Introduction
We use your personal information in order to fulfil our commitment to providing an unparalleled guest service experience in connection with all of your interactions with Wanderlust Lifespaces (hereafter referred to as "Wanderlust"). As part of that Purpose, we are committed to safeguarding the privacy of the personal information that we gather.
As one of our guests or someone else with whom we do business, you understand and agree that we collect, use and disclose your personal information in accordance with this Privacy Policy (this “Policy”).
The Application of this Policy
This Policy applies to all personal information, as defined below, regarding guests and the other individuals with whom we do business or who visit us and to the use of that personal information in any form – whether oral, electronic or written.
This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various Wanderlust properties around India. References to “Wanderlust”, “we” and “our” throughout this Policy, depending upon the context, collectively refer to those separate and distinct legal entities.
While this Policy is intended to describe the broadest range of our personal information processing activities throughout the country, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular state may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of the applicable law.
Types of personal Information Wanderlust collects
The term “personal information” in this Policy refers to information that does or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) may or may not include:
- your name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information;
- guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services utilised, special requests made, observations about your service preferences (including room and vacation preferences), telephone numbers dialed and faxes, texts and telephone messages received;
- your credit card details, and your account details and credentials for frequent guest programs, including any frequent flyer or travel partner program;
- any information necessary to fulfil special requests (e.g., health conditions that require specific accommodation or services);
- information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites or apps and those of third parties;
- information collected whilst at a Wanderlust property through the use of closed circuit television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device, or your location), card key and other security and technology systems;
- information collected whilst at a Wanderlust property regarding the use or misuse of any Wanderlust property, including but not limited to information regarding damages related to the occupancy or use of a Wanderlust property;
- information collected on any internet-access systems, internet-enable devices, or other smart devices, including but not limited to those provided by Wanderlust for use a Wanderlust property, which may include but is not limited to browsing history, cookie use and history, preferences, and log-in information;
- information collected whilst you access a Wanderlust website or Wanderlust app (we describe this in more detail in the “Apps” section below);
- contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners); and
- in limited cases, information relating to the credit of customers.
Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in other instances, we process personal information that we are able to infer about you based on other information you provide to us or during our interactions with you, or personal information about you that we receive from a third party. This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some very rare instances, financial records may form part of Sensitive Personal Information where you are located. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to Wanderlust that is considered to be Sensitive Personal Information or financial information. Except to the extent required by law, you are not obliged to provide Wanderlust with any of your Sensitive Personal Information, and should you chose not to, this will not prevent you from purchasing any products or services from Wanderlust.
How we use Personal Information
Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:
- provide and charge for accommodation and other goods and services;
- provide you with a better or more personalised level of service, including information and services from a third party (such as additional guest services at Wanderlust properties, local attractions and transportation options);
- respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
- administer a frequent guest program;
- fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organisers or your employer) and vendors (e.g., credit card companies, airline operators and third party loyalty programs);
- conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;
- provide for the safety and security of staff, guests and other visitors;
- administer general record keeping;
- meet legal and regulatory requirements; and
- test and evaluate new products and services.
Wanderlust uses and retains your personal information for as long as is necessary to fulfil the Purpose or such longer period as may be required by applicable law.
Disclosure of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries.
WHEN YOU AGREE TO THIS POLICY, YOU ARE, TO THE EXTENT REQUIRED AND PERMITTED UNDER YOUR LOCAL LAW, GRANTING YOUR CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION TO SUCH OTHER COUNTRIES FOR THE PURPOSE AND TO THE EXTENT STATED IN THIS SECTION AND AS DESCRIBED IN THE “HOW WE USE PERSONAL INFORMATION” SECTION ABOVE.
Circumstances where we might make such disclosure (in addition to those described in “How We Use Your Personal Information” above) include:
- Our Agents, Service Providers and Suppliers: Like many other international accommodation providers, we may outsource the processing of certain functions and/or information to third parties. We may also engage market research firms to assist us in contacting guests for the purpose of market research and quality assurance. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.
- Third party vendors, including Google, use cookies to serve ads based on a User's prior visits to our Website. You can disable these specific cookies that track prior visits for the sake of follow-up advertising by opting out at http://www.google.com/privacy_ads.html. You can learn more about cookies by visiting our Cookie Statement at [https://www.wanderlustlifespaces.com/cookie_policy].
- Consumer Insights: To the extent we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under the “Contacting Us/ Questions or Requests for Access to Personal Information” section below.
- Legal Requirements; Compliance with Laws and Law Enforcement: Wanderlust cooperates with government, law enforcement officials, and private parties to enforce and comply with the law. We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity. We may also disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to comply with the law, to protect the property and rights of Wanderlust or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
- Testimonials: With your consent, we may post your testimonial on Wanderlust website along with your name. If you want your testimonial removed, please contact us at [email protected].
- Aggregate Information and Non-Identifying Information: We may share aggregated information that does not include personal information and we may otherwise disclose non-identifying information and log data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personal information.
Information we may collect when you visit us online
If you access any Wanderlust website, you may wish to know the following:
- You can browse without revealing who you are: You can always visit our websites without logging in or otherwise revealing who you are.
- Usage Information: When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website.
- Cookies and Other Similar Technology: We use cookie technology on our websites to allow us to evaluate and improve the functionality of our websites. Cookies by themselves cannot be used to reveal your identity. They identify your browser, but not you, to our servers when you visit our websites. For information about how Wanderlust uses cookies, visit [https://www.wanderlustlifespaces.com/cookie_policy]. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our websites, including the customisation features associated with creating a user profile. Further information about cookies and other similar technology and how they work is available at www.allaboutcookies.org.
- Social Media: Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
- Links to Other Websites: From time to time, Wanderlust may partner with third parties to offer services to and with our guests; Wanderlust may also partner with third parties for non-guest-related services to expand the range of services we can offer our guests. If you visit a Wanderlust website and decide, for example, to purchase a gift certificate, make an airline reservation, rent a car, submit award request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website.
- To enhance your experience, Oasis may provide a tablet, smart device, or other internet-enabled device for use while at an Oasis property. Oasis may not limit the content that accessible via these devices, and the website content you consume wh