ON THE PROCESSING OF PERSONAL DATA
Last updated on 01-May-2022
La Serenita Resorts Pvt. Ltd., together with our holding company(ies), affiliates, subsidiaries and the resorts or other properties we own, operate or manage (“Properties”) (together, “La Serenita”, “La Serenita Group”, “we” or “our”), respect the privacy of every individual who visits our Properties and/or uses any of our websites.
- is provided to us when you stay or travel with us (or make enquiries to stay or travel with us) either by you or by a third party through whom you have made an enquiry or booking; and
- we collect from you when you visit any of La Serenita’s websites or which we obtain from any communications with you.
- Data Controller
La Serenita Management Limited is the data controller with respect to your personal data and is registered in Mumbai.
- Personal data we collect
2.1 Personal data you provide on a voluntary basis
- We will collect, store and process information about you if you voluntarily provide us with such information in connection with the following:
- filling in a form on any of our websites;
- filling in a physical registration card;
- opting in to receive marketing information with us;
- creating an online account with us and managing your preferences;
- contacting us by telephone or face to face (e.g. in the context of making a reservation);
- sending us a letter, e-mail or social media message;
- subscribing to receive a service from us (e.g. a newsletter, blog or by following us on social media);
- requesting promotional information from us (e.g. information about any of our goods or services including La Serenita gift cards);
- participating in a survey, competition or prize draw; or
- contributing content to us (e.g. for display on a La Serenita blog).
The types of information we may obtain include:
- name, address, email address, telephone number
- passport and visa data, payment data, travel history and details of joint travellers;
- dates of your stay or travel with us and associated charges;
- purchase or delivery of products or services;
- reviews and opinions about our brands, products and services;
information we receive about you from any third parties through whom you have booked your arrangements; and
information we receive about you from other members of the La Serenita Group (which may include information relating to a specific booking, travel dates, details of payments made to us, special requests and other information relating to your personal preferences (e.g. food and beverage preferences and interests).
‘Special category’ personal data
We do not collect data that is, by its nature, particularly sensitive (e.g. genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership) unless it is volunteered by you.
We may use certain sensitive (or “special category”) personal data where you have given your explicit consent to us doing so, to better serve and meet your needs. Such sensitive data is only shared with other members of the La Serenita Group or our third party service providers acting as data processors (e.g. excursion providers, restaurants, transport providers) for the purpose of providing the services you request and will not be shared or used by us for any other purposes.
Examples of sensitive personal data we may collect and process include:
dietary requirements which may imply or suggest your religion, health or other sensitive personal data;
2.2 Personal data we collect automatically
Data we collect through such means may comprise the following:
- date and time;
- originating IP address;
- domain name;
- type of browser and operating system used (if provided by the browser);
- URL of the referring page (if provided by the browser);
- object requested;
- completion status of the request;
- geographic location; or
- language preferences.
- Use of personal data
As a provider of luxury hospitality experiences worldwide, La Serenita has a legitimate business interest in operating and improving its business and the services it offers. La Serenita therefore uses and processes your personal data to:
help us create content that is relevant to our visitors;
- make improvements to our websites and social media pages and ensure that content on these is presented in the most effective manner for you;
- provide you with information, products or services that you request from us or which we feel may interest you;
- facilitate bookings, payment and other administrative processes related to your stay or travel;
- assess and help us understand general trends and patterns relating to our business;
- provide for the safety and security of our guests and visitors;
- manage general record keeping;
- enable us to compile anonymous, aggregated statistics that allow us to understand how users use our websites and to help us improve the structure of our websites;
- enable you to make reservations, buy La Serenita gift cards and make payments;
- meet any legal and/or regulatory requirements;
- provide the products or services you request from us including providing personalised services; and
- improve our products and services and to ensure our products and services are of interest to you.
Even where La Serenita has a legitimate interest in processing your personal data, it will not do so to the extent that processing would override your interests, rights and freedoms to protect your personal data.
We may also use your personal data to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by applicable law.
marketing and profiling purposes which are managed solely by La Serenita Management Limited as data controller for the La Serenita Group. Your decision to provide your data for such purposes is optional and will have no consequence on your ability to stay with us or benefit from the requested services;
all purposes concerning a specific booking, the related stay or travel with us, and the provision of stay-specific services you have requested, in relation to the processing of the relevant personal data by another member of the La Serenita Property which collects that data. Your decision to provide personal data (including special category/sensitive personal data) to us is voluntary, however, if you do not provide such personal data you may no longer be able to benefit from our services.
We may process your personal data by both automated and manual means. We may use your personal data in other ways for which we provide specific notice at the time of collection.
- Sharing personal data
We may share your personal data with third parties as described below:
third party service providers who have been appointed as data processors to perform functions and services on our behalf and who will be provided only with personal data necessary to perform the services on our behalf but are not authorised by us to use such data for any other purposes (e.g. providers of services in respect of web hosting, payment processing, information technology systems, customer relationship management, booking and reservations management, marketing, auditing, administration); reservations management platforms used by you or La Serenita to make reservations at La Serenita restaurants. Third party providers of components of any package holiday, excursion, transfer, concierge arranged activity/experience or another service we arrange for you; to our advisors and insurers in the event of a claim, dispute or where otherwise necessary; where the La Serenita Property you visit is operated, but not owned by the La Serenita Group, the owner of that La Serenita Property (and its advisors and representatives);
if we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a legitimate request from a law enforcement authority or another government official; and
- Your rights
We will only send you marketing communications if you “opted in” to receive such communications. You have the right to “opt-out” of receiving marketing communications, whether by email or otherwise, at any time. You can do this by (i) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, (ii) emailing [email protected] to indicate you no longer wish to receive marketing communications,
- How we protect your personal data
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Service providers and contractors who might have access to your data in order to provide services on our behalf will be contractually obliged to keep such data in confidence, provide adequate data security measures, and may not use that data for any other purpose.
For your own protection, we encourage you not to include sensitive personal data, credit card or similar personal data in any e-mails you send us or our staff.
- How long do we keep personal data for
La Serenita only retains your personal data for as long as needed to fulfil the purposes for which it is collected, unless we are required or permitted by law to keep the personal data for longer.
Your personal data will be anonymised or deleted if your last interaction with La Serenita was over 7 years ago. “Interaction with La Serenita” includes for example visiting a La Serenita Property or opening marketing communications from La Serenita.
- Links to other websites
Our websites may provide links to other websites for your convenience and information. These websites operate independently from us. Linked websites may have their own privacy policies, which we strongly suggest you review. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.
- How to contact us