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INTRODUCTION

Grand Asoke Residence is committed to protecting the privacy and security of your personal information. We have developed this Privacy Policy to explain our practices regarding the personal information we collect from you or about you on this site, via our apps, or through written or verbal communication with us when you visit our properties, or from other sources. While this Privacy Policy broadly describes the practices that we have adopted globally, local laws vary and some jurisdictions may place restrictions on our processing activities. Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY USING ANY OF OUR PRODUCTS OR SERVICES YOU UNDERSTAND AND ACKNOWLEDGE THAT WE WILL COLLECT AND USE YOUR PERSONAL INFORMATION AS DESCRIBED BELOW AND AGREE TO THIS PRIVACY POLICY.

This policy may change from time to time. Your continued use of our products or services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Data Controller

When this Policy mentions “Grand Asoke Residence,” “we,” ‘us,” or “our,” it refers to the Grand Asoke Residence that is responsible for your information under this Privacy Policy (the “Data Controller”).

PERSONAL INFORMATION WE COLLECT

Grand Asoke Residence collects personal information at every touch point or guest interaction. This personal information may include: your name, mailing address, work address, place of employment, billing address, email address, phone number, information related to your reservation, stay or visit to a property; participation in a membership or loyalty program; participation in a contest, sweepstakes, or marketing program; personal characteristics, gender, salary information, passport number, social security or IATA number (in limited circumstances); payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with billing; guest preferences; marketing and communication preferences; information about vehicles you may bring to our properties; reviews and opinions about our properties or service providers; and other types of information that you choose to provide to us or that we may obtain about you.

When we collect information from you to voluntarily supply us with the information. We endeavor to collect information only with your knowledge and with your permission if necessary. Where appropriate, we may also ask your employer, relocation company, travel agency or other third party (where such third party has made reservations, agreed to make payments, arranged for discounts, purchased services or are otherwise responding or interacting with us on your behalf, or if you use our services under a corporate or other commercial account) to voluntarily supply us with information we need to process your reservation. In these instances, we will confirm with the third party that they have received your consent to provide thisinformation to us.

In addition to the above, we collect other personal information in certain cases, such as:

Customer Surveys: We may request personal information and demographic data in customer surveys.

On-property Collection: We may collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties where permitted by law. In addition, we may collect personal information in connection with on-property services, such as concierge services.

WiFi Service: When you use WiFi service at our properties, the personal data you provide for access and authentication may be collected and used by us and third parties such as authentication gateway partners and WiFi service providers to facilitate your use of the WiFi service.

Cookies: Grand Asoke Residence uses cookies and pixel tags
(Web beacons) to obtain information while visiting our websites. Please view our
cookie policy

 USE OF PERSONAL INFORMATION COLLECTED ABOUT YOU

We use your personal information in a number of ways, including to provide and personalize the services you request and expect from Grand
Asoke Residence, conduct direct marketing and sales promotions, and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.

We collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information may result in our inability to process your reservation.

Marketing Communications: Where permitted we may use your personal information to provide or offer you newsletters, promotions, and featured specials, as well as other marking messages in accordance with any communication preferences you have expressed.

PERSONAL INFORMATION WE SHARE

In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal
information among Grand Asoke Residence’s affiliates, subsidiaries, services providers, properties that we manage but do not own, owners and operators of Grand Asoke Residence.

When we communicate with employers, relocation companies, travel agencies, companies or organizations who have made reservations, agreed to make payments, arranged for discounts, or purchased services on your behalf or if you use our services under a corporate or other commercial account.

If you seek to have your rental charges invoiced to your employer or any other third party, we may disclose your personal information to
that employer or third party and to any companies that assist the third party in processing invoices.

When we report to credit card issuers, credit reporting, fraud checking agencies and debt collection agencies, but only to the extent
necessary to comply with contractual agreements.

If you choose to business with us through, or with assistance of, your employer’s or any third party’s travel agent, relocation
company or other intermediary, we may disclose personally information about you to the employer or other intermediary to make, modify or cancel a reservation made by or with assistance of the agent, to respond to questions or comments made by the agent on your behalf, to facilitate any other task that the employer or intermediary advises us that you intend for the agent to fulfill, or that such agent would, as a matter of industry practice, typically fulfill.

We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate.
Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. However, our fraud detection service providers may use, but not share, your personal information for fraud detection purposes. We may use service providers to communicate news and deliver promotional transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law.

If you share personal information with us as described above, we will limit the scope of such information that is furnished solely to the amount necessary for the performance of the specific function. We may confirm personal information you provide us on applications and forms, or as a resident of one of our communities, with third parties, such as your bank, employer, present landlord, utility providers, government entities, resident screening agencies, credit agencies, and other businesses where you have an account or credit card. Unless otherwise precluded by legal process, we require third parties to protect your personally identifiable information in a similar manner as set forth in this Privacy Policy, and abide by applicable laws and regulations. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of your data that we transfer to them.

Under certain circumstances, we may be required to disclose your data in response to valid request by public authorities, including to meet
national security and law enforcement requirements.

OTHER INFORMATION

When you visit and interact with Grand Asoke Residence websites and apps, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information). We use Other Information to improve your experience online.

We use cookies and other technologies (such as “pixel tags” and “web beacons”) to collect information. If you want to remove or block
Cookies from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block Cookies.) Grand Asoke Residence is not responsible for your browser settings.

We may use information we have collected and aggregated or anonymized personal information received from third parties, to understand more about our users. This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, and other information we may collect from you or from third parties.

Because Other Information does not personally identify you, such information may be disclosed for any purpose where permitted by law. In
some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.

SENSITIVE INFORMATION

The term “sensitive information” refers to information related to your racial or ethnic origin, political opinion, religious philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data, and information contained on identity documents also are considered sensitive information.

We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

PERSONAL INFORMATION FROM CHILDREN

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not allow your children to submit personal information without your permission.

Our website and mobile application are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on our website or application. If you are under 10, do not use or provide any information to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child under 18, please contact us using the instructions outlined in the Contact Information section below.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our site and our mobile applications may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites,
the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Grand Asoke Residence may partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet services is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies by visiting the Internet provider’s website.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with
the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our website may then be inaccessible or not function properly.

Promotional Offers from the Company. If you do not wish to have your contact information used by Grand Asoke Residence to promote our own products or services, you can opt-out by following the directions on a marketing e-mail or direct mail communication from us, or send an email with your current contact information to rsvn@grandasokeresidence.com

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collection or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

ACCESSING, CORRECTING, AND DELETING YOUR INFORMATION

You can review, change, or delete your personal information by following the instructions in the Contact Information section below. Whenever you submit a request to update your information in any way, we will honor your request within 4 weeks and will inform you of the status.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). To request copies of your personal information, please contact using the instruction in the Contact Information section below.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website or through our app. Any transmission of personal information is at your own risk.

DATA TRANSFERS ACROSS INTERNATIONAL BORDERS

The nature of our business and operations may require us to transfer your information, including personally identifiable information, to other group companies, properties, centers of operations, data centers or service providers that may be located in countries outside of your own. Although the data protection and other relevant laws of these counters may not be as comprehensive as those in your own country, Grand Asoke Residence will take reasonable steps to ensure that your personally identifiable information is protected and handled as described in this Policy.

POLICY CHANGES

We may modify this Policy from time to time. When we make changes to this Policy, we will post a link to the revised Policy on the
homepage of our site. You can tell when this Policy was last updated by looking at the date at the top of the Policy. Any changes to our Policy will become effective upon posting of the revised Policy on the site. Use of the side, any of our products and services, and/or providing consent to the updated Policy following such changes constitutes your acceptance of the revised Policy then in effect.

CONTACT INFORMATION

If you have questions or comments about this notice, the ways in which Grand Asoke Residence collects and uses your information
described here, your choices and rights regarding such use, or wish to exercise your rights, please contact us via email or mail at: rsvn@grandasokeresidence.com