ITC Limited respects an individual's right to privacy. This policy lays down our practices with respect to confidentiality and disclosure of personal information. Please familiarize yourself with our privacy practices, as given below. Should you choose to share your personal information with ITC Limited, it will be assumed that you have no objection to the terms of this privacy policy.
Collection of Personal Information
- ITC Limited collects personal information only when it is required for business purposes. We may also receive information relating to you from third parties. This personal information includes information such as
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Date of birth
- Gender
- Marital status
- Nationality
- Next of kin and emergency contact information
- Copy of Government issued ID Card (for Indian citizens)
- Copy of Passport and Visa, if required (for non-Indian nationals)
- Duration of stay and other related details
- Photographs
- Bank account details, credit/debit card information
- CCTV footage and other information obtained through electronic means such as door access records.
- Information about your use of our information and communications systems.
- Dietary preferences, allergy details, health condition, and information about how you use our services and about how you use our website/mobile application
- While collecting any personal information, ITC Limited indicates the purpose of collection of such information and obtains the consent of the provider of the information in writing. ITC Limited gives the person providing the information an option of not providing the information. He also has the option of withdrawing his consent given earlier. In such cases, ITC Limited may choose not to provide any services/supply goods for which the information was necessary.
- While collecting information, ITC Limited or any entity authorized on its behalf to collect information takes such steps as are, in the circumstances, reasonable to ensure that the person providing the information has the knowledge of -
- the fact that the information is being collected
- the purpose for which the information is being collected; and
- the intended recipients of the information
- Where we need to protect your interests (or someone else's interests)
- Where it is needed in the public interest or for official purposes or to fulfil a legal obligation. For instance, requests made by law enforcement agencies, courts or tribunals.
- If you fail to provide certain information when requested, we may not be able to perform the agreement that we have entered or may enter into with you, or we may be prevented from complying with our legal obligations (such as to ensure your health and safety). You hereby accept and agree that we shall not be held liable in any manner whatsoever if we are unable to perform our services or if there is a deficiency in our services to you due to your failure to provide such information. You agree that you shall not file or initiate any complaints, legal proceedings or claims against us and/or our employees, directors, associates, etc. in this regard. You further agree to indemnify and hold us and/or our employees, directors, associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against us in this regard.
- We will only use your information for the purposes for [AS2] which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- You agree that we do not need any additional or further consent from you to use your sensitive personal information in accordance with this Policy to carry out our legal obligations or exercise specific rights.
- In limited circumstances, we may approach you for your written consent to allow us to collect and process certain additional sensitive personal information. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent for providing any additional information to us.
- The providers of information are permitted, as and when requested by them, to review the information they had provided.
Confidentiality and Disclosure
- The terms of confidentiality and disclosure of personal information will be recorded in the non-disclosure agreement that may be entered into with the provider of the information.
- ITC Limited has also adopted reasonable security practices and procedures comprising of managerial, technical, operational and physical security control measures with a view to ensure confidentiality and prevent unauthorized disclosure of personal information.
- ITC Limited uses the personal information only for the purpose for which the same has been furnished. ITC Limited does not retain information after the purpose for which it is furnished is accomplished unless the same is required to be retained under any law in force or for audit purposes. In such cases also, confidentiality of such information is maintained.
- We may disclose your information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy and for the purpose of providing services to you. We may disclose your information to any member of our organisation including our subsidiaries and partners, insofar as reasonably necessary for the purposes set out in this Policy. We may disclose your information:
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights including providing information to others for the purposes of fraud prevention and reducing credit risk;
- to the purchaser or prospective purchaser of any business or asset that we are or are contemplating selling; and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that information.
- Except as provided in this Privacy Policy, we will not provide your information to any other third party.
Transfer of Information
- Unless stated otherwise, we store and process your information in India. There will, however, be occasions when we need to transfer your information outside India in order to enable us to use the information in accordance with this Policy.
- Such transfer of information may be to a country which does or does not provide the same level of data protection as in India. In these circumstances we will take appropriate steps to ensure that your information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as us, so that your information is adequately protected.
- Please note that the information that we collect may be transferred to countries which do not have an adequacy of data protection in respect of that country. This means that the country to which we transfer your information is not deemed to provide an adequate level of protection for your information. To ensure that your information does receive an adequate level of protection we have put in place strong inter country security measures to ensure that your information is treated by those third parties in a way that is consistent with the nation in which you reside.
- You expressly agree to the transfers of your information described in this Section.
Information about Children
- As a general rule, we do not intentionally collect information about children under the age of 16. If we become aware that we have inadvertently collected such information about children under the age of 16, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it.
- Where we know a child is above the age of 16, but considered a minor under applicable law, we will obtain parental/guardian consent prior to collecting or using that child's information.
Automated decision-making
- Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
- We do not envisage that any decisions will be taken about you using automated means. However, we will notify you in writing if this position changes.
Policy for Website and Mobile Application Usage
- Any personal information shared by you in our website and mobile application shall be kept confidential in accordance with ITC Limited's reasonable security practices and procedures. Personal information, shared by you, shall be used for doing the intended business with you.
- ITC Limited assures you that in the event of your personal information being shared by ITC Limited with its subsidiaries, business associates etc., such sharing of information shall be for the purpose of doing the intended business with you. You hereby grant your consent to ITC Limited to share such information with its subsidiaries, business associates etc.
- ITC Limited reserves its rights to collect, analyse and disseminate aggregate site usage patterns of all its visitors with a view to enhance its services to the visitors. This includes sharing the information with its subsidiaries and business associates as a general business practice.
- In the course of its business, ITC Limited may hold on-line contests and surveys as permitted by law and it reserves its right to use and disseminate the information so collected to enhance its services to the visitors. This shall also include sharing the information with its subsidiaries and business associates as a general business practice.
- Cookies: - To personalize your experience on ITC Limited's website and mobile applications or to support one of its promotions, ITC Limited may assign your computer browser a unique random number (cookie). "Cookies" enhance performance [AS1] in important ways like personalizing your experience, or making your visit more convenient. Your privacy and security will not be compromised when you accept a "cookie" from ITC Limited's Website. However, please note that each time you visit our website / mobile applications, we automatically receive and record certain information of your session. Like many other websites and mobile applications, we use log files. These files merely log visitors to the website or mobile applications which is a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, internet service provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks made by you. This information is used to analyse trends, administer the website or mobile application, track your movement around the website or mobile application, and gather demographic information[AS2] . These log files and the information contained in it, such as IP addresses, and other such information, cannot be used by us to identify or ascertain your identity.
- You may choose to share certain special categories of personal data, such as health, with us directly (or through authorised persons, travel agents, etc.) in certain circumstances. We collect such special categories of personal data only when it is essential. Examples of where we may collect and process sensitive personal information includes the following:
- where you have requested specific medical assistance from us, such as the provision of a wheelchair, medical assistance; or
- where such information has been passed onto us by a third party, where you have given that third party consent to do so, such as the travel agent through which you made your booking or from other hotels for your onward journey, where the processing of such special categories of personal data is required for the processing of your service request.
- By providing such special category of personal data you agree that we may collect, use and share this information with third parties for the purpose of processing your service request, as described in this Privacy Policy[AS3] .
- ITC Limited shall not be responsible in any manner whatsoever for any violation or misuse of your personal information by unauthorised persons consequent to misuse of the internet environment.
Accuracy of Information
It is important that the information we hold about you is accurate and up to date. Please keep us informed if your information changes during your relationship with us.
Access and Correction of Information
- If any information we have about you is not accessible through our website/mobile application, you can send us a request for access to this information at no cost using the applicable contact details set out at the end of this Policy.
- After receiving your request and sufficient information to verify your identity we will provide you with a copy of the information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such information is being used, its recipients and the origin of the information.
- You may write to us at any time requesting amendments to certain information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your information. We will update, block, erase or remove your information upon request in line with applicable law.
Deletion of Information
You may at any time ask us to delete your information. We will consider and where necessary comply with your request in accordance with applicable law, as explained above. Please note that after deleting the information, we may not be able to provide the same level of services to you as we will not be aware of your preferences.
Withdrawal of Consent
You may at any time revoke or withdraw your consent to provide your information to us by using the applicable contact details set out at the end of this Privacy Policy. However, such action may render it impossible for us to assist you any further. You hereby accept and agree that we shall not be held liable in any manner whatsoever if we are unable to perform our services or if there is a deficiency in our services to you due to your withdrawal of consent. You agree that you shall not file or initiate any complaints, legal proceedings or claims against us and/or our employees, directors, associates, etc. in this regard. You further agree to indemnify and hold us and/or our employees, directors, associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against us in this regard
Access
You have the right to know whether we process information about you, and if we do, to access that information we hold about you and to ascertain how we use it and who we share it with. Please note that we may not provide you with certain information if providing it would interfere with another’s rights (e.g. where providing the information we hold about you would reveal information about another person) or where another exemption applies.
Portability
- You have the right to receive a subset of information we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such information to another party. If you wish for us to transfer the information to another party, please ensure you provide details of that party and note that we can only do so where it is legally, contractually and technically feasible.
- We are not responsible for the security of the information, its transmission or its processing once received by the third party. We also may not provide you with certain information if providing it would interfere with another’s rights (e.g. where providing the information we hold about you would reveal information about another person).
Erasure
- You may request that we erase the information we hold about you in the following circumstances:
- you believe that it is no longer necessary for us to hold the information we hold about you;
- we are processing the information we hold about you on the basis of your consent and you wish to withdraw your consent and there is no other ground under which we can process the information;
- we are processing the information we hold about you on the basis of our legitimate interest and you object to such processing;
- you no longer wish us to use the information we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
- you believe the information we hold about you is being unlawfully processed by us.
- However, please note that we may retain the information if there are valid grounds under law for us to do so. We will let you know if that is the case.
- Please note that after deleting the information, we may not be able to provide the same level of services to you as we will not be aware of your preferences. Where you have requested that we erase information that we have made public and there are grounds for erasure, we will use reasonable steps to attempt to tell others that are displaying the information or providing links to the information to erase such information.
Restrict Processing of your Information
In certain circumstances, you have a right to ask us to stop processing your information other than for storage purposes. However, please note that even if we stop processing your information, we may use it again if there are valid grounds under applicable laws for us to do so (e.g. for the defence of legal claims or for another’s protection).
You may ask us to stop processing your information and just store it with us in the following cases:
- Where your information is not accurate. In such a case you can ask us to stop processing your information for the duration it takes us to verify whether the information is accurate;
- Where we wish to erase your information as the processing we are doing is unlawful but you want us to store the information instead;
- Where we wish to erase the information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
- Where you have objected to our processing of your information on the basis of our legitimate interest and during the duration it takes us to determine whether there is an overriding interest for us to retain such information.
Objection
- You have the right to object to our processing of your information which is used to send you promotions, special offers, marketing messages, including where we build profiles for such purposes.
- You may also object to the processing of your information (including where the processing is profiling) on the basis of our legitimate interest and your objection to such processing
Grievance Officer
In accordance with the Information Technology Act, 2000 and the rules framed thereunder, the name and contact details of the Grievance Officer are provided below:
Mr. Tejinder Singh
Grievance Officer
grievanceofficer@itchotels.in
1-800-419-6444
9AM - 5PM (on all working days)
Changes to the Policy
- ITC Limited reserves its right to revise this privacy policy from time to time at its sole discretion. Such policy will be available on the ITC Limited's Website.
All words and expressions used herein and not defined, but defined in the Information Technology Act, 2000 and/or the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 shall have the meanings respectively assigned to them thereunder.