Privacy policy
MPS SAI Palace – Global
Privacy Policy
At MPS SAI Palace, its affiliates
and subsidiaries (hereinafter collectively referred to as “MPS”, “we” or “us”
or “our”), we endeavor to provide our guests outstanding services and
experiences in our hotels and luxury residences around the world. We value your
business and your faith in us in delivering you a superior level of service.
We recognize that privacy is
important to our guests, and hence our Global Privacy Policy explains our
practices regarding personal information we collect when you visit or use our
hotels, restaurants, bars, spas, salons, etc. and our website, mobile applications,
or other online products and services or when you fill up a form and become
member of our loyalty programs. We shall protect your personal data, to keep it
secure as per applicable privacy and data protection laws.
It also describes the purposes
for which we collect that 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.
You are advised to carefully read
this Privacy Notice before using or availing any of our products and/or
services.
1. DEFINITIONS
In this Privacy Notice, the
following definitions are used:
Data - personal information,
including sensitive personal information and special category personal data (as
defined under Data Protection Laws) about you, which we collect, receive or
otherwise process in connection with your use of our stores, website and/or
mobile application.
Cookies - a small file placed on
your device by our website or mobile application when you either visit or use
certain features of our website or mobile application. A cookie generally
allows a website or mobile application to remember your actions or preference
for a certain period of time.
Data Protection Laws - any
applicable law for the time being in force relating to the processing of Data.
Partners - select third parties
(including Booking.com) with whom we have contracts for the businesses
described in this Privacy Notice.
Service Providers -includes
entities which provide services to IHCL and to whom we may disclose your Data
for a specific purpose pursuant to a written contract.
MPS SAI PALACE (“MPS”) - a
company incorporated in India whose registered office is at Tiruvannamalai,
Tamilnadu, India - 606601
Booking.com, and its
subsidiaries, affiliates, associate companies and joint venture companies.
User or you- the natural person
who accesses our services , websites or mobile application.
2. WHAT DATA DO WE COLLECT
ABOUT YOU
MPS collects Data for various
purposes set out in this Privacy Notice.
This Data includes, without
limitation, the following categories:
(a) Contact information:
first and last name, email address, postal address, country, phone number and
other similar contact data.
(b) Financial information:
payment instrument information, transactions, transaction history, preferences,
method, mode and manner of payment, spending pattern or trends, and other
similar data.
(c) Technical information:
website, device and mobile app usage, Internet Protocol (IP) address and
similar information collected via automated means, such as cookies, pixels and
similar technologies. This may include the information mandated by the law enforcement
agencies.Product and service information: Your account membership number,
registration information, and program-specific information, when you request
products and/or services directly from us or participate in marketing programs.
(d) Your reviews, feedback and
opinions about our products, programmes and services.
(e) Loyalty programme
information: your loyalty membership information, account details, profile or
password details and any frequent flyer or travel partner programme
affiliation.
(f) Transaction information: date
of the transaction, transaction amount, transaction history and related
details;
(g) Other information (which may
include special category personal data): Age, sex, date of birth, marital
status, nationality, details of government identification documents provided,
occupation, ethnicity, religion, travel history or any other personal
information provided in responses to surveys or questionnaires.
3. HOW WE COLLECT DATA
We collect Data in the following
ways:
Information You Give Us: We
receive and store any information you enter on our website or mobile
application or give us in any other way (e.g., at our outlets, stores, hotels,
kiosks). Please see the section below, titled “Data Shared by You” for more information.
Automatic Information We Collect:
We use “cookies”, pixels and similar technologies to receive and store certain
types of information whenever you interact with us. Please see the section
below, titled “Data That is Collected Automatically” for more information.
E-mail Communications: We often
receive a confirmation (if your device supports such capabilities) when you
open e-mail from us or click on a link in the e-mail. You can choose not to
receive marketing emails from us by clicking on the unsubscribe link in any
marketing email.
Automatic Information We Collect
from Other Websites: We receive and store certain types of information when you
interact with third-party websites that use our technology or with whom we have
a specific agreement.
Information from Other Sources:
We may obtain information from other sources. An example of this is when you
authorize a third-party website (such as the website of another Booking.com) to
interact directly with our website or mobile application to provide or receive
information about you. In that case, we may receive information to identify
your account with that website.
Information Previously Provided
to Booking.com: Where you have shared any information previously with any of
the Booking.com is permitted to further share such information, it will share
such information with us. If such information is sensitive personal information
or special category personal data, the Booking.com will only share such
information with us with your consent.
You can make choices about our
collection and use of your Data. For example, you may want to access, edit or
remove your Data on our website or mobile application. When you are asked to
provide Data, you may decline. For more information, please see the section
below, titled “Your Rights and Choices”.
4. DATA SHARED BY YOU
MPS may collect your Data in
several ways from your use of our stores, website or mobile application. For
instance:
(a) when you register with us to
receive our products and/or services;
(b) when you conduct a
transaction with us or attempt a transaction at our stores, on our website or
mobile application;
(c) when you complete surveys
conducted by or for us;
(d) when you elect to receive any
communications (including promotional offers) from us;
(e) from the information gathered
by your visit to our stores, website or mobile application;
5. DATA THAT IS COLLECTED
AUTOMATICALLY
(a) We automatically collect some
information when you visit our website or use our mobile application. This
information helps us to make improvements to our content and navigation. The
information collected automatically includes your IP address.
(b) Our web servers or affiliates
who provide analytics and performance enhancement services collect IP
addresses, operating system details, browsing details, device details and
language settings. This information is aggregated to measure the number of visits,
average time spent on the site, pages viewed and similar information. MPS uses
this information to measure the site usage, improve content and to ensure
safety and security, as well enhance performance of our website or mobile
application.
(c) We may collect your Data
automatically via Cookies, pixels and similar technologies in line with
settings on your browser. For more information about Cookies, please see the
section below, titled “Cookies, Pixels and Similar Technologies”.
6. OUR USE OF DATA
Data collected by us may be used
by us for the following reasons:
(a) carry out our obligations
arising from any contract entered into between you and us;
(b) provide products and/or
services and communicate with you about products and/or services offered by us;
(c) enable Booking.com and
Partners to offer their products and/or services and communicate with you about
such products and/or services;
(d) process, disclose, transmit,
and/or share the Data with Booking.com, and other third parties which have
business or contractual dealings with us;
(e) provide you with offers
(including for financial products and/or services), personalized services and
recommendations and improve your experience on our website and mobile
application;
(f) operate, evaluate and improve
our business, website and mobile application;
(g) generate aggregated data to
prepare insights to enable us to understand customer behavior, patterns and
trends with a view to learning more about your preferences or other
characteristics;
(h) provide privileges and
benefits to you, marketing and promotional campaigns based on your profile;
(i) in connection with loyalty
programs owned and operated by us or by other Booking.com;
(j) communicate with you
(including to respond to your requests, questions, feedback, claims or
disputes) and to customize and
improve our services;
(k) enforce the terms of use of
our website and mobile application;
(l) protect against and prevent
fraud, illegal activity, harm, financial loss and other legal or information
security risks; and
(m) serve other purposes for
which we provide specific notice at the time of collection, and as otherwise
authorized or required by applicable law.
Where required under relevant
Data Protection Laws, we may need to ensure that there is a legal basis to
justify our processing of your Data. There are a number of different ways that
we are lawfully able to process your Data. We have set these out below.
Where processing your Data is
necessary for us to carry out our obligations arising from any contracts
entered into between you and us: If you enter into a contract with us in
relation to any of our product or service offerings, we may process certain Data
about you in order to perform our obligations under this contract, including to
enable us to communicate with you about such products and/or services and to
process your payment transactions.
Where processing your personal
information is within our legitimate interests: We can process certain Data
where it is necessary for the purposes of the legitimate interests pursued by
us or by a third party, except where such interests are overridden by the
interests or fundamental rights or freedoms of yours which require protection
of your Data. The ways in which we may process your Data for the purposes of
our legitimate interests include:
enforcing the terms of use of our
website and mobile application;
generating aggregated data to
prepare insights to enable us to understand customer behaviour, patterns and
trends with a view to learning more about your preferences or other
characteristics;
improving our website and mobile
application and ensuring that they run smoothly;
providing you with offers,
personalized services and recommendations and improving your experience on our
website and mobile application;
protecting against, and
preventing, fraud, illegal activity, harm, financial loss and other legal or
information security risks;
providing offers, privileges and
benefits to you, marketing and promotional campaigns based on your profile;
communicating with you (including
responding to your requests, questions, feedback, claims or disputes) and
customising and improving our services;
operating, evaluating and
improving our business;
enabling Booking.com and Partners
to offer their products and/or services and to communicate with you about such
products and/or services;
in connection with loyalty
programs owned and operated by us or by other Booking.com and processing,
disclosing, transmitting, and/or sharing the Data with Booking.com, and other
third parties which have business or contractual dealings with us.
Where you give us your opt-in
consent to process your personal information: In certain circumstances, where
required under relevant Data Protection Laws, we will seek to obtain your
consent before we undertake certain processing activities with your Data. You
have the right to withdraw your consent to these activities. You can do so at
any time, and details of how to do so can be found in the section below, titled
"Your Rights and Choices".
Where processing your personal
information is necessary for our compliance with a legal obligation: In certain
circumstances, we may disclose your Data for the purposes of compliance with a
legal obligation (for example, to comply with a law, regulation or compulsory
legal request). We do not think that any of the above activities prejudice you
in any way. However, you do have the right to object to us processing your
personal information in certain circumstances. If you would like to know more
about these circumstances and how to object to our processing activities,
please see the section below, titled "Your Rights and Choices".
Some of the above grounds for
processing will overlap and there may be several grounds which justify our use
of your Data.
Further, where required under
relevant Data Protection Laws, we will only process special category personal
data’ (as defined under Data Protection Laws) if there is a valid legal basis,
which might involve obtaining your explicit consent.
Where we use or share your Data
on behalf of another entity (i.e., the controller) as part of our services
offered to that entity, we do so under the instructions of that entity and that
entity is responsible for ensuring that there is a legal basis for us to use or
share your Data on its behalf (if such legal basis is required under relevant
Data Protection Laws).
7. MINORS
Our website and mobile
application do not offer products or services for use by minors. If you are
under 18, you may use our website or mobile application only with the
involvement of a parent or guardian.
8. SHARING OF DATA
We may share your Data in the
following ways (and for the purposes of relevant Data Protection Laws, we may
do so either as a controller in our own right or as a processor on behalf of
and under the instructions of another entity in accordance with our obligations
under our agreement with that entity):
(a) Partners: We may make
available to you services, products, or applications provided by Partners for
use on or through our website or mobile application. If you choose to use such
services, products or applications, Data related to these uses may be shared
with such Partner.Such Partners use your Data for the purposes of providing
their own products or services to you. Their use of your Data is subject to
their own privacy policies. For further information on how these Partners
process your Data, please refer to their privacy policies.
(b) Booking.com: We may share
your Data with Booking.com for them to make their products, services and /or
applications available to you, to assist them in reaching out to you in
relation to their programs or campaigns and to process your queries and
requests. We may also share your Data with the Booking.com as is relevant for
the purposes set out in Clause 6 above, and to facilitate the operation of our
business. Their use of your Data is subject to their own privacy policies. For
further information on how these Booking.com process your Data, please review
their privacy policies
(c) Booking.com Consumer
Platform: Your Data may be shared with Booking.com and other participating
entities on the Booking.com Consumer Platform operated by Booking.com for the
purposes of enrolment, offering you products, services and benefits on the Booking.com.
Accordingly, we may share your Data with other Booking.com, Partners and
Service Providers.
(d) Service Providers: We may
share your Data with Service Providers who may, in the course of providing
their respective services, receive and process Data. Examples include storing
and analysing Data, protecting and securing our systems, providing search
results and links, providing customer service, credit analysis, processing your
Data for profiling, user analysis and payment processing.
These Service Providers will be
required to only process Data in accordance with our instructions. The Service
Providers will also be required to safeguard the security and confidentiality
of the Data they process by implementing appropriate technical and
organizational security measures.
(e) When MPS acts as a Service
Provider: We may process and share your Data with Booking.com and Partners when
we act as a service provider to such Booking.com and Partners. In this case,
for the purposes of relevant Data Protection Laws, we act as a processor of the
Data on behalf of, and under the instructions of, the relevant Booking.com or
Partner (i.e. the controller).
(f) Protecting MPS: We may
release Data when we believe that disclosure is reasonably necessary (a) to
comply with a law, regulation or compulsory legal request; (b) to protect MPS
or a Booking.com intellectual property rights; (c) to protect MPS against harm
or financial loss; (d) when we believe disclosure is necessary to protect
individuals’ vital interests, or (e) in connection with an investigation of
suspected or actual fraudulent or illegal activity. This may include exchanging
information with other companies and organizations for fraud protection, risk
management and dispute resolution.
(g) Business Transfers: As we
continue to develop our business, we might sell or buy subsidiaries or business
units. Your Data (including in relation to loyalty programs) may be transferred
as part of such transactions.
(h) Third Parties: We may also
share your Data with other third parties where:
You request or authorize us to do
so;
We need to comply with applicable
law or respond to valid legal process; or
We need to operate and maintain
the security of our website or mobile application, including to prevent or stop
an attack on our computer systems or networks.
The sharing of your Data will be
in line with the processes set out in this Privacy Notice.
The sharing of your Data will be
in line with the processes set out in this Privacy Notice.
Please note that Booking.com and
Partners may have privacy practices that differ from those of MPS. The use of
your Data will be governed by their privacy statements when you provide Data on
their websites.
9. KEEPING DATA SECURE
We will use technical and
organizational measures to safeguard your Data and we store your Data on secure
servers. Technical and organizational measures include measures to deal with
any suspected data breach. If you suspect any misuse or loss or unauthorized
access to your Data, please let us know immediately by contacting us by e-mail.
10. RETENTION OF DATA
MPS retains Data for as long as
necessary for the use of our products and/or services or to provide access to
and use of our website or mobile application, or for other essential purposes
such as complying with our legal obligations, resolving disputes, enforcing our
agreements and as long as processing and retaining your Data is necessary for
our legitimate interests. Because these needs can vary for different data types
and purposes, actual retention periods can vary significantly.
Even if we delete your Data,
including on account of exercise of your right under Clause 12 below, it may
persist on backup or archival media for audit, legal, tax or regulatory
purposes.
11. WHERE WE STORE DATA
We may transfer your Data to
recipients in India, where we are headquartered, and other countries. These
countries may not have the same data protection laws as the country in which
you initially provided the information. If we transfer your Data to other
countries, we will protect that information as described in this Privacy
Notice, as disclosed to you at the time of data collection or as described in
our program-specific privacy notice.
(a) by way of a data transfer
agreement incorporating the current relevant standard contractual clauses
adopted in the European Economic Area/United Kingdom; or
(b) by transferring your Data to
a country where there has been a finding of adequacy by the European Commission
in respect of that country’s levels of data protection via its legislation; or
(c) where it is necessary for the
conclusion or performance of a contract between us and a third party and the
transfer is in your interests for the purposes of that contract; or
(d) where you have consented to
the data transfer.
12. YOUR RIGHTS AND CHOICES:
Depending on which country’s laws
are applicable to you, you may have various rights in relation to the Data that
we hold about you. To get in touch with us about any of your rights under Data
Protection Laws, please use the contact details set in the section below,
titled “How to Contact Us”. We will seek to deal with your request without
undue delay, and in any event, within any time limits provided for in Data
Protection Laws (subject to any extensions to which we are lawfully entitled).
Please note that we may keep a record of your communications to help us resolve
any issues which you raise. Where we are legally permitted to do so, we may
refuse your request.
You may be entitled to the
following rights in relation to your Data:
a) Right to Confirmation and
Access - you may ask us to confirm what Data we hold about you at any time, and
request us to modify, update or delete such Data. You may also request a copy
of the Data we hold about you.
b) Right to Rectification - you
have the right to request that we rectify any inaccurate or incomplete Data
that we hold about you, including by means of providing a supplementary
statement.
c) Right to be Erasure - you have
the right to request that we "erase" your Data in certain
circumstances.
d) Right to Restrict Our Use of
your Data - you have the right to request that we restrict our processing of
your Data in certain circumstances, for example if you dispute the accuracy of
the Data that we hold about you or you object to our processing of your Data
(including where we process your Data for our legitimate interests, where
permitted under applicable law).
e) Right to Object – this right
enables you to object to us processing your Data where we do so for certain
reasons.
f) Right to Data Portability -
you have the right to request that we transfer your Data to another third
party. This right of data portability only applies to certain types of Data.
g) Right to Withdraw Consent –
where we have obtained your consent to process your Data for certain
activities, you may withdraw this consent at any time and we will cease to
carry out that particular activity that you previously consented to unless we consider
that there is an alternative legal basis to justify our continued processing of
your Data for this purpose.
h) Right to File Complaints – you
have the right to lodge a complaint with the relevant supervisory authority in
your jurisdiction.
To get in touch with us about
these rights, or for more information about managing your Data and promotional
communications, please use the contact details set out in the section below,
titled “How to Contact Us”.
It is important that the Data we
hold about you is accurate and current. Please keep us informed if your
personal information changes during the period for which we hold it.
13. PROCESSING YOUR DATA
We take steps to ensure that your
Data is processed according to the provisions of this Privacy Notice and the
requirements of applicable law.
To ensure that your Data receives
an adequate level of protection, we have put in place appropriate written
contracts with Booking.com, Partners and Service Providers that we share your
Data with.
14. SEVERABILITY
If any court or competent
authority finds that any provision of this Privacy Notice (or part of any
provision) is invalid, illegal or unenforceable, that provision or
part-provision will, to the extent required, be deemed to be deleted, and the
validity and enforceability of the other provisions of this Privacy Notice will
not be affected.
15. COOKIES, PIXELS AND
SIMILAR TECHNOLOGIES
Our website and mobile
application may place and access certain Cookies on your device. Cookies are
unique identifiers that we transfer to your device to enable our systems to
recognize your device. We also use pixels and similar technologies to analyze traffic
on our website and mobile application to improve your experience of using them.
When you first visit our website
and mobile application, you will be presented with a pop-up screen informing
you of our use of Cookies and asking you to provide your consent for such use.
The pop-up screen may not reappear for all your subsequent visits to our
website and mobile application, but you may adjust your web browser software if
you do not wish to receive Cookies or web beacons, but this may prevent you
from taking advantage of some of the features of our website and mobile
application. Please refer to your browser instructions or help pages to learn
more about these functions
16. CHANGES TO THIS PRIVACY
NOTICE
Our business changes constantly
and our Privacy Notice will change also. We may e-mail periodic reminders of
our notices and conditions, unless you have instructed us not to, but you
should check our website and mobile application frequently to see recent
changes. The updated version will be effective as soon as it is accessible. We
encourage you to review this Privacy Notice frequently to be informed of how we
are protecting your information.
17. HOW TO CONTACT US
To request to review, update, or
delete your personal information or to otherwise reach us, please submit a
request by e-mailing us at dpo@tajhotels.com. You may contact us for
information on Service Providers, Partners and Booking.com with whom we may
share your Data in compliance with this Privacy Notice and applicable law. We
will respond to your request within 30 days.
GRIEVANCE OFFICER
Please see below the details of
our grievance officer:
Email: booking@mpssaipalace.com
Address: No:44/a, Mariyamman
kovil street, Tiruvannamalai 606601