Confidentiality Agreement

The information contained in this document is the property of Sterling Holiday Resorts Limited (SHRL) and may not be copied, communicated to a third party, or used for any purpose other than that for which it is supplied without the express written consent of SHRL.

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 use cookies and similar technologies to enhance your experience on our website, www.sterlingholidays.com, mobile applications, and other digital platforms (collectively, "Platforms"). This Cookie Policy explains what cookies are, how we use them, and how you can manage your preferences. By using our Platforms, you consent to the use of cookies as described in this policy.

1. What Are Cookies?

Cookies are small text files stored on your device (e.g., computer, smartphone, tablet) when you visit our Platforms. They enable functionality, remember preferences, and provide insights to improve our services. Cookies may be:

• Session Cookies: Temporary, deleted when you close your browser.
• Persistent Cookies: Stored until deleted manually. Similar technologies (e.g., web beacons, local storage) may also be used and are covered by this policy.

2. How We Use Cookies

We use cookies to deliver a seamless, secure, and personalized experience on our Platforms, which offer services such as resort and hotel bookings, vacation ownership (Sterling Holidays Vacation Ownership Points Plan), event planning (e.g., weddings, corporate events), and destination information via our AI-enabled chatbot, Merlin. Cookies enable us to:

• Enhance Functionality: Ensure smooth navigation, secure booking processes, and access to member areas, and record sessions for a smoother experience.
• Personalize Experience: Tailor content (e.g., resort recommendations, event offers) based on your preferences, browsing history, or membership details.
• Analyze Performance: Collect anonymized data on user interactions to optimize Platform design and functionality.
• Facilitate Transactions: Support secure reservations, payment processing, and availability checks.
• Deliver Marketing:  Provide targeted promotions about resorts, workcations, vacation ownership plans, and products like and not limited to What-A-Trip, Corporate Plus, and resort-based services such as Food & Beverage (F&B), Spa, and Destination & Experiences (D&E), including cross-device tracking.

3. Types of Cookies We Use

We categorize cookies as follows:

a. Essential Cookies

• Purpose: Critical for Platform operation, enabling core features like member logins, booking dashboards, and payment processing.
• Examples: Session management cookies, authentication cookies.
• Retention: Session-based or until deleted manually.
• Note: These cannot be disabled, as they are necessary for functionality.

b. Performance and Analytics Cookies

• Purpose: Collect anonymized data on Platform usage (e.g., page visits, dwell time) to improve performance and user experience.
• Examples: Google Analytics (_ga, _gid), Adobe Analytics.
• Retention: Until deleted manually.
• Note: Opt-out available via browser settings.

c. Functionality Cookies

• Purpose: Remember user preferences (e.g., resort selections, language, region) for a personalized experience.
• Examples: Preference cookies, membership dashboard cookies.
• Retention: Until deleted manually.
• Note: Opt-out available via browser settings.

d. Marketing and Targeting Cookies

• Purpose: Deliver personalized ads and communications (e.g., resort promotions, event offers, What-A-Trip, Corporate Plus, F&B, Spa, D&E) and track campaign effectiveness.
• Examples: Google Ads, Facebook Pixel, DoubleClick.
• Retention: Until deleted manually.
• Note: Opt-out available via browser settings.

4. Third-Party Cookies

We use third-party services that may set cookies on our Platforms, including:

• Analytics: Google Analytics, Adobe Analytics.
• Advertising: Google Ads, Facebook, DoubleClick.
• Payments: Razorpay, PayU.
  These cookies are governed by the respective third parties’ privacy policies (linked on our Privacy Policy page). We ensure third parties comply with data protection laws through Data Processing Agreements (DPAs) and, for international data transfers, Standard Contractual Clauses (SCCs) or adequacy assessments.

5. Managing Your Cookie Preferences

You can manage cookie preferences via your browser settings. Options include:

• Accept All Cookies: Enable all cookie types.
• Customize Preferences: Disable non-essential cookies (performance, functionality, marketing).
• Delete Cookies: Remove existing cookies through your browser.

Browser Settings:

• Google Chrome: Settings > Privacy and Security > Cookies and Other Site Data.
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data.
• Safari: Preferences > Privacy.
• Microsoft Edge: Settings > Cookies and Site Permissions.

Note: Disabling essential cookies may impair functionality (e.g., booking or login issues).

6. Cookies and Personal Data

Some cookies collect personal data (e.g., IP address, browsing behaviour, membership details) to provide personalized services. We process this data under lawful bases, such as:

• Consent: For marketing and non-essential cookies.
• Legitimate Interest: For analytics and functionality, balanced with your rights.
• Contractual Necessity:  For bookings and payments. Personal data is handled per our Privacy Policy (https://www.sterlingholidays.com/privacy-policy). You have rights under applicable Data Privacy laws, including:
• Access: View your data.
• Rectification: Correct inaccurate data.

7. Children’s Data

Our platforms are not directed at children under 18. 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.

8. Cookie Retention and Deletion

Persistent cookies are retained until deleted manually via your browser settings.

9. Updates to This Cookie Policy

We may update this policy to reflect changes in practices, services, or legal requirements.
This policy was last updated in August 2025.