners (e.g., device type and location)

YOUR CHOICE AND CONTROL OF THE INFORMATION WE COLLECT ON YOU

Privacy is a guiding principle of for TPRH and we value your privacy. To this end, we provide you with the ability to control how your information is stored, and what information is collected. You may change your browser settings and choose not to share certain information by disallowing the creation of cookies. Additionally, much of the data we collect is voluntary and your choice entirely to provide us or not. Of course, should you wish, you may also request the permanent deletion of your data, in which case all personal information collected on you will be removed from our servers and encrypted (except, in some cases your IP address required for security purposes, site maintenance, and spam protection).

We also provide you additional data control options, created by the GDPR, but provided to the TPRH community regardless of geographic location with respect to your information, including data access and portability (including the right to obtain and download a copy of the personal data you provided to TPRH), data correction, data deletion (where TPRH will delete personal information stored on you, which we are not required by necessity to maintain), and the ability to have us stop processing your personal data (with certain exceptions as may be necessary). Please also be aware that in order to provide some of these data choices to you, we may need to first verify your identity. We will make reasonable efforts to verify your identity, however if we are unable to do so, we reserve the right to refuse such a request in keeping with data privacy and information security principles. You may additionally control the receipt of certain marketing and advertising communications from TPRH. Some messages that we send are required, and related to our legal obligations, or service related and mandatory. Other messages, like marketing and advertising, are voluntary. We provide you with the opportunity to opt out of direct communications through unsubscribe options in our emails.

COOKIES

In order to provide the TPRH Network along with the Products and Services described in this policy, we may place cookies on you as well as partner with third parties including advertising partners, who may use cookies or other similar technologies to provide you with advertising based on your browsing activities and interests. Please see our Cookies Policy for additional information on how we use cookies and what third party cookies we permit.

DATA PROCESSING DISCLOSURES

When you access the TPRH Network and use the Products and Services we offer, we collect, display, store, share, transmit, and process your information in the manner described in this policy. In order to carry out these activities, TPRH may rely on a number of legal bases in order to process your personal data, including where:

• necessary to perform the contractual obligations in our Terms of Service and in order to provide the Products and Services to you
• necessary for our legitimate interests
• necessary to comply with a legal obligation or to defend legal claims
• necessary to protect the public interest or vital interest of others
• you have consented to the processing, which may be revoked at any time

Where we process your information on the basis of legitimate interests, we do so in order to:

Secure your Personal Data and Information

All records containing personal or financial information are considered to be proprietary and are afforded confidential treatment at all times. TPRH is committed to the safety and security of your personal data and the information that you share with us and with the public. We treat your personal safety and safety from harassment as top organizational priorities. At TPRH we consider it necessary to pursue these legitimate interests in order to keep your information safe from spam, harassment, intellectual property infringement, identity theft, and the scraping and unlawful collection of your information.

Provide and Optimize Products and Services

We use your information to provide and improve our Products and Services, for identification verification, to provide support, for online and offline marketing including through third party tools such as Google Analytics, and for general research and analytics reporting. In doing so, we may learn which of our Products and Services you are using most, what you’re interested in, and to better enable you to use and access our Products and Services. As a core part of our business, TPRH has a legitimate interest in enabling and customizing your experience of our Product and Services offerings.

Engage in Commercial Transactions

As part of providing our core Products and Services, TPRH may charge you for the use of some Products and Services, or certain features within these Products and Services. In order to process your payment, and to secure your financial information, we may facilitate the sharing of your information with third parties. We share your information only with third parties who have met strict security standards and consider the secure processing of your financial information to be a strict and legitimate business necessity.

Comply with Regulatory and Legal Obligations

TPRH has a legitimate interest in complying with certain legal obligations and interests which, from time to time, may require the disclosure of your personal information. TPRH will not disclose your personal information to legal authorities except where such disclosure is by lawful request, including to meet legitimate national security or law enforcement demands (including a subpoena, court order, or other lawful legal demand by a legal authority with lawful jurisdiction). In some cases, we may also release your personal information to defend our legitimate legal interests. We consider our obligation to protect the TPRH community from imminent physical harm to be both a legitimate business interest as well as to be within the public interest and may disclose your personal information if we believe you or another individual may be in imminent danger of harm to yourself or to another.

Marketing and Product Communications

From time to time, TPRH may communicate with you about commercial and other Product and Services offerings. In doing so, we provide you with an opportunity to opt-out of such messages at any time you choose via your email or browser settings. TPRH will not sell your personal information to enhance our marketing opportunities or profitability, and as we are committed to preventing spam, our direct marketing efforts are limited in scope and frequency. We engage in such activities as a legitimate business interest in order to promote key Products and Service offerings and provide you with every opportunity to unsubscribe from such communications or to further limit their scope and frequency. In short, while we want to communicate some key commercial communications with you and have determined it to be a legitimate interest for us to be able to do so, you have the final say in whether or not you would like to receive such commercial communications from us.

Core Business Operations

TPRH may engage with third parties in business transactions including the buying and selling of assets, the auditing of our business practices and financials, and to engage in business development opportunities. These core activities may involve the processing and/or disclosure of some limited personal information which may be necessary and within our legitimate interests to develop the TPRH brand and business. If we transfer any personal information in pursuing such a business transaction, we will always ensure that strict confidentiality measures are in place to protect your privacy interests.

DATA TRANSFERS

TPRH is a global brand and as such, you may access the TPRH Network from most anywhere in the world and are subject to the local laws of your jurisdiction. By accessing the TPRH Network and engaging with our Products and Services, you acknowledge that your personal data may be collected and transferred from your local jurisdiction to the United States or India.

OUR ONGOING COMMITMENT TO DATA SECURITY

Security is important to us and we know it is important to you. TPRH follows generally accepted standards to protect your personal information when processing, transferring, and storing your personal information including Transport Layer Security (“TLS”), by restricting your personal data when we do not need to access it and by keeping your personal data only as necessary to perform our legitimate business interests.

DIRECT MARKETING OPT-OUT

You may opt-out of receiving TPRH email marketing materials by using the unsubscribe link in these communications.

PRIVACY POLICY AMENDMENTS

We may amend or update this policy from time to time, and will notify you of any material changes to this policy. Previous versions of this privacy policy are available upon request.

CONTACT US

General Contact Information Head of Public Relations, [email protected]

HOW DOES THE PAUL RESORTS AND HOTELS USE COOKIES?

A cookie is a small piece of text that allows a website to recognize your device and maintain a consistent, cohesive experience throughout multiple sessions. If you use any website in The Paul Resorts and Hotels Network (“TPRH”), both TPRH and third parties will use cookies to track and monitor some of your activities on and off the TPRH Network, and store and access some data about you, your browsing history, and your usage of the TPRH Network.

This policy describes how both TPRH and other third parties use cookies both within and without the TPRH Network and how you can exercise a greater degree of control over cookies. Please keep in mind that this may alter your experience with our websites and may limit certain features.

General Browsing: We use cookies that are important for certain features of our website, like monitoring sessions to improve our offerings and implementing fixes and improvements to our website.

• Enable behavior in our Products and/or Services that is tailored to the activity or preferences of a person visiting our properties
• Collect information on our users’ preferences in order to create more useful offerings
• Maintain the regular business operations of our Advertising and Marketing departments
• Help to diagnose and correct downtime, bugs, and errors in our code to ensure that our products are operating efficiently

Advertising: We use cookies to enable advertising with our third-party Partners.

• Customize the ad experience for our users, including tailoring room and display ads to the properties a person has previously looked at.
• Collect impressions and click data for internal reporting and product optimization

Analytics: We use cookies to compile usage activity in order to better cater our offerings to you. We DO NOT share identifiable “raw” data with any third parties, however we do make high-level decisions based on aggregated data about your usage of our Products and Services.

• Monitor site traffic and behavior flows of users
• Measure the effectiveness of on-site products
• Measure the effectiveness of off-site marketing campaigns and tactics

WHAT INFORMATION IS COLLECTED ON ME VIA COOKIES

In general, we collect most data from you via form submission on our booking platform through our partnerTravelClick or through our contact forms. However, there are cases when visiting our site and/or using our platforms in which we may receive certain information through the use of cookies. This data will generally not include personally identifying information about you.

Third Party Cookies

The use of cookies, the names of cookies, and other cookies related cookies technology may change over time and The Paul Resorts and Hotels will make all reasonable efforts to notify you by updating our cookies table where material changes occur and from time-to-time. Please also note that companies and other organizations that sponsor The Paul Resorts and Hotels may use cookies or other technologies to learn more about your interest in their products and services and in some cases to tailor such products and services to you.

HOW DO I RESTRICT COOKIES?

If you decide that you do not want cookies to be set on your device by our third-party Partners, you can adjust the settings on your internet browser and choose from the available Cookies setting to best meet your preferences. While setting options may vary from browser to browser, you can generally choose to reject some or all cookies, or instead to receive a notification when a cookie is being placed on your device. For more information, please refer to the user help information for your browser of choice. Please keep in mind that cookies may be required for certain functionalities, and by blocking these cookies, you may limit your access to certain parts or features of our sites and platforms.

Finally, while cookies are set for varying durations on your device, you can manually delete them at any time. However, deleting cookies will not prevent the site from setting further cookies on your device unless you adjust the settings discussed above.

CONTACT US

If you have any questions, comments, or concerns regarding this Cookies Policy, please contact us at: [email protected]