OYO’s Patron Privacy Policy

This Patron Privacy Policy (the “Policy”) describes how OYO Hotels, Inc., its parent company, subsidiaries, affiliates, and related entities (together, “Us” or  "OYO") process, share (if at all), use, and protect personal information about you as a current, former or prospective Patron through use of the OYO Platform or our Services when you engage in a business relationship with Us, visit or use our websites or application. Your privacy is important to Us, and we are committed to protecting your personal information as detailed below and in compliance with applicable laws. This Policy also covers how your personal information is handled by our third-party data processors.

By accessing or using the OYO Platform or Services or contracting with OYO, you agree to this Policy, and you are consenting to OYO’s collection, use, disclosure, retention, and protection of your Personal Data as described herein. If you do not provide the information we require, we may not be able to provide all our Services to you.

1.Scope of our Patron Privacy Policy:

This privacy policy applies to any person or business  who interacts with Us concerning our products and services, via any channel (e.g. in person, through our app, website, email, phone, contacts Patron support, shares reviews, etc.) (hereafter, “Patron”).  

Patrons acknowledge and expressly consent that personal data mentioned in this policy means any information that can directly or indirectly identify a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (hereinafter “Personal Data”).

Personal Data (whether or not in aggregated, pseudonymized, and/or anonymized form) related to Patrons, the property/hotel/home/guest house, and other parameters collected by OYO may be used, transmitted, processed, shared, and transferred by OYO (i) for facility performance evaluation, optimization and improvement (ii) benchmarking (iii) for marketing and advertising; (iv) where OYO has a duty to or are permitted to disclose data under applicable law or under a court/ Government order; (v) in connection with any merger, sale of company assets, consolidation or restructuring, financing, liquidity event or acquisition; or (vi) any other lawful purpose.

Sometimes we will provide you with additional information or notices, depending on the way we interact with each other, e.g. if you use particular functionality on our app, we may explain how that functionality uses your information.

This Policy does not apply to any guest/customer data obtained by Patron or data insofar as it is held, processed, disclosed, or published in a form which cannot be linked to a living individual (such as anonymized or aggregated data which cannot directly or indirectly be used to identify you or to obtain information about you) ("Anonymized and Aggregated Data"). We may generate or extract Anonymized and Aggregated Data out of any databases containing your Personal Data and we may make use of any such Anonymized and Aggregated Data for our purposes as we see fit.

2. Ways in which we obtain Personal Data from You:

2.1 We obtain Personal Data directly from You such as:

  • Through your interactions with us, including by telephone (please note that we may record or monitor our calls for compliance and quality assurance purposes), by email, via our websites, via our apps, via post, via social media, or face to face e.g. in accommodations booked through us or when you meet an OYO employee/ agent.
  • Your name, address, date of birth, social security number, driver’s license, foreign identification, or passports.
  • Personal or Business bank account numbers, credit cards, or payment methods stored by OYO.
  • Financial statements relating to the Patron property/hotel, partnership agreements, corporate records, and the like.  

2.2.  We obtain Personal Data from third parties such as:

  • Your employees or authorized agents about the property, hotel, or guest home in the normal course of providing Services or access to the OYO Platform.
  • OTA through our Services or access to the OYO Platform.
  • Service providers who work with us about our product or service.

3. Categories of Personal Data:

We process two categories of personal information about you and/or, your interactions with us, such as:

  • Standard personal information (e.g. information we use to contact you, identify you, or manage our relationship).
  • Standard Personal information examples include:
  • Contact Information: We collect your name, username, address, e-mail address, and telephone/mobile number(s); if you choose to upload one or connect your social media account to your OYO Patron account, your profile picture; and your country of residence, age, gender and date of birth;
  • Location Information: We may derive your approximate location from your IP address so that we show you more relevant content (e.g. revenue management services local to your area). This will mean that we collect the precise location of your device when our apps are running both in the foreground and the background.
  • Location Information: We may derive your approximate location from your IP address so that we show you more relevant content (e.g. revenue management services local to your area). This will mean that we collect the precise location of your device when our apps are running both in the foreground and the background.
  • Transaction Information: We collect transaction details related to your use of our OYO Platform or Services, e.g. type of service requested, date and time the Service was provided, amount, da
  • Usage and Preference Information: We collect information about how you interact with our website, apps, or other Services, including IP addresses, search terms and parameters, and device information (you’ll find more information about this in our HYPERLINK "https://www.oyorooms.com/cookie-policy" Cookie Statement)
  • Log Information: We collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.
  • Device Information: When applicable we collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information to help us understand how our app is performing across a range of devices and to help us identify the cause of “crashes” and potential performance improvements.
  • CCTV: When applicable and dependent on our contractual relationship, we may also collect your personal information if you access our premises and we use CCTV to monitor those premises. Card details and other payment information: We may collect and store card details and other payment information to the extent permitted by law when you create an account or while making payment for Services our use of the OYO Platform.
  • Special categories of information (e.g. if you have indicated a halal or kosher food preference or have chosen to let us know that you have a medical condition requiring special accommodations when conducting business with us).
  • 4. Purposes and grounds for processing and sharing Personal Data:

    We process and share special category information because 1) we have your consent and 2) processing is necessary for the establishment, exercise, or defense of legal claims. We will ask for any consent to process and share your special category data separately.

    4.1. Processing: We process standard Personal Data about you on the basis that 1) it is necessary to comply with the performance of a contract or contractual relationship and 2) to provide, improve, and develop the OYO Platform and Services. Some examples of these uses are as follows:

    • enable you to access the OYO Platform and/or Services and make and receive payments when applicable
    • enable you to communicate with OYO
    • perform analytics, debug, and conduct research
    • provide customer service
    • send you messages, updates, security alerts, and Patron account notifications
    • if you provide us with your contacts’ information such as your employees, partners, data-protection, or your third-party vendors, we may process this information: (i) to facilitate Services being provided to you (ii) for fraud detection and prevention, and (iii) to facilitate your requests or for any other purpose you authorize
    • personalize and customize your experience based on your interactions with the OYO Platform or our Services  
    • enable your use of other OYO products as they become available
    • conduct security investigations and risk assessments
    • verify or authenticate information provided by you
    • conduct checks against databases and other information sources, including background checks
    • comply with our legal obligations, protect the health and well-being of guests, Patrons, Patron employees, and members of the public
    • resolve disputes with You
    • enforce our agreements with third parties
    • comply with the law, respond to legal requests, prevent harm, and protect our rights 

    4.2. Sharing: We share your information within OYO and with contracted third parties who help us provide Services to you as stated in this Policy that includes but are not limited to the following: 

    • Third-party suppliers including OTAs who help deliver products or services on our behalf, or who have partnered with OYO in connection with Services or a relevant promotional offering, as well as other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate.
    • The public, if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the public. For example, you may choose to use social sharing features and related tools which let you share your OYO experience with other apps, sites, or media, and vice versa. Your use of these features enables the sharing of information with your customers or followers or the public, depending on your social sharing service settings. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide or share through them.
    • Third parties where we are required to disclose your personal information under law (e.g. law enforcement officials, government authorities).
    • With the police and other law enforcement agencies in the exercise of their functions or with others as required by a court order.
    • Third parties in connection with any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of the OYO’s business, in which case personal data held by it about its Patrons or visitors to the website may be one of the transferred assets.

    When we share your Personal Data appropriate protections will be in place to protect your information as required by data-protection laws. If your information is in anonymized or aggregated form, we may share it with third parties or publish it.  This data does not personally identify you and helps us to measure the success of the Services and its features and better improve your experience.  We reserve the right to make use of any such aggregated data as we see fit.

    5.Legitimate Interests:

    We process and share your personal information for several legitimate interests (considering your interests, rights, and freedoms), including providing you with Services, administering our relationship with you, for marketing and service/product improvement purposes, and to exercise our rights or handling claims. More detailed information about our legitimate interests is set out below.

    • To provide and administer our products and services, provide products and services requested (including our loyalty program if applicable), send service communications, facilitate payments, send receipts, and provide Patron customer support.
    • To administer our relationship with you, our business, and our third-party providers (e.g. to investigate complaints, confirm that our providers have provided the correct service to you and invoiced correctly for them, etc.).
    • To ensure that you can interact with us securely, e.g. we authenticate users.
    • To improve our Services and develop new features for the OYO apps, website, and offers, including troubleshooting software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
    • To send you marketing that we think will be of interest to you (including information about products, services, promotions, news, and events) and to personalize your experience of us (in each case as permitted by law), including to identify your preferences, provide or recommend features, content, social connections, referrals, and advertisements.
    • To detect and/or prevent fraud, money laundering, and abuse of our Services, including spam and other security and safety incidents.
    • To enforce or apply our website terms of use, our policy terms, and conditions or other contracts, or to protect the rights, property, or safety of OYO, our customers, or others.

    6.Marketing and Preferences:

    We use your Personal Data to send you marketing by telephone, social media platforms, email, SMS, application notifications, and silent notifications to track the installation status of the application. We may also use your personal information to carry out online paid marketing activities.

    We also use technology to help us understand your personal preferences and interests so that we can send recommendations and marketing communications that are likely to be of more interest to you and your business. Using technology in this way is sometimes known as profiling.

    7. Analytics and Advertising Services Provided by Others:

    Third parties provide us with audience measurement and analytics services that analyze your online interactions (both with the OYO and other websites), serve you with tailored marketing, and report on the performance of that marketing. If you log in or access the OYO Platform with a third-party service, such as Google, Facebook, Instagram, etc., you may direct OYO and/or such third party service to exchange information regarding profiles as authorized by you through the privacy settings selected by you on the OYO Platform and/or such third party service.

    We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services. For more information about these technologies and service providers, please refer to our Cookie Statement.

    OYO is using Google Place API for place prediction. Please refer to their privacy policy. HYPERLINK "http://www.google.com/privacy.html" http://www.google.com/privacy.html

    Further, please note that the OYO Platform stores your data with the cloud platform of Amazon Web Services provided by Amazon Web Services, Inc., which may store this data on their servers located outside of the United States of America. Amazon Web Services has security measures in place to protect the loss, misuse, and alteration of the information, details of which are available at https://aws.amazon.com/. The privacy policy adopted by Amazon Web Services is detailed in https://aws.amazon.com/privacy. In the event you have questions or concerns about the security measures adopted by Amazon Web Services, you can contact their data protection/privacy team / legal team or designated grievance officer, whose contact details are available in its privacy policy, or can also write to our Grievance Officer at the address provided below.

    8.

    OYO uses global information systems. As a result, OYO may transfer your Personal Data to a country outside of your country for the purposes set out in this Policy and as permitted under applicable laws.  

    OYO takes steps to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards. More information about these safeguards (including copies, where relevant) can be obtained by contacting HYPERLINK "mailto:dataprotection@oyorooms.com" dataprotection@oyorooms.com or HYPERLINK "mailto:legal.us@oyorooms.com" legal.us@oyorooms.com.

    9. Retention period:

    OYO will retain your personal information per applicable laws, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain information related to you if we believe that it may be necessary to prevent fraud, abuse or to enable OYO to exercise its legal rights and/or defend against legal claims or if required by law or for other legitimate purposes. OYO may continue to retain your personal information in anonymized form for research and analytical purposes.

    10. Your obligations:

    You agree not to publish, transmit, store, update or share any information in the course of our business dealings that:

    • (i) belongs to another person and to which do not have any right.
    • (ii) is defamatory, obscene, pornographic, pedophilic, invasive of another's privacy, including bodily privacy, insulting, or harassing based on gender, libelous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force.
    • (iii) is harmful to a child.
    • (iv) infringes any patent, trademark, copyright, or other proprietary rights.
    • (v) violates any law for the time being in force.
    • (vi) deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading but may reasonably be perceived as a fact.
    • (vii) impersonates another person.
    • (viii) threatens the unity, integrity, defense, security or sovereignty of India, friendly relations with foreign states, or public order, or causes incitement to the commission of any cognizable offense or prevents investigation of any offense or is insulting other nation.
    • (ix) contains a software virus or any other computer code, file, or program designed to interrupt, destroy or limit the functionality of any computer resources.
    • (x) is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity, or agency for financial gain or to cause any injury to any person.

    11.Data protection contacts / Contact Us

    If you have any questions, comments, complaints, or suggestions concerning this notice or any other concerns about how we process information about you, please contact our data protection team at HYPERLINK "mailto:dataprotection@oyorooms.com" dataprotection@oyorooms.com or HYPERLINK "mailto:legal.us@oyorooms.com" legal.us@oyorooms.com.  

    If you are not satisfied with the response from our data protection team, you can contact our Grievance Officer:

    • Name: Jagbir Singh
    • Designation: Director - Technology
    • Address: 3rd Floor, Orchid Centre Near IILM Institute, Sector 53, next to Sector 54, Gurugram, Haryana 122022
    • Email: HYPERLINK "mailto:dataprotection@oyorooms.com" dataprotection@oyorooms.com and HYPERLINK "mailto:legal.us@oyorooms.com" legal.us@oyorooms.com. 
    • Phone: 9313931393

    12.CHANGES TO THIS PRIVACY POLICY

    We may update this Policy at any time in response to changing laws or technical or business developments. You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy.