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, publicrelations@thepaul.in
