Privacy Policy

Bird Hospitality Services Private Limited is a company incorporated in India, engaged in the business of providing hospitality services, particularly hotel accommodation under the brand/trademark “Roseate Hotels & Resorts” and “The Roseate,” along with all its associates, affiliates, joint ventures, and group companies in India (hereinafter referred to as the “Bird Group” or “we” or “us”). We are committed to protecting the privacy and security of your personal information.

This privacy statement describes how we collect and use your personal information and data, in accordance with applicable data protection laws. It applies to all guests and visitors of the hotels managed, owned and operated by Bird Group in India.

We are responsible for deciding how we hold and use personal information about you and are required under data protection legislation to notify you of the information contained in this privacy statement. This statement does not form part of any contract to provide services and may be updated at any time.

By continuing to use our services, you signify that you have read and understood this Privacy Policy. We will not collect any personal information unless you choose to provide it to us. If you provide personal information to avail our services, we will comply with applicable data protection law and this Privacy Policy.

1. Collected Personal Information

1. Definition: Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Categories we may collect, store and use include:

   1. Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
   2. Date of birth.
   3. Gender.
   4. Marital status.
   5. Next of kin and emergency contact information.
   6. National Insurance or TAX ID number/PAN card.
   7. Bank account details, payroll records and tax status information.
   8. Driving licence.
   9. Grievance information.
   10. CCTV footage and other information obtained through electronic means such as door access records.
   11. Information about your use of our information and communications systems.
   12. Photographs.
   13. Payment information, such as credit or debit card information (cardholder name, card number, billing address, expiry date).
   14. Travel information, such as ticket numbers, destinations, visa information, flight information.
   15. Smoking or non-smoking preferences.
   16. Information we receive from you on official social media channels and our website.
   17. Information about your health, including but not limited to any medical conditions and food allergies.
   18. Sensitive Personal Information: We may also collect sensitive information such as information about your race, ethnicity, religion or health (“sensitive personal data”). Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your hotel stay and travel arrangements that reveal or suggest something about you that could be considered “sensitive personal data”, or if you otherwise choose to provide such information to us (or a third party such as the travel agent through which you made your booking). Examples include requests for halal or kosher meals (which may imply religion) or requests for specific medical assistance (which may reveal a medical condition).
   19. Any other personal information that you choose to send to us.

2. How is your personal information collected?

We collect personal information about you through various methods like your check-ins, bookings, and reservations, provided either directly by you or sometimes from a third party acting on our behalf (for example through a booking agency, travel agent or corporate account). Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose personal information is supplied to Bird Group has authorised the disclosure, and is informed of and agrees to this Privacy Policy.

3. How we will use information about you

A. Principles

1. Lawfulness, fairness and transparency
2. Purpose limitation
3. Data minimisation
4. Accuracy
5. Storage limitation
6. Integrity and confidentiality

B. Lawful bases and purposes

1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4. Where you have given us explicit consent to do so.
5. In rare situations: to protect your interests (or someone else’s), for the public interest or for official purposes, or when requested by investigating agencies, police or governmental authorities.
6. Enable your use of the services available at our hotels.
7. Send statements, invoices and payment reminders, and collect payments from you.
8. Send non-marketing commercial communications.
9. Send email notifications that you have specifically requested.
10. Send our email newsletter if requested (you can unsubscribe at any time).
11. Send marketing communications relating to our business or carefully-selected third parties by post or, where specifically agreed, by email or similar technology (you can opt out at any time).
12. Provide third parties with statistical information about our users without identifying individuals.
13. Deal with enquiries and complaints relating to services provided.
14. Keep our website and/or mobile application secure and prevent fraud.
15. Publish personal information you submit for publication on our website or other publications (online/offline, including social media) in accordance with the licence you grant to us.
16. We will not, without your express consent, supply your personal information to any third party for their direct marketing.
17. All financial transactions via our website and/or mobile application are handled through our payment service providers; we share information only to the extent necessary for processing payments, refunds, and dealing with related complaints/queries.

4. If you fail to provide personal 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 (such as providing a benefit), or we may be prevented from complying with our legal obligations (such as ensuring health and safety or proof of nationality, e.g., passport).

5. Disclosing personal information

1. We may disclose your personal information to our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy and for providing services.
2. We may disclose your personal information within our group companies (subsidiaries, ultimate holding company and its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3. We may disclose your personal information:
   1. as required by law;
   2. in connection with any ongoing or prospective legal proceedings;
   3. to establish, exercise or defend our legal rights (including fraud prevention and reducing credit risk);
   4. to a purchaser or prospective purchaser of any business or asset we are (or are contemplating) selling; and
   5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure where such disclosure is likely to be ordered.
4. Except as provided in this policy, we will not provide your personal information to third parties.

6. International Data Transfer

1. Information we collect may be stored and processed in, and transferred between, any countries in which we operate, in order to use the information as described in this policy.
2. Information may be transferred to countries without an adequacy decision by the European Commission. To ensure adequate protection, we implement strong inter-country security measures so that your personal information is treated consistently with EU and UK data protection laws.
3. By using our services, you expressly agree to such transfers as described in this section.

7. Data Security

1. We have put in place measures to protect the security of your personal information.
2. Third parties will only process your personal information on our instructions and where they have agreed to treat it confidentially, legally and securely.
3. We implement appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access is limited to those with a business need to know and subject to confidentiality obligations.
4. We maintain procedures to deal with suspected data security breaches and will notify you and any applicable regulator where legally required.
5. We store personal information on secure, password- and firewall-protected servers.
6. All electronic financial transactions via our website and/or mobile application are protected by encryption technology.
7. You acknowledge that transmission of information over the internet is inherently insecure. Any transmission is at your own risk.
8. You are responsible for keeping your website and/or mobile application password confidential. We will not ask for your password except when you log in.

8. Your Rights

You have certain rights in relation to the personal information we hold about you. To exercise any of these rights, please contact us at [email protected]. We may require proof of identity and address. We will respond without undue delay and at least within one month (extendable by two months in certain circumstances).

• The right of access
• The right of data portability
• The right of rectification
• The right of erasure
• The right to restrict processing
• The right to object

Complaints

If you wish to make a complaint about how we process your personal information, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to lodge a claim with your data protection authority.

Access

You have the right to know whether we process personal information about you and to access the personal information we hold and certain details about how we use it and with whom we share it. If you require more than one copy, we may charge an administration fee. We may withhold certain personal information if disclosure would interfere with another’s rights or another exemption applies.

Portability

You have the right to receive a subset of personal information we collect from you in a structured, commonly used and machine-readable format and to request that we transfer such personal information to another party, where legally, contractually and technically feasible.

Correction

You have the right to correct any inaccurate personal information held about you. While we assess accuracy or completeness, you may exercise your right to restrict processing.

Erasure

You may request that we erase personal information we hold about you where, for example, it is no longer necessary, consent is withdrawn and no other legal ground applies, you object to processing based on legitimate interests, you no longer wish to receive marketing, or you believe processing is unlawful. We may retain information where legally justified (e.g., defence of legal claims or freedom of expression). After deletion, we may not be able to provide the same level of service as we will not be aware of your preferences.

Restriction of Processing to Storage Only

You may request we stop processing (other than storage) where: accuracy is contested (pending verification); processing is unlawful and you prefer restriction to erasure; data is no longer needed by us but required by you for legal claims; or you have objected to processing based on legitimate interests while we assess overriding interests.

Objection

You may object at any time to our processing of personal information about you for promotions, special offers, and marketing (including profiling for such purposes), in which case we will stop processing for that purpose. You may also object to other processing based on legitimate interests; please email [email protected] with your reasoning so we can assess whether there is a compelling overriding interest or legal necessity.

9. Retention

1. We maintain data retention policies designed to ensure compliance with legal obligations regarding retention and deletion of personal information.
2. Personal information processed for any purpose shall not be kept longer than necessary.
3. We usually delete personal data in accordance with client contracts and agreements.
4. We may retain documents (including electronic documents) containing personal information:
   1. as required by law;
   2. if relevant to ongoing or prospective legal proceedings;
   3. to establish, exercise or defend legal rights (including fraud prevention and reducing credit risk);
   4. to the extent necessary to fulfil the purposes collected for, including legal, accounting, or reporting requirements.
5. To determine retention periods, we consider the amount, nature and sensitivity of the data, potential risks from unauthorised use or disclosure, the purposes of processing and whether those can be achieved by other means, and applicable legal requirements.

10. Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis allowing us to do so. We may process personal information without your knowledge or consent where required or permitted by law.

11. Amendments

1. We may update this policy from time to time by publishing a new version on our website and/or mobile application.
2. Please check this page occasionally to ensure you are happy with any changes.
3. We may notify you of changes by email or through the private messaging system on our website and/or mobile application.

12. Third Party Websites and/or Mobile Applications

1. Our website and/or mobile application may include hyperlinks to third-party websites and applications.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

13. Updating information and accuracy

1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
2. We need your assistance to ensure that your personal information is current, complete and accurate. Please inform us of changes by contacting us in writing. We reserve the right to charge a reasonable administrative fee for this service.

14. Cookies

1. Our website and/or mobile applications may use cookies.
2. A cookie is a file containing an identifier sent by a web server to a web browser and stored by the browser. The identifier is sent back to the server each time the browser requests a page.
3. Cookies may be “persistent” or “session” cookies. A persistent cookie remains valid until its set expiry date (unless deleted earlier). A session cookie expires at the end of the user session (when the browser is closed).
4. Cookies do not typically contain information that personally identifies a user, but personal information we store about you may be linked to information stored in and obtained from cookies.
5. We may use session cookies, persistent cookies, or both, for purposes such as recognising a computer, tracking navigation, enabling shopping cart functionality, improving usability, administering the site, preventing fraud, personalising content, targeting advertisements, validating authenticated sessions, facilitating search, etc.
6. Most browsers allow you to refuse to accept cookies.
7. Blocking all cookies may negatively impact site/app usability; certain features may not function.
8. You can delete cookies already stored on your computer; doing so may negatively impact usability.

15. Contact Information

Bird Hospitality Services Private Limited
E 9, Connaught Place,
New Delhi – 110001
Email: [email protected]
Referencing: Data Protection