THE WETZLAR GLOBAL PRIVACY POLICY
Your Privacy Rights

Updated : July 11, 2015
Effective Date : August 1, 2015

This Privacy Policy applies to the sites, apps, digital and print forms; associated with WETZLAR RESORTS & HOTELS and wherever it appears.

At WETZLAR RESORTS & HOTELS we endeavor to provide our guests outstanding services and experiences in our hotel and luxury residences. 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 WETZLAR RESORTS & HOTELS’s Global Privacy Policy explains our practices regarding personal information we collect when you visit our hotel, restaurant, our website, when you fill up a form and become member of our loyalty programs.

We request you to read this policy document carefully before sharing personal information with us. By visiting our website, we assume, your acceptance to the practices described in this policy document.

This policy document covers the following areas relating to privacy of information provided by you:

i. Type of Information We Collect from Our Guests

ii. Purpose for Collection, Processing and Disclosure

iii. Non personal information collected by WETZLAR

iv. Links to Other Websites

v. WETZLAR‘s Policy Regarding Protection of its Guests’ Personal Information

vi. Consent

vii. How long does WETZLAR Retain your Personal Information

viii. Data Transfers across International borders

ix. Access to Personally Identifiable Information

x. Online Technologies

xi. Do-s & Don’t to ensure your personal information security

xii. Minors

xiii. Should You want to Opt-Out?

xiv. Contact Us

xv. Updates to the Privacy Statement

TYPE OF INFORMATION WE COLLECT FROM OUR GUESTS:

There are a number of situations in which your personal information may be gathered by WETZLAR RESORTS & HOTELS to serve you better. At various touch points with our guests, we may collect the following personal information including, but not limited to: your name and contact information; date of birth; how you prefer to be addressed in communication from the WETZLAR, preferred modes of communication; your job designation and business address; spouse name, anniversary, credit card details, including the three-digit code that appears on the back of your credit card; member number of our loyalty programs, membership numbers of frequent flyer or travel partner programs you are enrolled into, your dates of arrival and departure from our hotel/restaurant/other outlets, your preferences when you stay or dine at WETZLAR RESORTS & HOTELS, your transaction history at the WETZLAR; offers you have availed of from third party marketers in response to communication from the WETZLAR. We may also record details on guests who have stayed or dined with you at the WETZLAR, including their names and contact details.

WETZLAR collects information about our guests and visitors to our web sites so that we can provide an experience that is responsive to our guests’ and visitors’ needs. Information may be collected as part of: (i) fulfilling reservation or information requests, (ii) purchasing products or services, (iii) registering for program membership, (iv) submitting a job application, (v) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations), (vi) accommodating your personal preferences, (vii) fulfilling requests for services or recommendations we provide you, (viii) working with third party sources, including collecting information available from social networking and other web sites, to better assist us with understanding your interests and to serve you better, (ix) your use of our apps on your electronic devices, (x) updating your contact information including your address. The types of personally identifiable information (sometimes referred to as “PII”) that we collect may include your name, home, work and e-mail addresses, telephone, mobile telephone, and fax numbers, credit card information, date of birth, gender, and lifestyle information such as room preferences, leisure activities, names and ages of children, and other information necessary to fulfill special requests (e.g., health conditions that require special room accommodations).

Besides the above, we may also collect the following:

• When you fill out a form (online or hard copy), stating your preferences when you stay or dine at the WETZLAR.

• User name and password selected by you when you register at our website or become a member of our loyalty programs at our website.

• When you enroll in our online loyalty programs we collect your personal information and record your membership number and password.

• If you choose to reserve a room online we record your arrival and departure dates, number of guests in the group, details of guest rooms and tariff details.

• When you make a request for a proposal from our meeting planners, by visiting our websites.

• When you contact us with your questions or comments.

• From time to time, our website may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend. To fulfill your request, WETZLAR may require personal information about the person to whom you are sending an electronic postcard or message, including name and email address, along with the text of any message you choose to include. Using this feature is tantamount to entitling us to store and use the recipient’s name and email address.

• WETZLAR may also collect non-personally identifiable information about you, such as your use of our web sites, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys.

Please note, to better safeguard your information, please do not include any credit card information in your electronic communication unless it is specifically required by us as part of the reservation or transaction fulfillment process on our branded reservation web sites

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

We do not knowingly collect information related to your racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background or political affiliations, unless it is volunteered by you. We may use any health-related information provided by you only to serve you better and meet your specific needs when you stay or dine or chose from our Ayurveda programs at the WETZLAR.

PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE:

Collection & Use:

Your privacy is of utmost importance to us and we take it very seriously. We do not sell or rent your contact information to other marketers. We use your personal information to provide you with the services you request from WETZLAR.

WETZLAR is fully committed to providing you with information about the collection and use of PII furnished by, or collected from, visitors while using our web sites, products and services. It is our practice not to ask you for information unless we need it or intend to use it. Some of the primary purposes for collecting your PII are as follows:

• providing services such as processing a transaction (e.g., making a reservation, fulfilling a request for information, or completing a product order)

• marketing and communications with you in relation to the products and services offered by WETZLAR, our strategic marketing partners, and other trusted third parties

• performing market research via surveys to better serve your needs, improve the effectiveness of our web sites, your hotel experience, our various types of communications, advertising campaigns, and/or promotional activities on WETZLAR services by email, direct mail and phone, to make you offers sourced from third parties, per your stated preferences or usage pattern exhibited at WETZLAR.

You may opt out of marketing emails and WETZLAR surveys at any time by clicking on the link included in such communications, or by contacting us directly to opt out of direct marketing, telemarketing, emails or surveys. You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing a name will prevent the processing of reservations.

Processing and Disclosure – How does Wetzlar share the personal information collected from its guests, including with third parties:

In most cases, the information you provide is added to a local or global database. In the course of processing your information, it may be necessary to transfer your PII to WETZLAR‘s affiliates, properties within the Wetzlar system and/or third party service providers located in Kerala, India and throughout the world for the purposes outlined within this Privacy Statement. Unless otherwise precluded or governed by legal requirements and/or process, WETZLAR subsidiaries, affiliates and property owners that may receive your information are required to abide by substantially similar privacy requirements relating to your PII. As a general practice, WETZLAR does not sell, rent, or give physical possession of your PII to unaffiliated third parties outside the WETZLAR system. Situations in which WETZLAR may disclose your information to others include:

• when we have received your consent to do so

• With third parties:

1) in situations where sharing or disclosing your information is required in order to offer you products or services you desire (e.g., a vacation package)

2) when companies or services providers that perform business activities on behalf of WETZLAR require such information (e.g., credit card processing, customer support services, market research administration or database management services, management of the loyalty programs, mass mailings)

3) when a associate hotel or other property leaves the WETZLAR system and access to your PII is necessary to facilitate business operations or meet contractual obligations in connection with the fulfillment of reservations that are booked for future stays or events

4) In the event of a merger, consolidation, sale, liquidation or transfer of assets, WETZLAR in its sole and absolute discretion may transfer, sell or assign information collected, including without limitation, non-personal information and personal information, to one or more affiliated or unaffiliated third parties.

5) to comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena. WETZLAR with or without prior notice to you, may have to share your information in order to comply with applicable laws or respond to governmental inquiries or requests from public authorities or to comply with valid legal process, to protect the rights, privacy, safety or property of WETZLAR RESORTS & HOTELS, its guests, employees or the public or to permit us to pursue available remedies or limit the damages that we may sustain or to respond to an emergency

6) in case of emergency such as to safeguard the life, health, or property of an individual

These parties are contractually prohibited from using the personal information for any purpose other than those specified by WETZLAR. We may provide information that is non-personal, to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. WETZLAR expressly prohibits the sale or transfer of any information to any party outside of WETZLAR by such service providers.

If information is shared as mentioned above, we seek to limit the scope of information that is furnished to the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your PII and abide by applicable privacy laws and regulations.

• From time to time WETZLAR may partner with other companies to provide co-sponsored or co-branded promotions, products and services and may share your information with our co-sponsor. For example, we may co-sponsor some prize draws, competitions or contests on our site with other companies or we may provide prizes for and contests sponsored by other companies. If you enter one of these contests, we may share your information with our co-sponsor or the third party sponsor.

• If you use a corporate credit card, your billing information may be shared with your employer.

NON-PERSONAL OR ANONYMOUS INFORMATION COLLECTED BY WETZLAR:

Information that does not personally identify you is referred to as non-personal or anonymous information. When you visit and interact with the sites ww.thewetzlar.com or third parties with whom WETZLAR RESORTS & HOTELS has contracted to provide services, non-personal information, like, list of website pages visited by you, could be collected. Technology like cookies could be used to help you deliver content per your preference, to help you process your reservations or other requests. While this cannot be used to disclose your identity, this information will identify your browser to our servers when you visit our site. To remove the cookies at any point from your computer, you can delete them using your browser.

We also may collect data by using web beacons, clear GIFS, pixel tags or similar means, which will tell us when you visit our site. Non-personal information like the domain name, the areas of the site you visit, your operating system, your browser version, and the URL you visited from, can be identified, which can be used to enhance your online experience by understanding your web usage patterns.

We may use or disclose non-personal information for any purpose from time to time since this does not personally identify you. For instance, we may embed e-mail addresses with images. In such cases where we combine non-personal information with personal information, the combined information will be treated by us as personal information as per this policy.

LINKS TO OTHER WEBSITES & OF THIRD PARTY MARKETERS:LINKS TO OTHER WEBSITES & OF THIRD PARTY MARKETERS:

In order to anticipate your needs, WETZLAR provides links to other web sites for your convenience and information. WETZLAR is not responsible or liable for any content presented by or contained on any independent web site, including, but not limited to, any advertising claims or marketing practices. Please note that while WETZLAR will protect your information on WETZLAR owned and operated web sites, we cannot control and will not be responsible for the privacy policies of third party web sites, including web sites owned or controlled by independent franchisees, third party interval ownership, or web sites not controlled or authorized by WETZLAR.

Third party web sites that are accessed through links on our web sites have separate privacy and data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their web sites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.

From time to time, we may allow third party advertisers advertise on our websites. These third party advertisers may use technologies like cookies, pixel tags to track which ads your browser has seen and which site pages you may have visited. WETZLAR has no control over the use of this technology or the resulting information and is not responsible for any actions or policies of such third parties.

WETZLAR’S POLICY REGARDING PROTECTION OF ITS GUESTS’ PERSONAL INFORMATION:

WETZLAR takes precautions, including administrative, technical and physical measures- to safeguard your personal information against loss, theft, misuse, as well as unauthorized access, disclosure, alteration or destruction. However, unfortunately no security system or system of transmitting data over hard copy or the internet can be guaranteed to be entirely secure. You can help us by also taking precautions to protect your personal data when you are on the Internet. For your own privacy protection we advise you not to include sensitive personal information in any emails or written information you may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.

CONSENT:

As part of our commitment to keep you informed, we may mail, e-mail, telephone, or contact you by other means to notify you of new WETZLAR products and services, or upcoming WETZLARspecial offers, events, enhancements, or other relevant information that may be of interest to you. You may also receive mailings or other communications from carefully selected third parties. We offer you the option to decline any or all of these WETZLAR communications by following the directions included in our e-mails or other communications, or by contacting WETZLARdirectly.

If you are a WETZLAR member, you may also change your communication choices by updating your communication preferences in your individual membership profile.

We would like to keep all of our guests and visitors informed and equally able to take advantage of the benefits offered by WETZLAR and its strategic marketing partners. However, if you reside outside India, certain data privacy regulations may require us to obtain your permission before we send you information that you may have / not requested from us.

In some cases your permission will be implied from the nature of the service requested or transaction undertaken. For example, WETZLAR may collect and use PII that you volunteer, or behavioral data or information collected in the aggregate. In addition, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.

In certain circumstances, we will seek your express permission when we collect information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions).

You may object to WETZLAR disclosing your PII with third parties except when: (i) service providers have been retained to perform services on behalf of WETZLAR; (ii) disclosure is required by law; (iii) disclosure concerns national, legal or public interest grounds; (iv) disclosure is necessary to protect the vital interests of the guest; (v) information has been collected from publicly accessible sources; (vi) disclosure concerns the retrospective processing of the information for historical, statistical or enhancement of guest experiences; or (vii) disclosure is authorized by a supervisory authority (such as a Privacy Commissioner, Data Protection Authority, or other similar authority).

 

HOW LONG DOES WETZLAR RETAIN YOUR PERSONAL INFORMATION:

WETZLAR will retain your personal information for the period necessary to fulfill the purposes outlined in this policy document, unless a longer retention period is required or permitted/mandated by applicable law.

 

DATA TRANSFERS ACROSS INTERNATIONAL BORDERS:

WETZLAR RESORTS & HOTELS , as part international entity PANSUN GROUP, we endeavor to provide you with the outstanding service, and hence we have established a global network comprised of offices, data centers, trusted marketing partners, service providers, customer contact centers, and trained associates across the globe. The nature of our business and our operations require us to transfer your information, including PII, to other group companies, properties, centers of operations, data centers, or service providers that may be located in countries outside of your own. We may transfer the PII we collect about you to countries other than the country in which the information was originally collected. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, WETZLAR will take appropriate steps to ensure that your PII is protected and handled as described in this Privacy Statement.

 

ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION:

To ensure that your PII is accurate and up to date, we encourage you to regularly review and update your information as appropriate (e.g., in the event your home or e-mail address changes, or you wish to add an additional method for us to communicate with you). If you are WETZLAR member, you can review and update your individual membership profile on-line or with the assistance of a WETZLAR customer service representative. If you are not a WETZLAR member you can share and update your PII via email to reservations@thewetzlar.com. Please note that in an effort to prevent the unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication materials) together with the completed request form. Access to PII for non-WETZLAR members cannot be provided by telephone.

If, upon review, you wish to deactivate your program member profile, or update your PII, we will endeavor to do so in a timely manner. Occasionally, information that you request to be removed will be retained in certain files for a period of time in order to properly resolve disputes or to troubleshoot problems. In addition, some types of information may be stored indefinitely on “back up” systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your PII will be completely removed from our databases in response to your request.

Please refer to the appropriate contact information below to contact us about updating your communication preferences, removal from our marketing lists, or to submit a general question or request.

 

ON-LINE TECHNOLOGIES:

Cookies

As is standard practice on many corporate websites, WETZLAR RESORTS & HOTELS website uses cookies and other technologies to help us understand which parts of our website are most popular, where our visitors are going, and how much time they spend there and use this information to improve our marketing programs and content. We use cookies and other technologies to study traffic patterns on our website, to make it even more rewarding as well as to study the effectiveness of our customer communications. And we use cookies to customize your experience and provide greater convenience each time you interact with us.

WETZLAR and its third party marketing partners may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our web sites and reported in the aggregate and does not contain PII. WETZLAR cookies are not designed to damage your files, nor can they read information from other files on your computer hard drive.

Cookies can help us provide you with a personalized on-line experience in the following ways:

• they remember your user name and password for future visits so log-in is easier and faster.

• they ensure you are provided with the appropriate frames and content.

• they ensure you obtain all requested information.

• they help us deliver communications that are relevant and responsive to your interests and location.

WETZLAR cookies are limited to our web sites only, and are not designed to follow you when traveling on the Internet after leaving WETZLAR owned website. We track the usage of our website in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to WETZLAR cookies, various third parties may also place cookies on your computer’s hard drive. WETZLAR is not responsible for the presence or absence of third party cookies, or for the technological capabilities or practices employed by third parties in connection with third party cookies.

We also work with vendors and marketing partners to help deliver advertisements and personalized content that we believe will be of interest to you. These vendors and other partners include advertisers, advertising agencies, advertising networks, audience segment providers, data exchanges, analytics providers, and other similar providers. These partners and vendors use cookies and web beacons to collect information about your online activity (e.g., the sites and pages you have visited at WETZLAR sites and other third party sites) in order to help WETZLAR (and in some cases, third party advertisers) deliver personalized content and advertising to you while you are on WETZLAR or other sites.

If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our web sites and our ability to recognize your browser from one visit to the next.

 

DO & DON’T TO ENSURE YOUR SECURITY

• For your own privacy we advise you not to include sensitive personal information in any emails you may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.

• We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not allow your children to submit personal information without your permission.

MINORS:

WETZLAR RESORTS & HOTELS does not seek to obtain nor does it wish to receive PII directly from minors; however, we cannot always determine the age of persons who access and use our web sites. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future WETZLAR marketing communications.

SHOULD YOU WANT TO OPT OUT:

If we possess your contact information, we may want to keep you posted about our products, services and events, through email. Should you prefer not to keep up to date with WETZLAR news and latest information on services and receive such marketing materials, please send an email to marketing@thewetzlar.com

We will update your preferences as soon as reasonably practical. However, do note, if you opt out of WETZLAR emailing list, as described here, we will not be able to remove your personal information from the databases of affiliates, business partners with which we have already shared your personal information, prior to the date of your opt-out request.

CONTACT US:

Updating Your Communication Preferences

If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from WETZLAR RESORTS & HOTELS in the future, you can contact us:

by e-mail: marketing@thewetzlar.com

by telephone: +91 485 2838444 or +971 55 7984744

by writing to us at: Wetzlar Resorts & Hotels Pvt. Ltd.(A unit of Kandamkulathy Enterprise), Prasad Road, East Kadathy, Market P.O., Muvattupuzha – 686673, Ernakulam District, Kerala, India

Customer Service

If you would like to contact WETZLAR’s Customer Service Department, please choose the most convenient method from the following:

by e-mail: wecare@thewetzlar.com

by telephone: +91 485 2838444 or +91 90484 94444

by writing to us at: Wetzlar Resorts & Hotels Pvt. Ltd.(A unit of Kandamkulathy Enterprise), Prasad Road, East Kadathy, Market P.O., Muvattupuzha – 686673, Ernakulam District, Kerala, India Attention: Customer Service

Data Privacy

If you have comments or questions regarding WETZLAR‘s data privacy practices or this Privacy Statement, you may contact us by choosing the most convenient method from the following:

by e-mail: feedback@thewetzlar.com

by writing to us at: Wetzlar Resorts & Hotels Pvt. Ltd.(A unit of Kandamkulathy Enterprise), Prasad Road, East Kadathy, Market P.O., Muvattupuzha – 686673, Ernakulam District, Kerala, India

Attention: Consumer Affairs – Privacy

If you have any questions or concerns about this policy, please get in touch with us at marketing@thewetzlar.com

UPDATES TO THE PRIVACY STATEMENT:

WETZLAR RESORTS & HOTELS may update its privacy policy from time to time without prior notice and posted on the website.

This statement was last updated to include WETZLAR RESORTS & HOTELS’ Booking Engine Platform, updates to the types of information we may collect, online advertising, online technologies section, as well as information regarding updates to your communication preferences, and new contact information. WETZLAR RESORTS & HOTELS may amend this Privacy Statement from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our guests, properties, strategic marketing partners, and service providers. Updated versions will be posted to our web site and date stamped so that you are always aware of when the Privacy Statement was last updated