Data Privacy & Policy

Purpose of this document

Bona Sera Hotels Ltd. (The Waterfront Shaw, Lavasa) is 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 the EU General Data Protection Regulation (GDPR).

It applies to all guests and visitors.

Bona Sera Hotels Ltd. (The Waterfront Shaw, Lavasa) is responsible for deciding how we hold and use personal information about you.

We are required under data protection legislation to notify you of the information contained in this privacy statement.

This statement applies to all guests and visitors. This statement does not form part of any contract to provide services. We may update this statement at any time.

It is important that you read this statement, together with any other privacy statement we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

Date of birth.

Gender.

Marital status.

Next of kin and emergency contact information.

National Insurance or TAX ID number/PAN card.

Bank account details, payroll records and tax status information.

Driving licence.

Grievance information.

CCTV footage and other information obtained through electronic means such as door access records.

Information about your use of our information and communications systems.

Photographs.

We may also collect, store and use the following “special categories” of more sensitive personal information:

Information about your race or ethnicity, religious beliefs, sexual orientation.

Information about your health, including but not limited to any medical conditions, food allergies.

How is your personal information collected?

We collect personal information about data subjects through various methods; check-ins, bookings, and reservations. Either directly from data subjects or sometimes from a third party acting on our behalf (for example through a booking agency, online travel agent, travel agent or corporate account).

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal 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. 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.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest or for official purposes or requested for by the CBI, police or governmental authorities.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties

Administering the contract, we have entered into with you.

Business management and planning, including accounting and auditing.

Making decisions about grievances.

Making arrangements for the termination of a contract.

Dealing with legal disputes and insurance claims.

Complying with health and safety obligations.

To prevent fraud.

To monitor your use of our information and communication systems to ensure compliance with our Global IT policy and laws of the land.

To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

To conduct data analytics studies to review and better understand customer satisfaction and needs.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

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 to ensure the health and safety or proof of nationality for example passport)  

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 and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations
  3. Where it is needed in the public interest, such as for requested for by CBI, police or governmental authorities

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Principles of GDPR

We will use your personal data only in-line with the following principles:

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

This is the only principle that deals explicitly with security. The GDPR states that personal data must be “processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures”.

The GDPR is deliberately vague about what measures organisations should take, because technological and organisational best practices are constantly changing. Currently, organisations should encrypt and/or pseudonymise personal data wherever possible, but they should also consider whatever other options are suitable.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in Bona Sera Hotels Ltd. (The Waterfront Shaw, Lavasa).

We require appointed third parties to respect the security of your data and to treat it in accordance with the law.

If we do, you can expect the same degree of protection in respect of your personal information. Data will only be transferred within the Bona Sera Hotels Ltd. (The Waterfront Shaw, Lavasa).

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, or where we have another legitimate interest in doing so, or when we have your explicit consent.  

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We may share your personal information with other entities in the Bona Sera Hotels Ltd. (The Waterfront Shaw, Lavasa) as part of our regular reporting activities on company performance, in the context of system maintenance, support and hosting of data.  

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially, legally and securely.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal 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. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact info@waterfrontshaw.com in writing.

No fee is usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact info@waterfrontshaw.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this privacy statement

We reserve the right to update this privacy statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Log file data

When visiting our website and with each retrieval of a file, the data that your browser sends us is automatically saved in a log file. These are:

– Browser type
– Operating system used
– URL referrer
– Host name of the accessing computer (IP address)
– Date and time of retrieval

These are not personal data apart from the IP address. IP addresses allow an addressing of devices on the Internet. Each computer has a distinct IP address in the form of a specific sequence of numbers.

All of this data is exclusively used for our website statistics. We do not link this data to any other data.

 

Cookies<

Cookies are small text files that are filed on your computer and stored by your browser. Cookies cause no damage to your computer and contain no viruses. The cookies that we use are so-called “session cookies”. They are automatically deleted at the end of your visit.

If you refuse the use of cookies, we ask you to change the corresponding settings of your browser. However, your refusal may result in you no longer being able to use our services.

 

Google Analytics web analysis service

This website uses Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files that are saved on your computer and enable analysis of your use of the website. The information created by the cookie concerning your use of this website (including your IP address) is transmitted to a Google server in the USA and stored there. Google will use this information to evaluate your use of the website, to produce reports concerning your activities on the website and to produce additional services associated with the use of the Internet and website. Google may also transfer this information to third parties if this is legally mandatory or if third parties process this data on behalf of Google. Under no circumstances will Google use your IP address in connection with other Google data. You can prevent cookies from being installed with an appropriate setting in your browser software. By using this website, you give your consent to the processing of the data acquired by Google about you in the way described above and for the above-stated purpose.

Our website uses the Google Analytics anonymisation function. IP addresses are thus saved and further processed only in abbreviated form to prevent them being directly linked to a particular individual.

You can temporarily or permanently prevent Google Analytics from storing cookies on your computer; to do so you can download a deactivation add-on for your browser.

 

Facebook

Our website contains programmes (plug-ins) from the social network Facebook. These are exclusively managed by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (Facebook). The plug-ins can be identified on our website by the Facebook logo. When visiting a website that contains this type of plug-in, your browser creates a direct link with the Facebook servers, whereby the content of the plug-in is transferred directly on your browser and from there it is integrated into the displayed website. The information that you visited our website is hereby forwarded to Facebook. Provided that you are logged in to your user account at Facebook when visiting our website, Facebook can assign the website visit to your account. Interaction with plug-ins enables the transfer of the corresponding information directly to Facebook, where it is stored. If you want to prevent this data transfer you must log out of your Facebook account before visiting our website. For information on the purpose and extent of data capture and the further processing and use of data by Facebook, as well your rights in this regard and the setting options for the protection of your personal privacy, please refer to the Facebook data protection information: (http://www.facebook.com/policy.php).

 

Twitter

Twitter and the retweet functions are services of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107 (“Twitter”). This website uses the Twitter button. The button is marked with the “Twitter” logo.

When a page on our website is accessed, the browser creates a direct link with the Twitter servers. The button is transferred directly from Twitter to the browser, which then integrates it into the website.

Via this integrated button, Twitter receives the information that the corresponding website page was accessed. If the visitor of the relevant page is logged into their Twitter account at the time of the visit, then Twitter can allocate the visit to the Twitter account of the user. If the button is clicked, then the browser sends the corresponding information directly to Twitter, where it is stored.

For information on the purpose and extent of data capture and the further processing and use of data by Twitter, as well as the rights of the user in this regard and the setting options for the protection of personal privacy, please refer to the Twitter data protection information: http://twitter.com/privacy.

If the user does not want Twitter to be able to collect data about them via the visited website page, then the visitor must log out of Twitter before visiting this website page.

 

Linkedin

Our website contains programmes (plug-ins) from social network Linkedin. These are exclusively managed by Linkedin, Sunnyvale, California, U.S. The plug-ins can be identified on our website by the Linkedin logo. When visiting a website that contains this type of plug-in, your browser creates a direct link with the Linkedin servers, whereby the content of the plug-in is transferred directly on your browser and from there it is integrated into the displayed website.

 

Via this integrated button, Linkedin receives the information that the corresponding website page was accessed. If the visitor of the relevant page is logged into their Linkedin account at the time of the visit, then Linkedin can allocate the visit to the Linkedin account of the user. If the button is clicked, then the browser sends the corresponding information directly to Linkedin, where it is stored.

For information on the purpose and extent of data capture and the further processing and use of data by Linkedin, as well as the rights of the user in this regard and the setting options for the protection of personal privacy, please refer to the Linkedin data protection information: https://www.linkedin.com/legal/privacy-policy?src=li-other&veh=www.linkedin.com%7Cli-other

If the user does not want Linkedin to be able to collect data about them via the visited website page, then the visitor must log out of Linkedin before visiting this website page.

 

YouTube

Our website contains programmes (plug-ins) from YouTube a service from Google Inc. (“Google”). The plug-ins can be identified on our website by the YouTube logo. When visiting a website that contains this type of plug-in, your browser creates a direct link with the YouTube servers, whereby the content of the plug-in is transferred directly on your browser and from there it is integrated into the displayed website.

 

Via this integrated button, YouTube receives the information that the corresponding website page was accessed. If the visitor of the relevant page is logged into their YouTube account at the time of the visit, then YouTube can allocate the visit to the YouTube account of the user. If the button is clicked, then the browser sends the corresponding information directly to YouTube, where it is stored.

For information on the purpose and extent of data capture and the further processing and use of data by YouTube, as well as the rights of the user in this regard and the setting options for the protection of personal privacy, please refer to the YouTube data protection information: https://policies.google.com/privacy?hl=en-GB&gl=uk

If the user does not want YouTube to be able to collect data about them via the visited website page, then the visitor must log out of YouTube before visiting this website page.

 

Google+

Our website contains programmes (plug-ins) from Google+ a service from Google Inc. (“Google”). The plug-ins can be identified on our website by the Google+ logo. When visiting a website that contains this type of plug-in, your browser creates a direct link with the Google+ servers, whereby the content of the plug-in is transferred directly on your browser and from there it is integrated into the displayed website.

 

Via this integrated button, Google+ receives the information that the corresponding website page was accessed. If the visitor of the relevant page is logged into their Google+ account at the time of the visit, then Google+ can allocate the visit to the Google+ account of the user. If the button is clicked, then the browser sends the corresponding information directly to Google+, where it is stored.

For information on the purpose and extent of data capture and the further processing and use of data by Google+, as well as the rights of the user in this regard and the setting options for the protection of personal privacy, please refer to the Google+ data protection information: https://policies.google.com/privacy?hl=en-GB&gl=uk

If the user does not want Google+ to be able to collect data about them via the visited website page, then the visitor must log out of Google+ before visiting this website page.

 

Liability for links

This website contains links to external websites (third parties), who are our partners. We have no influence on their contents. Therefore we can assume no liability for this external content. The content of linked sites remains the responsibility of the provider or operator concerned. The linked sites were checked at the time of linking for any possible legal infringements. Illegal content was not identified at the time of the linking. Permanent control of the content of linked sites, however, is not reasonable without specific indications of an infringement of rights. As soon as we become aware of an infringement of rights we will immediately remove such links.

 

This is the Data Privacy Policy of the company Bona Sera Hotels Ltd. having its registered office at 640/B Khorshed Villa, Khareghat Road, Dadar Parsi Colony, Dadar East, Mumbai – 400014, Maharashtra, India.