Privacy Policy

1. Who We Are

Privy Stays Private Limited is a hospitality company registered under the laws of India, operating as the hospitality arm of We All.

• · Registered Name: Privy Stays Private Limited
• · CIN: U55101MH2023PTC413085
• · GSTIN: 27AAOCP2059H1Z4
• · Registered Office: Sheth Arcade, Bypass Road, Alibag, Maharashtra, India
• · Contact: info@privystays.com | +91 99705 16669
• · Working Hours: 9:00 AM to 5:00 PM (IST), Monday to Saturday, excluding public holidays.

This policy is provided in compliance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Consumer Protection (E-Commerce) Rules, 2020.

2. Personal Data We Collect

We collect personal data from you in the following ways:

Data You Provide Directly

• · Booking data: Name, phone number, email address, booking dates, property selected, number of guests, and payment details.
• · Identity data: Government-issued photo identification collected at check-in for all adult guests, as required under applicable Indian regulations for hospitality stays.
• · Corporate booking data: Company name, GSTIN, CIN or equivalent registration number, designation of authorised signatory, and Purchase Order details.
• · Guest list data: Names and identification of all guests for Group Bookings.
• · Communication data: Correspondence with us via email, WhatsApp, or other channels, including grievance submissions, damage dispute communications, and general enquiries.

Data Collected Automatically

When you visit the Website, we collect certain data automatically through cookies and similar tracking technologies:

• · Usage data: Pages visited, traffic sources, time spent on pages, and user journey data, collected via Google Analytics 4.
• · Device data: Browser type, operating system, and device identifiers.
• · Marketing & conversion data: Interaction with our advertisements on Facebook and Instagram, and engagement with our messaging campaigns, collected via the Meta Pixel and ManyChat Pixel.
• · Booking session data: Session cookies set by Stayflexi (our booking engine) to process and manage your bookings.
• · Payment session data: Cookies set by Zoho Payments and UPI session authentication for secure payment processing.

For full details on cookies, see our Cookie Policy.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• · To process and manage your booking: Including confirmation, check-in, check-out, invoicing, and post-stay communication.
• · To comply with legal obligations: Including guest identification requirements under applicable hospitality regulations, GST invoicing requirements, and data protection obligations under the DPDP Act, 2023.
• · To process payments: Including security deposits, booking fees, and any additional charges arising from your stay.
• · To manage damage assessments and refunds: Including communicating inspection findings, processing security deposit refunds via bank transfer, and resolving disputes.
• · To deliver marketing communications: Including relevant advertisements on Meta platforms (Facebook and Instagram) and messaging campaigns via WhatsApp and Instagram Direct Messages, where you have not objected to such communications.
• · To improve the Website: Using anonymised analytics data to understand how visitors interact with the Website and to improve its content and functionality.
• · To respond to grievances and disputes: Including complaints about bookings, personal data, Website content, and staff conduct.

4. Legal Basis for Processing

We process your personal data on the following grounds:

• · Consent: For non-essential cookies, marketing communications, and data processing activities where we have requested and received your consent. You may withdraw your consent at any time.
• · Contractual necessity: To fulfil our obligations under your booking agreement, including processing payments, managing your stay, and handling deposits and refunds.
• · Legal obligation: To comply with applicable Indian law, including guest identification requirements, GST invoicing obligations, and the requirements of the DPDP Act, 2023.
• · Legitimate interests: To improve the Website, prevent fraud, and manage our business operations, where such interests are not overridden by your rights.

5. Sharing Your Personal Data

We do not sell your personal data. We may share your personal data with the following categories of third parties, solely for the purposes described in this policy:

• · Property management and booking: Stayflexi, our hospitality property management system and booking engine, to process and manage your reservation.
• · Payment processing: Zoho Payments and UPI payment infrastructure, for secure payment and deposit processing.
• · Analytics: Google (via Google Analytics 4), for anonymised website usage analytics.
• · Marketing: Meta (Facebook and Instagram), for advertising measurement and delivery; ManyChat, for messaging engagement and campaign conversion tracking.
• · Independent property owners: Where a property is managed by Privy Stays on behalf of an independent owner, certain booking details may be shared with that owner solely for operational purposes. Privy Stays remains your primary point of contact in all such cases.
• · Legal and regulatory authorities: Where required by applicable law, court order, or regulatory authority.

Each third-party service processes your data under its own privacy policy. We encourage you to review:

• · Google: policies.google.com/privacy
• · Meta (Facebook, Instagram): facebook.com/privacy/policy
• · ManyChat: manychat.com/legal/privacy
• · Stayflexi: stayflexi.com/privacy-policy
• · Zoho: zoho.com/privacy.html

6. Your Rights Under the DPDP Act, 2023

Under the Digital Personal Data Protection Act, 2023, you have the following rights in relation to your personal data held by Privy Stays:

• · Right to access: You may request a summary of the personal data we hold about you and the purposes for which it is processed.
• · Right to correction: You may request correction of inaccurate or incomplete personal data.
• · Right to erasure: You may request deletion of your personal data where we no longer have a lawful basis to retain it.
• · Right to data portability: You may request that your personal data be provided to you in a machine-readable format.
• · Right to nominate: You may nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity.
• · Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please write to our Grievance Officer at info@privystays.com. We will respond within the timelines prescribed under applicable law.

7. Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes described in this policy, or as required by applicable law. Booking and transaction records are retained for the period required under Indian tax and corporate law. Guest identification records are retained in accordance with applicable hospitality regulations. After the applicable retention period, your personal data will be securely deleted or anonymised.

8. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Payment processing is handled by Zoho Payments and the UPI infrastructure, which maintain their own security standards. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. Cookies

This Website uses cookies and similar tracking technologies for essential website functionality, analytics, marketing, and booking and payment processing. You may manage your cookie preferences through the consent banner on your first visit to the Website, or through your browser settings. For full details, see our Cookie Policy.

10. Grievance Officer & Redressal

In compliance with the DPDP Act, 2023, the Information Technology Act, 2000, and the Consumer Protection (E-Commerce) Rules, 2020, Privy Stays has appointed a Grievance Officer to address concerns related to your personal data and your use of this Website.

• · Grievance Officer: Ankit Choudhary, Co-Founder and Sales Head
• · Email: info@privystays.com
• · Address: Privy Stays Private Limited, Sheth Arcade, Bypass Road, Alibag, Maharashtra, India
• · Working Hours: 9:00 AM to 5:00 PM (IST), Monday to Saturday, excluding public holidays.
• · Acknowledgment: We will acknowledge your grievance within 24 to 48 hours.
• · Resolution: We will endeavour to resolve your grievance within 15 working days of acknowledgment.

When writing to us, please include your full name and contact details, a clear description of your concern, your booking reference or transaction ID if applicable, and any supporting documents or evidence.

If your grievance is not resolved to your satisfaction, you may escalate to:

• · The Data Protection Board of India, for personal data matters under the DPDP Act, 2023, once fully constituted and operational.
• · The National Consumer Helpline: 1800-11-4000 or consumerhelpline.gov.in.
• · The appropriate civil or consumer court with jurisdiction in Raigad / Mumbai, Maharashtra, India.

11. Governing Law & Jurisdiction

This Privacy Policy is governed by the laws of India. All disputes are subject to the exclusive jurisdiction of the courts at Alibag (Raigad District), Maharashtra, India.

12. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in technology, applicable law, or our practices. Any changes will be posted on this page with a revised effective date. We encourage you to review this policy periodically.

Effective Date: This policy is effective from the date of publication on privystays.com and may be updated from time to time. Please check this page periodically for changes.

Privacy · Private Time · Branded Hospitality · Privy Stays, the hospitality arm of We All