privacy Policy

1. INTRODUCTION

SUJÁN Luxury Hospitality Private Limited is a company incorporated under the laws of India, having its registered office at 1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110 016 along with its subsidiaries i.e. (a) Desert Friendly Camps Private Limited having its registered office at 1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110 016 and (b) Forest Friendly Camps Private Limited having its registered office at 1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110 016, hereinafter referred to as “We” or “Us” or “Company” or “SUJÁN”.

We own, operate and manage a chain of luxurious camps and palaces in India under the ‘SUJÁN’ brand. “Properties” that SUJÁN operates in India are SUJÁN Sherbagh, SUJÁN JAWAI, SUJÁN The Serai and SUJÁN Rajmahal Palace. We understand the need to respect the privacy of the esteemed guests who communicate with us and/or visit our hotel properties.

Our privacy policy has been created in accordance with all applicable laws [hereinafter referred to as “Privacy Policy” or “Policy” or “Privacy Statement”].

We hereby request our esteemed guests and visitors to read this Privacy Policy, together with any privacy statement we may provide on specific occasions when we are collecting or processing Information about them, so that they are aware about the usage of the Information.

2. GOVERNING LAW

We are an organisation based and existing in India and are thus bound by the laws of the Republic of India. This Privacy Policy has been prepared in accordance with applicable Indian laws, including the Indian Information Technology Act, 2000.

3. APPLICABILITY

This Policy applies to all Guests, Visitors, and other individuals who provide their personal information to SUJÁN. All such Guests, Visitors and other individuals are hereinafter referred to as “You”.

4. OBJECTIVE

This Privacy Policy, as mentioned above, is intended to inform you on how we gather, define, and use Personal Data or Information that you provide to SUJÁN when communicating with us, including when relying on our hospitality services during a stay at any of our properties.

This Privacy Policy also covers our treatment of any Personal Information or Information that third parties share with SUJÁN.

This Privacy Policy will primarily help you understand:

  1. The nature of information we collect about you directly or through third parties.
  2. The sources from where your  information is collected
  3. The manner in which your  information is collected
  4. The purpose of collecting your information
  5. The manner in which your  information is stored, used and processed by SUJÁN
  6. The rights you  have  under applicable laws regarding such information collected by SUJÁN
  7. The process to contact SUJÁN for any issues regarding the collection or use of your  information

5. CATEGORY OF INFORMATION COLLECTED AND USED

Your Information collected by ‘SUJÁN’ primarily consists of: Personal Information and sensitive Personal Information [Collectively referred to as “Information” or “Your Information”].

(A) Personal Information
Personal Information means any information about you from which you can be identified. It does not include data where the identity has been removed [anonymous data].

If someone submits any Personal Information relating to other people other than yourself to SUJÁN or to SUJÁN‘s service providers in connection with the Services [e.g., if you make a reservation for another individual], you represent and warrant that you have the authority to do so and to permit SUJÁN to use the information in accordance with this Privacy Policy.

When you enter into a transaction or communicate with SUJÁN, we may collect Personal Information from you such as:

  1. Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  2. Gender
  3. Next of kin and emergency contact information
  4. Bank account details, credit card or debit card details
  5. CCTV footage.
  6. Information about your use of our information and communications systems.
  7. Your  Photographs
  8. Your travel arrangements and purchase history
  9. Your  passport number and nationality
  10. Dietary preferences, allergy and information about how you  use our services and information about how you  access our websites
  11. Behavioural or demographic attributes, when tied to personal identifiers
  12. Social media account ID or user ID, profile photo and other data you  make available publicly or to SUJÁN  from your social media accounts, publically available platforms or other sources


  13. (B) Sensitive Personal Information
    Certain categories of personal information, such as financial record, health or biometric information are considered to be sensitive personal information.

    You may choose to share his or her sensitive personal information with SUJÁN directly [or through authorised persons, travel agents] in certain circumstances.

     SUJÁN collects and processes sensitive personal information only when it is essential. An example of where we may collect and process sensitive Personal Information includes the following:


    1. Where you have requested specific medical assistance from SUJÁN, such as the provision of a wheelchair, medical assistance; or
    2. Where such information has been passed onto SUJÁN by a third party, where you have given that third party consent to do so, such as the travel agent through which you  made a booking or from other hotels for your  onward journey, where the processing of such sensitive Personal Information is required for the processing of your  service request; or
    3. Where such information is required under applicable laws.  

    By providing your sensitive Personal Information, you agree that we may collect, use and share this information with third parties for the purpose of processing your service request[s].

    6. HOW WE COLLECT YOUR INFORMATION

    We collect Information about you through the following means:



    1. Whenever you use our services [whether services provided directly by SUJÁN or by other companies or agents acting on our behalf - for example through a booking agency, travel agent or corporate account];
    2. When you stay with SUJÁN or checks-in;
    3. When you  use our website or makes reservations or bookings through our website or do an online chat with our reservation agent;
    4. When you interact with SUJÁN via email or social media platforms such as Facebook, LinkedIn, Instagram or Twitter;
    5. When you book through third parties [such as travel agents etc.]. to use our services.

    7. WHY WE COLLECT YOUR INFORMATION

    We use your Information to conduct our business and to provide you with the best possible services and hospitality experience. We will only use your Information based on this Privacy Policy, our contract with you, and when the law allows SUJÁN to.

    SUJÁN will collect adequate, relevant and necessary Information of  yours, and will process such information fairly and lawfully for the purpose it is collected. Most commonly, SUJÁN will use your Information in the following circumstances:

    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. To enable you  use of the services available at our hotels;
    4. To send statements, invoices and payment reminders to you, and to collect payments from you;
    5. To send non-marketing commercial communications to you;
    6. To send you email notifications that you has specifically requested for;
    7. To send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you. However, you can inform SUJÁN at any time if you no longer requires such marketing communications;
    8. To provide third parties with statistical information about our users but those third parties will not be able to identify any individual user from that information;
    9. To deal with enquiries and complaints made by or about you relating to services provided;
    10. To improve and customise our services in accordance with your preferences;

    Where you have given SUJÁN explicit consent to do so.

    We may also use your Information in the following situations, which may arise occasionally:

    1. Where we need to protect your interests,
    2. Where it is needed in the public interest or for official purposes or to fulfil a legal obligation. For instance, requests made by law enforcement agencies, courts or tribunals.

    8. FAILURE TO PROVIDE 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, or we may be prevented from complying with our legal obligations.

    You hereby accept and agree that we shall not be held liable in any manner whatsoever if we are unable to perform our services or if there is a deficiency in our services to you due to your failure to provide such information.

    You  agree that he/she shall not file or initiate any complaints, legal proceedings or claims against SUJÁN and/or our employees, directors, associates, etc. in this regard.

    You further agree to indemnify and hold SUJÁN and/or our employees, directors, associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against SUJÁN in this regard.

    9. CHANGE OF PURPOSE

    We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

    If we need to use your Information for any additional purposes, we will notify you and we will explain the legal basis which allows SUJÁN to do so.

    10. CONSENT

    You agree that we do not need any additional or further consent from you to use your Information in accordance with this policy to carry out our legal obligations or exercise specific rights.

    11. INFORMATION SHARING AND DISCLOSURE

    We may disclose your Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors;  or to any member of our company, including our subsidiaries and partners insofar as reasonably necessary for the purposes set out in this policy and for the purpose of providing services to you.

    In addition to this, we may disclose your Information:

    1. to the extent that we are required to do so by law;
    2. in connection with any ongoing or prospective legal proceedings;
    3. in order to establish, exercise or defend our legal rights including providing information to others for the purposes of fraud prevention and reducing credit risk;
    4. to the purchaser or prospective purchaser of any business or asset that we are or are contemplating selling; and

    to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that information.

    SUJÁN ensures that our third party service providers employ industry standard security measures to ensure the security of information through legally binding terms and conditions. Except as provided in this policy, we will not provide you Information to any other third party.

    Use of cookies
    We, and our partners, use various technologies to collect and store information when you visit www.sujanluxury.com, and this may include using cookies or similar technologies to identify your browser or device. Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, e-mail address when you are logged-in to your e-mail from the browser you are using, time spent on the online services, pages visited, referring URL, language preferences, and other aggregated traffic data. We, and our service providers, use the information for sending e-mailers to our website visitors whose online behaviours indicate that they may be interested in travelling, to facilitate navigation, to display information more effectively, to collect statistical information, to personalise your experience while using the Online Services and to recognise your computer in order to assist your use of the Online Services, such as for the online reservation process. . You can configure your browser to refuse cookies, or to warn you before a cookie is placed.

    12. TRANSFER OF INFORMATION OUTSIDE INDIA

    Unless stated otherwise, we store and process your Information in India. There may, however, be occasions when we need to transfer your Information outside India in order to enable SUJÁN to use the information in accordance with this policy.

    Such transfer of information may be to a country which does or does not provide the same level of data protection as in India. In these circumstances we will take appropriate steps to ensure that your Information is adequately protected.

    Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as SUJÁN, so that your Information is adequately protected.

    You expressly agree to the transfer of his/her information described in this Section.

    13. DATA SECURITY

    We are committed to protecting your Information and thus implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.

    Appropriate physical, electronic, and managerial procedures have been put in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information collected from you.

    We strive to keep your personal information protected and take reasonable effort to safeguard that proper security and technical controls are applied to ensure data security.

    14. DATA RETENTION

    We will only retain you Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    In some circumstances we may anonymise your Information so that it can no longer be associated with you, in which case we may use such information without a further statement to you.

    15. REMOVAL OF INFORMATION

    You may at any time ask SUJÁN to delete your Information.  We will consider and where necessary comply with your request in accordance with applicable law, as explained above. Please note that after deleting the information, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.

    We may, however, need to retain certain Information of yours for recordkeeping purposes and/or to complete any transactions that you began prior to requesting removal of the information. For instance, when you make a purchase or reservation, or participate in a promotion, he/she may not be able to change or delete the Personal Information provided to SUJÁN until after the completion of such purchase, reservation, or promotion.

    There may also be residual information that will remain within our databases and other records, which will not be removed. In addition to this, there may be certain Information of yours which we may be unable to delete due to legal reasons.

    16. WITHDRAWAL OF CONSENT

    You may at any time revoke or withdraw your consent to provide your  Information to SUJÁN by using the applicable contact details set out at the end of this policy. In case of withdrawal of consent, SUJÁN may not be able to provide the same level of servicing to you as SUJÁN will not be aware of your preferences.  

    17. REVIEW OF INFORMATION

    You can contact SUJÁN at any time requesting access to your Information for reviewing or requesting amendment to certain information that you consider to be incorrect or wrong. SUJÁN shall process such requests from you in accordance with applicable law.

    18. CHANGES TO THIS PRIVACY POLICY

    1. The policy is subject to modification from time to time. If we decide to change our policy, we will post those changes here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone.
    We may also notify you in other ways from time to time about the processing of your Information.

    19. GRIEVANCE OFFICER

    In accordance with the Indian Information Technology Act 2000 and the rules notified thereunder, the contact details of the Grievance Officer are provided below:



    Ms. Devika Manocha
    1, Sri Aurobindo Marg, Hauz Khas, New Delhi – 110016
    privacy@sujanluxury.com
    (+91) (11) 4617 2700

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