Privacy Notice for SHRL Customers/ Website Visitors/ Job Applicants

Sterling Holiday Resorts Limited, its group companies and subsidiaries, including but not limited to entities operating under different brand names within the SHRL group, its subsidiaries and branch operations of SHRL, and other entities managed and operated by SHRL, SHRL group or its subsidiaries hereinafter referred as ‘SHRL’, ‘we’, ‘us’ or ‘our’ is committed to respect your privacy and choices. We respect your privacy and are committed to honouring and protecting your privacy rights and the reason we collect your personal data is to improve our services to you. We are committed to treating your Personal Data with the utmost care in all circumstances.

We have designed our Privacy Notice to provide transparency into our privacy practices and principles in a format that is easily understandable and readable.

This Privacy Notice explains the purposes for which we collect your personal information, the other parties with whom we may share it and the measures we take to protect the security of your data. It also tells you about your rights and choices with respect to your personal information, and how you can contact us about our privacy practices.

This Privacy Notice also explains how we process the Personal Data we collect about you, when you avail   any of our services directly, and/or by agreeing to this Privacy Notice, this privacy notice is also applicable when you apply for a job or an internship at SHRL.

We shall protect your personal data, to keep it secure as per applicable privacy and data protection laws.

What Personal Data do we collect?

Personal Data, or Personal Information, means any information or combination of information that could identify you directly (e.g., your name) or indirectly (e.g., through your email address or telephone number). This may include identifiers such as name, address, phone number, email ID, and reservation or transaction details. We may also collect information such as your preferences, age, gender, occupation, which may not in isolation identify you but could contribute to profiling you when combined with other identifiers. The type of Personal Data we collect depends on how you interact with us and generally falls into five main categories:

Reservation Data – Information related to hotel reservations, regardless of booking channel (Website, App, travel agency, chatbot or direct booking). This includes your contact details, reservation number, hotel name, stay dates, rate, meal plan, personal preferences, and billing/financial information.

Guest Data – Information about guests who have stayed, will stay or are staying at our hotels. This includes contact details, gender, birth date, other personal information details, reservation history, personal preferences, requests and redressals, marketing communication preferences and government ID details.

Member Data – Information related to your membership in our SHRL program, including contact details, gender, birth date, other personal information details, membership tier, status, reward points, redemption history, enrolment details, reservation history, personal preferences and government ID details.

Recruitment Data – Information collected during the recruitment process, including application details, CVs, employment history, qualifications, skills, interview records, reference checks, eligibility to work, and talent pool inclusion for future opportunities.

Others – Information collected during – but not limited to – login/signup, feedback or queries, while filling up enquiry forms on the website and includes contact details, gender, birth date, reservation history, personal preferences, and marketing communication preferences.

Categories of Data Collected

We collect and process several types of Personal Data, including but not limited to:

-        Contact Information: Name, email address, postal address, country, phone number, and similar details.

-        Financial Information: Payment details, transaction history, billing preferences, and spending patterns.

-        Technical Information: Device and website usage, IP address, and data collected through cookies and tracking technologies.

-        Product & Service Information: Account membership details, registration information, and service-specific data.

-        Reviews & Feedback: Customer opinions, ratings, and experiences shared through surveys or online platforms.

-        Loyalty Program Data: Membership details, reward points, redemption history, and travel partner affiliations.

-        Transaction Information: Dates, amounts, and history of transactions made with us.

-        Career & Recruitment Data: Application details, qualifications, interview records, reference checks, employment eligibility, and talent pool inclusion for future job opportunities.

-        Other Data (including sensitive personal data): Age, gender, date of birth, marital status, nationality, government ID details, occupation, ethnicity, religion, and travel history.

We collect this information to enhance your experience, improve our services, and also to comply with Government directives and compliances.

How do we collect your Personal Data?

We collect, process, and retain your Personal Data when you visit our website, stay at one of our hotels, apply for a Job or internship or engage with our services. You may provide this information directly when making a reservation, subscribing to our newsletter, purchasing gift cards, or contacting our customer service. Personal Data collected may include your name, contact details, demographic information, other personal information details, payment details, and social media identifiers. If you provide Personal Data about others (e.g., making a booking for another guest), you hereby confirm that you have obtained their explicit consent to share their data for processing in accordance with this Privacy Policy. You further agree to indemnify SHRL against any liability arising from failure to obtain such consent.

Automatically Collected Information

When you interact with our website, chatbot or App, we automatically collect certain data to enhance your experience and improve our services. This includes Log Data such as IP addresses, device details, browser type, pages visited, and interaction timestamps. We may use cookies, web beacons, and similar tracking technologies to collect behavioural insights, improve website functionality, and personalize content. You may control cookie settings through your browser, but disabling them could impact our ability to enhance your experience and improve our services on our website, chatbot and App.

Third-Party Data Sources

We may receive Personal Data about you from third-party sources, including travel booking platforms, travel agents, credit card providers, Alliance Partners and publicly available information. We rely on these third parties to ensure that they have obtained the necessary legal permissions and consents to share your personal data with us. We are not responsible for any non-compliance by third-party providers in relation to the lawful collection or disclosure of personal data. Additionally, we collect data from social media platforms when you interact with our content and from online review platforms (e.g., Tripadvisor, Booking.com, Google, Facebook, Instagram, LinkedIn) when you provide feedback on your stay or our services. This helps us enhance our customer experience, tailor our services, and address any concerns efficiently.

Careers

If you apply for a job with us, we may collect and process Personal Data related to your application, including your name, contact details, employment history, educational background, and any additional information you provide in your resume or cover letter. This data is used for recruitment purposes, evaluating candidates, and communicating with you throughout the hiring process. Any Personal Data submitted via our careers section, email, or other recruitment platforms will be stored and processed in accordance with this Privacy Policy.

Why do we collect your Personal Data?

SHRL processes your Personal Data in compliance with applicable data protection laws. The lawful bases on which we rely include:

Consent - We process your data with your explicit consent, for example, when you opt-in to marketing communications, loyalty programs, or provide sensitive information (such as health data) for special accommodations.

Performance of Contract - Processing is necessary to fulfil our contractual obligations to you, such as managing bookings, memberships, rewards, recruitment processes, and customer services.

Legal Obligations - We process data to comply with laws and regulatory requirements, including tax filings, security obligations, lawful disclosures, and fraud prevention.

Legitimate Interests - We process Personal Data for our legitimate business interests, such as improving our services, ensuring security, conducting market research, and managing customer relationships.

Vital Interests - In exceptional circumstances, we may process your data to protect your vital interests or those of others, such as during health or safety emergencies.

The key purposes for collecting Personal Data include:

-        Membership & Loyalty Programs: Managing SHRL memberships, tracking rewards, and providing personalized benefits.

-        Hotel & Resort Management: Facilitating reservations, check-ins, guest services, and ensuring security and legal compliance.

-        Travel & Booking Services: Processing reservations and coordinating with travel agencies and service providers.

-        Business Operations & Customer Support: Improving services, handling inquiries, and managing customer relationships.

-        Marketing & Engagement: Sending promotional offers, personalized recommendations, and conducting market research (with user consent).

-        Legal & Regulatory Compliance: Meeting tax, financial, and security requirements while preventing fraud and unauthorized activities.

-        Sensitive Data Processing: Only processed with explicit consent or legal necessity, such as health-related requests.

-        Third Party Sources: We may receive your Personal Data from third parties, who are responsible for

o   Verifying references and employment eligibility.

o   Maintaining a talent pool for future job opportunities.

o   Issuing offer letters to successful candidates.

SHRL only processes special categories of Personal Data (e.g., health-related data) when required by law or when you provide explicit consent. This may occur in limited cases such as health accommodations during stays or legal documentation requirements.

SHRL ensures that all Personal Data is collected fairly, lawfully, and transparently while respecting users· rights and privacy. Users may withdraw consent for marketing communications, recruitment processes, or other data processing at any time by pressing an appropriate “Unsubscribe” button, or by writing an express email to [email protected].

With whom do we share your personal data?

When we share your personal data with trusted third-party service providers and partners, we require them to adhere to applicable data protection laws and implement appropriate safeguards to protect your personal information. However, we do not accept responsibility or liability for any misuse, unauthorized access, or breach of your personal data that occurs due to acts or omissions by these third parties outside our control.

·       No Sharing for Third-Party Marketing

We do not share your Personal Data with third parties for their independent marketing purposes. However, if you choose to share your data with social media platforms or other third-party sites (for example, by linking your account to a social media platform or using a third-party service), those external entities may use it for marketing.

·       Sharing Within SHRL Group and subsidiaries

Your Personal Data may be shared across SHRL’s affiliated companies when necessary for providing services, managing operations, or improving our business processes. Access is limited to only those who need it.

·       Sharing with SHRL Hotels

When you book a stay at a SHRL hotel, your reservation details are shared with the hotel to manage your booking, payment, and any special requests. If you are a loyalty member, we share your details with the hotel to apply your member benefits. Hotels may also share feedback or complaints back with us for service improvement.

·       Sharing with Hotel Owners

Some SHRL hotels are managed by us but owned by third parties. In these cases, we may share certain data for accounting, guest records, and operational purposes under strict agreements.

·       Sharing with Travel Agents and Online Travel Websites

If you book a stay through a travel agent or an online travel website, we share your reservation details with them to process your request and fulfil their requirements.

·       Sharing with Service Providers

We work with third-party service providers who assist us with:

o   Managing databases, websites & marketing communications (based on legitimate interest / consent)

o   Conducting surveys and customer feedback collection to improve our offerings.

o   Providing technical and logistical support for seamless operations

o   Processing payments securely in compliance with financial regulations

o   Assisting with reservations and order fulfilment for guest stay

 

 

These partners only receive the data necessary to provide their services and are required to keep it secure. Also, they are contractually bound to use the shared data only for the intended purpose and in compliance with applicable data protection laws. However, SHRL disclaims liability for any data breach or misuse resulting from the independent actions, omissions or negligence of such Service Providers outside our control.

·       Public Disclosures

Please note that any information you choose to submit on these pages may be publicly visible to other users. Before posting, ensure that you do not share personal or sensitive data unless you are comfortable making it public. You have the right to request the deletion or modification of your comments where applicable. If you need assistance with managing your posted information, please contact us by writing to us at [email protected].

·       Other Disclosures Without Your Consent

We may disclose your information when required by law, such as in response to subpoenas, warrants, court orders, or other legal processes. We may also share data:

o   To comply with national security laws within our operating jurisdictions

o   To establish or defend legal claims

o   To investigate, prevent, or take action regarding fraud, illegal activities, or policy violations

o   To fulfil your request for third-party services or product shipments

o   With corporate affiliates (subsidiaries, joint ventures, or related entities)

o   If SHRL or its assets are acquired or are in negotiations for acquisition by another company

 

·       Other Disclosures with Your Consent

In some cases, we may request your consent to share your Personal Data with associated third parties not listed in this policy. If you have any questions about how we share your Personal Data, please contact us by writing to us at [email protected].

·       Sharing with Third Parties

We may share your Personal Data with third-party business partners of SHRL group in accordance with this Privacy Policy. While we enter into appropriate agreements to ensure these third-party business partners handle your data with care, we are not liable for breaches of data privacy arising from the acts or omissions of such third parties acting independently of our instructions.

How long do we keep your Personal Data?

We retain your Personal Data for as long as it is necessary to fulfil the purposes for which it was collected and to meet applicable legal, regulatory, and business requirements. The retention period depends on the nature of the data, our operational needs, and relevant obligations. You may request deletion of your personal data at anytime by writing to us at [email protected] subject to any overriding legal obligations we may have.

For job applicants, if you are not selected, your data may be retained for future employment opportunities. If hired, your data will be retained in our employee records and for official purposes, including statutory compliance (e.g., IT systems, Provident Fund, ESI).

Where do we store and process your Personal Data?

SHRL primarily stores and processes your personal data in India. However, certain services, including those provided by third-party SAAS platforms, may involve the storage and processing of your data in data centres located outside India.  In such cases, we take reasonable steps, including periodic reviews and contractual safeguards, to ensure that our partners and service providers implement appropriate measures to protect your personal data.

How do we protect your Personal Data?

We take strong measures to keep your Personal Data safe from unauthorized access, loss, or misuse to our best ability possible. Our security includes secure data storage, network security, strict access controls, threat detection and data transmission security.

What are your rights regarding your Personal Data?

We are committed to upholding your rights regarding the processing of your personal data, as provided under applicable data protection laws. These rights include:

Your Rights

·       Right to Information: You have the right to - details about - collection and use of your Personal Data.

·       Right to Access: You can request a copy of the personal data we hold about you. We will provide this in electronic or written form as per applicable laws.

·       Right to Rectification: If your Personal Data is incorrect or incomplete, you can request that we update or complete it.

·       Right to Deletion (Right to be Forgotten): You can ask us to delete your Personal Data when:

o   It is no longer needed for the purpose it was collected.

o   You withdraw your consent, and we have no other legal reason to keep it.

o   It has been processed unlawfully.

o   We are required by law to delete it.

Note: We may retain certain data if required by law or for legitimate business reasons.

·       Right to Withdraw Consent: Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. You may do so by writing to us at [email protected]. Please note that withdrawal of consent does not affect the legality of data processing done before the withdrawal. However, where processing is required by law or under legitimate interests, your rights may be limited.

·       Right to Restriction of Processing: You can ask us to temporarily stop processing your Personal Data in certain situations, such as when verifying its accuracy or assessing a legal claim.

·       Right to Data Portability: You have the right to request that we provide the Personal Data we hold in respect of you, for which you provided consent, in a structured, commonly used, and machine-readable format to you or another service provider. SHRL may limit or deny such requests with appropriate reasons, if they significantly harm our legitimate business interests, as permitted by law.

·       Right to Object: You can object to certain types of data processing, including when we process your Personal Data based on legitimate interests or for direct marketing purposes.

·       Right to Grievance Redressal: If you have any concerns about how we process your Personal Data, you have the right to raise a grievance by writing to us at [email protected]

·       Right to Nominate: You have the right to nominate another individual to exercise your data rights on your behalf in case of incapacity or death.

How to Exercise Your Rights

You can exercise your rights by writing to us at [email protected]. We will respond within the time required by applicable laws. To protect your privacy, we may need to verify your identity before processing your request. For any concerns regarding your data privacy, please write to us at [email protected].

 

Your Choices

You can decide whether you want to receive marketing messages from SHRL.

·       We obtain your consent through selecting an unchecked opt-in box during account creation or when subscribing to our services before sending promotional emails or offers. For walk-in guests and certain third-party referred guests, we offer the option to opt out of receiving promotional emails and special offers at the time of check-in.

·       You can opt out at any time by clicking the unsubscribe link in our emails or writing to us at [email protected].

How We Contact You

We may contact you via email, WhatsApp, phone, SMS, browser push notifications, direct postal mail, In-app notifications, social media messaging or other appropriate channels, in accordance with your communication preferences and applicable law to:

·       Remind you about your membership benefits.

·       Share updates on our services, promotions, and offers.

·       Inform you about other SHRL products and services.

If you want to opt out at any time, you can do so by clicking the unsubscribe link in our emails or writing to us at [email protected].

Your Responsibilities

Please provide only your own accurate personal data. If you share another individual's information, ensure you have their explicit consent and comply with legal obligations. By using a credit card not in your name, you confirm the cardholder's consent to its use and data processing.

Protection of Children's Privacy

Our website does not offer products or services for use by minors. If you are under 18, you may use our website only under parental guidance. In the event that a minor accesses or uses our products or services despite this policy, Sterling Holiday Resorts Limited (SHRL) shall not be held responsible, and such use shall be deemed to have been made with the consent and under the sole responsibility of the minor’s parent or legal guardian.

Updates to This Privacy Notice

We may update this Privacy Notice periodically to reflect changes in our services, legal requirements, or business practices.  The most current version will be made available on our website and may also be shared through future communications, where appropriate, to keep all individuals informed of any significant changes.

As SHRL continues to evolve to meet customer needs, our policies may be reviewed and revised accordingly. We encourage you to check this Privacy Notice regularly for any updates.

This Privacy Notice was last updated on July, 2025.