Lemon Tree Hotels Limited (LTHL) herein referred to as “LTH” (collectively referred to as the "Company" or "LTH" or "Us" and also indicated by "us", "we" or "our") and our affiliated companies, are committed to respecting your privacy and recognise your need for appropriate protection and management of any personally identifiable information ("Personal Information") You share with us based on applicable data protection laws and regulations.

This Privacy Policy ("Policy") applies to all visitors, users and others (hereinafter referred to as "You" or the "User") who access or use the (i) Website – Lemon Tree Hotels - Privacy and Cookies Policy(www.lemontreehotels.com/privacypolicy.aspx) (ii) (ii) the social media accounts(viz. Facebook, Instagram, LinkedIn etc.) , and/or communication channels that LTH control (Sites/Social Media/RCS/SMS/WhatsApp) (iii)any person (‘User’) who visits and/or approaches the Lemon Tree Hotels through any of Our customer interface channels including its website [www.lemontreehotels.com] SMS, RCS, WhatsApp, online & offline channels including messaging centres, call centres and its hotels/offices (collectively referred herein as "Sales Channels") or inquire about any product(s) or service(s) from Lemon Tree Hotels through any of the aforementioned mode (iv) any person (‘User’) to whom Lemon Tree Hotels reaches out by way of SMS, RCS, WhatsApp to disseminate information about any product(s) or service(s).

Except as otherwise provided in this Policy, in general, You can visit/use our Sites/Social Media without identifying who You are. LTH will provide You with the option to deal with LTH without identifying yourself where it is lawful and practical. However, particular sections on our Sites/Social Media may require You to provide personal information in order that we may provide the products/services or information You have requested while visiting/using our Sites/Social Media.

This Privacy Policy is intended to inform You about what personal information we collect, why we collect (purpose) and what we do with it (use), processing/sharing and transfer of personal information and your rights relating to such personal information shared with us.

Personal Information means any information that identifies you as an individual (‘data subject’ here in referred as you/your’) and any other information we associate with it. In particular using a common identifier this includes but is not limited to: first and last name, email address, mailing and residential address, telephone number, title, birth date, gender, occupation, your profession and other information needed to provide a service you have requested.

Sensitive personal data or information means personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person,

WHAT PERSONAL INFORMATION WE COLLECT?

A. Personal Data Information you give us

We may collect Personal Information shared by you on our Sites/Social Media/RCS/SMS/WhatsApp. Depending upon the site(s) and context, this information may include the following:

• Contact Information:Name, phone number, address, city, state, postal/zip code, email address
• Demographic information:Date of birth, gender, occupation, country of origin, educational details, and employer details.
• Account Information:If you create user account on our website, then we may collect username/name, password, email, mobile number, and answers to your security question.

If you provide us with Personal Information concerning your relatives, friends or other third parties, by doing so you confirm and guarantee that you have received an appropriate consent from such third parties for the disclosure of such Personal Information to us for use for the purposes set out in this Privacy Policy.

B. Information collected automatically

Log information

Depending upon the Sites/Social Media/RCS/SMS/WhatsApp or context, we automatically collect and store certain information that your browser sends whenever You visit our Sites/Social Media in server logs ("Log Data") or actively use our RCS/SMS/WhatsApp. This includes:

• details of how You used our Sites/Social Media/RCS/SMS/WhatsApp;
• Internet Protocol address;
• device event information such as caches, system activity, hardware settings, browser type, browser language, the date and time of your visit, time spent on those pages and other statistics and referral URL; and
• cookies, web beacons and other similar technologies that may uniquely identify your browser or your Account. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some portions of our Sites/Social Media/WhatsApp/RCS.

Information collected through cookies

Cookies are small text files that a website/Social Media/WhatsApp/RCS downloads onto your computer or other internetenabled devices (such as mobile phones and tablets) when you visit a website/chat on WhatsApp. The cookie will help the website/Social Media/WhatsApp/RCS recognise your device the next time you visit.

We may use both session cookies (disappear after You close your website/Social Media browser/exit WhatsApp/RCS chat) and persistent cookies (remain after You close your website/Social Media browser/exit WhatsApp/RCS chat and may be accessed every time You use or connect with us on these channels). We may collect information like user’s IP address, geographical location, browser/device type and version, operating system, referral source, device, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of user website use through "cookies".
You can block cookies by activating the setting on your browser/WhatsApp/RCS setting that allow You to refuse the setting of all or some cookies. However, if You use your browser/WhatsApp/RCS settings to block all cookies (including essential cookies), You may not be able to access all or parts of our site/details, or they may not function properly.
For more information about our use of cookies please refer to our Cookie Policy.

Social Media Widgets

Our sites and applications may include social media features connected with social media platform such as Facebook, Twitter, Instagram, Snapchat, Google Plus, Pinterest, YouTube and others. These features may collect information about your IP address and which page you are visiting or features you are using, and may set a cookie or employ other tracking technologies. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with those features are governed by the privacy policies of the companies that provide them

Tracking code in website analytics, a tracking code is a snippet of script that tracks the activity of a website user by collecting data and sending it to the analytics module. The code is generated automatically, is different for each website, and can be installed on each page that needs tracking.

Careers

Our site may include a link to our Career Section. Any Personal Information submitted through that portion of the sites, by upload or via e-mail, will be governed as per this privacy policy

HOW WE COLLECT THE INFORMATION?

LTH will generally collect your personal information directly from You. This may be achieved through your interactions with LTH including those via our Sites/Social Media/RCS/SMS/WhatsApp, other social media applications or internet sites, telephone, email or writing to us.

LTH may also collect your personal information from a third-party source, such as our vendors, business partners, government authorities and judicial authorities.

WHY WE COLLECT THESE INFORMATION?

Unless otherwise provided in the Policy, we may use your personal information collected from the Sites/Social Media/RCS/SMS/WhatsApp in various ways including:

• To facilitate or fulfil the information, products or services you have requested.
• To contact the User for confirming your registration on our website.
• To communicate with the User to respond to his/her queries or seeking feedback or resolving disputes on the product and services.
• For business, marketing and promotional purposes such as sending information about special promotions, programs, schemes, offers, new features, plans on products/services and marketing communications that we believe may be of interest to you.
• For the legitimate business interest, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. To consider an application for career with LTH.
• To consider an application from prospective Vendors for partnering with LTH.
• To educate You about us, our products and services or to understand your interest to improvise the content and performance of our Sites/ WhatsApp/RCS/SMS.
• For maintenance of high quality and standards of products and services.
• To send You important information regarding the Sites/ WhatsApp/RCS/SMS, changes in terms and conditions, user agreements, and policies and/or other administrative information
• For internal business operations including:
  1. Reviews and data analysis for the website (e.g., to determine the number, category of visitors to specific pages within the website).
  2. To manage, operate, maintain and secure our Sites/WhatsApp/RCS/SMS, network system, and other assets and to customise/personalise your experience with us, which may include displaying content based upon your preferences.
  3. For the purposes of analysing the use of the Sites/Social Media/RCS/SMS/WhatsApp, enabling and monitoring your use of our Sites/Social Media/RCS/SMS/WhatsApp, operating our Sites/Social Media/RCS/SMS/WhatsApp, ensuring the security of our Sites/Apps, for maintaining back-ups of our databases.
  4. To help diagnose problems with our server, and to administer our Sites/Social Media/RCS/SMS/WhatsApp.
• To comply with our legal obligations or as otherwise permitted by law.
• To investigate potential breaches, or to protect the rights, property or safety of LTH, the Users of our Sites/Social Media/RCS/SMS/WhatsApp or others.
• For any other purpose necessary or incidental to our business.
• For any other purpose for which you give your consent.

In the event we use your Personal Information for other purposes, not specified above, we will inform you about the specific purposes for processing of your personal information and, when required, our basis for doing so at the time we collect the Personal Information from you to the extent required by law. For the purposes of clarity, we may also use your personal information in combination with information we obtain from third parties about you for the same purposes described above.

In the event that You provide any personal information on any of the Sites/Social Media/RCS/SMS/WhatsApp, You consent to the transfer of such information across country borders, and to the use, processing, and disclosure of such information in global locations, including those that may have different levels of privacy protection than in your own country

THIRD PARTY LINKS:

Our Sites/Social Media/RCS/SMS/WhatsApp may have links to the websites/Apps of other third parties and these third-party websites/Apps may collect personal information about Users for their own purpose, in such cases, our Privacy Policy does not extend to these external websites/Apps of third parties. Please be aware that if You access these links, You will be leaving our Site(s). We encourage users to read the privacy policies of those websites/apps, as we are not responsible for their content, links, or privacy procedures

RETENTION, PROCESSING AND STORAGE OF INFORMATION:

Your personal data processed by LTH are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed in line with legal, regulatory, contractual or statutory obligations as applicable.
At the expiry of such periods, your personal data will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.

TO WHOM WE SHARE YOUR INFORMATION WITH?

We may share the Personal Information collected from the Sites/Social Media/RCS/SMS/WhatsApp with third parties as outlined in this section

1. Affiliates
   Our parent company, subsidiaries, joint ventures, group and associate companies. These entities may use this information for the purposes outlined above.
2. Business Partners
   1. Service Providers who perform services on behalf of LTH and which may need information about You in order to perform their functions including but not limited to authorised service partners, call centre operators, marketing contractors, social media website providers, data entry service providers, IT agencies operating handling or maintaining Sites/Social Media/ WhatsApp/RCS/SMS, storing/processing information, overseas service providers who work for us etc
   2. Vendors who are business associates of LTH like suppliers, research and development vendors, professional advisors, agents, representatives etc.
3. Other Partners
   Any third party with whom LTH co-brand or partner with or collaborate with or with any other third parties as may be necessary for LTH’s business purposes or to investigate potential data incidents or to protect the rights, property and safety of LTH and the Users of our Sites/Social Media/RCS/SMS/WhatsApp or others
4. Legal Authorities
   We may share your Personal Information in response to any notice, order, investigation or demand or request or any other communication from a law enforcement agency which necessitate or mandate the sharing of such personal information, or to otherwise comply with applicable laws.
5. Changes in Corporate Structure or Bankruptcy
   In the event that LTH is involved in a merger, acquisition, reorganization or sale of assets, bankruptcy, your information may be transferred as part of that transaction. We also may retain a copy of such information.

We DO NOT use or disclose Information for purposes other than as mentioned in this Policy, except with the consent of User providing such Information or as required by law.

INTERNATIONAL SHARING AND / OR TRANSFERS OF YOUR PERSONAL INFORMATION

LTH is a global company and therefore uses global dealers, distributors, vendors, subcontractors and other business partners, as well as global IT systems and applications. We may require the transfer of PI/SPI to other third parties that are located outside of the LTH’s country of business. We shall develop a standardized approach for protection of data moving across borders. We will adopt appropriate technical and administrative controls that apply well to cross border data flows to act as an accountability framework for information management as a whole and including natural checkpoints for each step of international transfer.

ACCESS AND ACCURACY

LTH wants to maintain only accurate information about the users. You can request access to your personal information by contacting us at dpo@lemontreehotels.com. Upon receipt of appropriate identification information, and where required by applicable Data Protection Laws, LTH will provide you with access to the information that it maintains about you.

YOUR RIGHTS

At LTH, we take your privacy very seriously, and we never monetize your information; we use it to enhance your experience. When it comes to your privacy rights, we want to make sure you have everything you need to make informed decisions. You have the right to:

• Right of Access - You have the right to be informed why and how we collect your personal data, how we will use this information, who we share it with, what are the security measures we take to protect this information and what your individual rights are; We will publish this information in this Privacy Notice. LTH shall provide a copy of the personal information undergoing processing. For any further copies requested, please note that LTH may charge a reasonable fee based on administrative costs
• Right to Rectification - You have the right for inaccurate or incomplete data we hold to be updated.
• Right to Erasure - Except in very specific cases where provided by law, you have the right to request that we delete any Personal Information which we are holding about you.
• Right to Restriction of Processing - Except in very specific cases where provided by law, you have the right to restrict processing of all or some of your personal information (e.g., if we have no legal right to process it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Data Portability - You have the right to receive your personal information or to transmit that information to another controller in a structured, commonly used and machine-readable format.
• Right to Object to the Processing - You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. Such right can be exercised at any time where your personal data is processed for direct marketing purposes
• Right to object being subjected to a decision based solely on automated processing, including profiling.
• You may opt-out of receiving non-essential (promotional, marketing-related) communications from us or our Affiliates/Business Partner/Other Partners/Third Parties. If you want to opt-out from any such communication as mentioned above from LTH then you may send an email to DPO email ID (as mentioned under “Contact Us” section of this policy).

At any stage, you can withdraw your consent to the retention/storage/processing of your Personal Information and LTH shall erase the Personal Information withdrawn by you unless there is a contractual obligation or legal requirement/obligation to retain/hold it or otherwise permitted by law to retain it. However, upon such withdrawal, the Company will not able to communicate with you and provide you with certain information on product and/or services which are required for fulfilment of any obligation.
LTH may be allowed by law, in particular in case of excessive or manifestly unfounded request, to charge a fee for fulfilling your request, subject to applicable conditions. The relevant contact details of Data Protection Officer are provided in this Policy.
How to Submit a RequestYou may submit a request to exercise your rights by following below steps:

• Download and fill the DSR form attached below

• Submit the DSR form on the following email dpo@lemontreehotels.com.

HOW WE PROTECT YOUR INFORMATION?

Our Sites/Social Media/RCS/SMS/WhatsApp have stringent security practice and measures in place to protect the personal information provided to us. Our database stores Personal Information in secure environment that are designed to safeguard it from loss, misuse, wrongful disclosure, destruction and alteration. The security measures are reviewed periodically by LTH to keep pace with business, technology and regulatory changes.

• The security and confidentiality of your Personal Data is important to us and LTH has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as LTH. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure
• We have physical, electronic, and procedural safeguards that comply with the applicable laws to protect personal information about you. We seek to ensure compliance with the regulatory requirements to ensure the protection and preservation of your privacy.
• We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.

CONTACT US

We welcome your questions, comments, and concerns about privacy. If you have any questions about the Privacy Policy or our data practices, please contact us as follows:

Data Protection Officer
Lemon Tree Hotels Ltd.,
Asset No. 6, Aerocity Hospitality District,
New Delhi - 110037
Phone: +91 4505 0101
Email: dpo@lemontreehotels.com

The Data Protection officer shall expeditiously redress the grievances, but within reasonable time as may be provided in applicable laws. Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in any email to us.

UPDATES TO THIS PRIVACY POLICY

We may periodically update this Privacy Policy. Please refer the “Updated on” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our sites. Your use of the Sites following these changes means that you accept the revised Privacy Policy.

MISCELLANEOUS

This Privacy Policy shall be governed by the laws of India and the courts in New Delhi shall have the exclusive jurisdiction to try any disputes arising thereof. This Privacy Policy shall be governed by any applicable data protection laws.