VOW is committed to protecting your information. This privacy notice provides details about the information we collect about you, how we use it and how we protect it. It also explains rights available under applicable law and how to contact us if you have questions about how we use your information.

In this privacy notice, references to “VOW”, “ VOW stays”, "we" or "us" or “our” are to Cross-Sell Technologies Pvt Ltd (a company incorporated under the laws of India).

Depending on where and how you interact with us (e.g. by using our app or by walking into one of our VOW-branded accommodations or booking an VOW- branded accommodation via a third party travel agency) different companies within VOW will process your information. You can find out more about the VOW companies that handle your information, including which company makes decisions about how your information is handled, by contacting us.

This notice applies to anyone who interacts with us in relation to our products and services (“you”, “your”), via any channel (e.g. app, website, email, phone, walk-ins to VOW-branded accommodations, booking an VOW-branded accommodation via a third party travel agency, etc.). We may give you additional privacy notices if required for specific interactions.

# If you book a stay through us at one of our partners’ guest houses, hotels and other lodgings (i.e. you stay at a property that is not VOW-branded), that partner will use your personal data as shown in their privacy notice.

This privacy notice applies to individuals who enquire about, purchase or make use of our products and services, such as when a user signs up with VOW, modifies his/her account, makes a booking (whether through our app, website, in person or via any other channel), requests on-demand services, contacts customer support, stays at VOW-branded accommodations or otherwise communicates or interacts with VOW.

It describes how we handle your information, regardless of the way you contact us (e.g. app, website, email, phone, walk-ins to VOW-branded accommodations, etc.). 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.

VOW offers accommodation in both VOW-branded guest houses, hotels and other lodgings. The word “VOW” appears in front of all VOW-branded accommodations, e.g. VOW 541 Royal Park Beach Resort, VOW 5341 Shyamala Garden and VOW 2262 Hotel Heritage Inn. If you book a stay through us at one of our partners’ accommodations, that partner will use your personal information as shown in their privacy notice (which can normally be found on our partner’s website or is provided by our partner via email or at check-in).

VOW’s website and app is not aimed at children, and we do not allow children to book accommodation or stay at our accommodations without a responsible adult. This privacy notice is therefore not aimed at children. If you provide us with information about your children, it is processed as described in this notice.

If you have any questions about this, please contact us.

We obtain personal information from you and from travel agents and others who book accommodation for you.

Where you provide us with information about other individuals (e.g. the names of others who you will stay at the accommodation you book), you must ensure that they have seen a copy of this privacy policy and are comfortable with you doing this. We obtain personal information from you through your interactions with us, including by telephone (please note that we 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 our VOW-branded accommodations or when you meet an VOW agent.

We also obtain your personal information from third parties such as:

a. others who book accommodation for you;

b. travel agencies through which you book VOW-branded accommodation.

c. accommodation providers;

d. service providers who work with us in relation to our product or service; and

e. if your work role involves you booking corporate employee accommodation, third parties who identify you as the appropriate contact for marketing our services to your organisation.

We process two categories of personal information about you and/or, where applicable, others whom you have booked accommodation for, namely:

a. standard personal information (e.g. information we use to contact you, identify you or manage our relationship with you); and

b. special categories of information as defined by applicable law (e.g. if you have indicated a Vegetraian or Non-Vegetraian food preference )

For further information on these categories of information, please expand this section.

a. Contact Information: We collect your name, user name, address, e-mail address and telephone number(s); if you choose to upload one or connect your social media account to your VOW account, your profile picture; and your country of residence, age, gender and date of birth;

b. Location Information: We may derive your approximate location from your IP address so that we show you more relevant content (e.g. accommodation near you). You can choose to allow our app to access location services so that we can suggest nearby accommodation. This will mean that we collect the precise location of your device when the app is running both in the foreground and the background.

c. Transaction Information: We collect transaction details related to your use of our services, e.g. type of service requested, date and time the service was provided, amount charged, days booked/stayed, and other related transaction details. If someone else uses an VOW referral code you have given them, VOW may associate that other person with you to ensure that you receive the benefit of having made that referral.

d. Account History: We collect details of your bookings and of contact we have had with you, such as complaints or incidents.

e. Usage and Preference Information: We collect information about how you interact with our website, app or other Services, including IP addresses, search terms and parameters and device information (you’ll find more information about this in our Cookie Statement)

f. 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

g. Device Information: 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.

h. Call and SMS Data: We make it easier for you to contact accommodation managers. In connection with this, we receive call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message.

i. CCTV: We may also collect your personal information if you access our premises and we use CCTV to monitor those premises.

j. WiFi: If you use WiFi offered at our accommodation, we will collect login information (which may include your email) and usage information that tells us how you use the WiFi.

a. information about religious or philosophical beliefs may be revealed by food preferences (e.g. halal, kosher, etc.);

b. information about health may be revealed by special requests for assistance or disability-friendly accommodation or if you require medical assistance during your stay; and

c. information about sexual orientation may be revealed if you tell us that you are married or in a relationship and you also give us the name of your partner.

We process your personal information for the purposes set out in this notice, based on the legal grounds set out under the Read More text. Different legal grounds apply depending on what category of personal information we process. Standard personal information is normally processed by us on the basis that it is necessary for the performance of a contract, our or a third parties’ legitimate interests or law. Further information about this and special category processing grounds is set out below.

We process standard personal information about you on the basis that it is:

a. necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract (i.e. to provide you and others you have booked accommodation for with products and services).

b. in our or a third parties’ legitimate interests: details of those legitimate interests are set out in more detail below.

c. where we are required to or is otherwise permitted by law.

a. you have manifestly made it public: for example if you are open about your sexual orientation or (if the AutoParty service is available in your country) you choose to tell us that your AutoParty is for the celebration of your same-sex or opposite-sex wedding;

b. processing is necessary for reasons of substantial public interest, on the basis of law: for example, if you are taken ill or have an accident at your accommodation, we may have to keep a record of the incident for health and safety purposes;

c. we have your consent: we would ask for any consent to process your special category data separately (your consent is not assumed simply because you have read this privacy notice);

d. processing is necessary for the establishment, exercise or defence of a legal claims

We process your personal information for a number of legitimate interests, including providing you with services, administering our relationship with you, for marketing and service/product improvement purposes and in order to exercise our rights or handle claims. More detailed information about our legitimate interests is set out below.

a. to provide and administer our products and services in respect of your booking, e.g. provide products and services requested (including our loyalty programme if applicable), send service communications (including updates about your accommodation arrangements), facilitate payments, send receipts and provide customer support;

b. 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);

c. to ensure that you can interact with us securely, e.g. we authenticate users;

d. to improve our services and develop new features for the VOW app, website and offering, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends;

e. to send you marketing that we think will be of interest to you (including information about products, services, promotions, news, and events) and to personalise your experience of us (in each case as permitted by law), including to provide or recommend features, content, social connections, referrals, and advertisements. You can opt-out of marketing at any time by the unsubscribe link in any emails you receive, adjusting your device settings to block notifications or contacting us.

f. to prevent fraud and abuse of our services;

g. 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 VOW, our customers, or others;

h. to exercise our rights and to defend ourselves from claims; or

i. to participate in, or be the subject of, any sale, merger or acquisition or all or part of the VOW business.

To ensure that the processing of personal information we carry out for the purpose of achieving these interests is proportionate, we have carefully balanced these legitimate interests and your interests and fundamental rights and freedoms. For further details of this balancing test, please contact us.

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

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.

If you wish to unsubscribe from emails sent by us, you can do so at any time by clicking on the "unsubscribe" link that appears in all emails and by adjusting the settings on your device to turn off notifications from our app. Otherwise, you can always contact us through email to update your contact preferences. You may also object to profiling relating to direct marketing by contacting us.

We and our service providers use cookies and other tracking technologies to track information about your use of our websites and mobile application. For more information about our use of cookies, please see our Cookie statement.

Currently, our systems do not recognize browser do-not-track signals. You may disable tracking on the website by following the steps in the Cookie Statement or on the service provider’s own website.

Service providers provide us with audience measurement and analytics services that analyse your online interactions (both with the VOW and other websites), serve you with tailored marketing and report on the performance of that marketing. We also use Google Place API to make suggestions based on your location or search strings

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.

VOW Stays is using Google Place API for place prediction. Please refer to Google Maps Terms of Service available at

https://maps.google.com/help/terms_maps.html

. To learn more about Google’s privacy practices, please see the Google Privacy Policy available at http://www.google.com/privacy.html . You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

We share your information within the VOW Group and with others who help us provide services to you (e.g. your accommodation provider). We also share your information in accordance with the law. For more information on who we share your information with, please expand this section.

We share your information for the purposes set out in this privacy policy, with the following categories of recipients:

a. other members of the VOW Group;

b. with accommodation managers to enable them to provide the services you request, e.g. we share your name and expected check-in time;

c. service providers who help deliver products or services on our behalf, entities who have partnered with VOW 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;

d. your contact if you use a referral feature;

e. the general public, if you submit content in a public forum, such as blog comments, social media posts, or other features of our services that are obviously viewable by the general public. For example, you may choose to use social sharing features and related tools which let you share your VOW experience with other apps, sites, or media, and vice versa. Your use of these features enables the sharing of information with your friends 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 to or share through them;

f. entities where we have a duty to or are permitted to disclose your personal information by law (e.g. law enforcement officials, government authorities);

g. with the police in the exercise of their functions or with others as required by a court order;

h. other entities where we (or any member(s) of the VOW Group) sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

i. entities in connection with any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of the VOW Group’s business, in which case personal data held by it about its customers or visitors to the website may be one of the transferred assets.

Where we share your personal information, appropriate protections will be in place to protect your personal information as required by data protection laws. Sometimes, we may share information in an aggregated, pseudonymised and/or anonymised form which cannot reasonably be used to identify an individual.

If you have any questions, comments, complaints or suggestions in relation to this notice, or any other concerns about the way in which we process information about you, please contact us.

This Privacy Notice is current as of the Last Updated date set forth above. We may change this Privacy Notice from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Notice on our websites and our mobile applications.

The following sections provide additional information for individuals in the European Union or European Economic Area about our processing of their personal information.

We retain your personal information in accordance with VOW’s records retention policies. However, there may be circumstances that mean we must retain your personal information for longer (e.g. if you make a claim in relation to a booking).

We retain your personal information in accordance with VOW’s records retention policies. In order to determine how long it is necessary to retain your personal information, we calculate retention periods in accordance with the following criteria:

a. the currency of your relationship with us and the types of products or services you have with us;

b. the length of time it is reasonable to keep records to demonstrate that we have fulfilled our obligations to you and under law;

c. any limitation periods within which claims might be made;

d. any retention periods prescribed by law or recommended by regulators, industry bodies or associations; and

e. the existence of any relevant proceedings.

Data protection laws for individuals with rights in relation to the information that VOW holds about them on some computer and paper records. These include rights to access, correct, delete, restrict the use of, object to the use of, port to another person, and withdraw consent to the use of, your information. Exceptions may apply to these rights.

a. Right of subject access: The right to make a written request for details of personal information we hold about you and to request a copy of that personal information.

b. Right to rectification: The right to have inaccurate information about you rectified.

c. Right to erasure ('right to be forgotten'): The right to have certain personal information about you erased.

d. Right to restriction of processing: The right to request that your personal information is only used for restricted purposes.

e. Right to object: The right to object to the use of personal information (including the right to object to marketing).

f. Right to data portability: The right to ask for personal information you have made available to us to be transferred to you or a third party in machine-readable formats.

g. Right to withdraw consent: We do not normally rely on consent as a basis for processing your personal information. We will only ask for your consent in very limited circumstances and, if we do so, will make it obvious to you when we are asking for that consent and what that is for. You have the right to withdraw any consent you have given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of use of your personal information prior to the withdrawal of your consent.

These rights may not apply in all cases. If we are not able to comply with your request, we will explain why. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If you would like more information about your rights or to exercise any of your rights.

If you have any questions, comments, complaints or suggestions in relation to this notice, or any other concerns about the way in which we process information about you, please contact us.

You also have a right to make a complaint to your local privacy supervisory authority.

1. you are living,

2. you work, or

3. the alleged infringement took place.