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HOTSPOT Rooms Privacy Notice

Last updated: 08/02/2021

HOTSPOT Rooms 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 your rights and how to contact us if you have questions about how we use your information.

Information about HOTSPOT

In this privacy notice, references to “HOTSPOT”, “HOTSPOT Rooms”, “we” or “us” or “our” are to Oravel Stays Singapore Pet Limited (a company incorporated under the laws of Singapore) and its parent company and its subsidiaries (the “HOTSPOT Group”).

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

Scope of our privacy notice

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 HOTSPOT-branded accommodations, booking an HOTSPOT-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 HOTSPOT-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 HOTSPOT, modifies 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 HOTSPOT-branded accommodations or otherwise communicates or interacts with HOTSPOT.

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

HOTSPOT offers accommodation in both HOTSPOT-branded guest houses, hotels and other lodgings. The word “HOTSPOT” appears in front of all HOTSPOT-branded accommodations, e.g. HOTSPOT 116 Kathmandu Resort, HOTSPOT 316 Hotel Brigade Royale and HOTSPOT 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).

HOTSPOT’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.

Ways in which we obtain personal information

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.

Categories of personal information

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

• Standard personal information (e.g. information we use to contact you, identify you or manage our relationship with you); and
• Special categories of information (e.g. if you have indicated a hall or kosher food preference or have chosen to let us know that you have a medical condition requiring special accommodations).

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

Standard personal information includes:

• 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 HOTSPOT account, your profile picture; and your country of residence, age, gender and date of birth;
• 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
• 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 a HOTSPOT referral code you have given them, HOTSPOT may associate that other person with you to ensure that you receive the benefit of having made that referral.
• Account History: We collect details of your bookings and of contact we have had with you, such as complaints or incidents.
• 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)
• 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.
• 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.
• 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.
• CCTV: We may also collect your personal information if you access our premises and we use CCTV to monitor those premises.
• Wi-Fi: If you use Wi-Fi offered at our accommodation, we will collect login information (which may include your email) and usage information that tells us how you use the Wi-Fi.

Sometimes you may choose to give us special category information about you or others which may attract extra protections under data protection laws. For example:

• Information about religious or philosophical beliefs may be revealed by food preferences (e.g. hall, kosher, etc.);
• 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
• 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.

Purposes and lawful grounds of our processing personal information

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:

• Necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfill that contract (i.e. to provide you and others you have booked accommodation for with products and services).
• In our or third parties’ legitimate interests: details of those legitimate interests are set out in more detail below.
• Where we are required to or is otherwise permitted by law

We process special category information because:

• You have manifestly made it public: for example if you are open about your sexual orientation or (if the Auto Party service is available in your country) you choose to tell us that your Auto Party is for the celebration of your same-sex or opposite-sex wedding;
• 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;
• 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);
• Processing is necessary for the establishment, exercise or defense of a legal claims

Legitimate interests

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.

We process your personal information for the following legitimate interests (taking into account your interests, rights and freedoms):

• To provide and administer our products and services in respect of your booking, e.g. provide products and services requested (including our loyalty programmed if applicable), send service communications (including updates about your accommodation arrangements), facilitate payments, send receipts and provide customer support;
• 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);
• To ensure that you can interact with us securely, e.g. we authenticate users;
• To improve our services and develop new features for the HOTSPOT app, website and offering, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
• To send you marketing that we think will be of interest to you (including information about products, services, promotions, news, and events) and to personalize your experience of us (in each case as permitted by law), including to identify your preferences, provide or recommend features, content, social connections, referrals, and advertisements. You can opt-out of marketing at any time by clicking the unsubscribe link in any emails you receive, adjusting your device settings to block notifications or contacting us.
• To prevent fraud and abuse of our services;
• 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 HOTSPOT, our customers, or others;
• To exercise our rights and to defend ourselves from claims; or
• To participate in, or be the subject of, any sale, merger or acquisition or all or part of the HOTSPOT 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

Marketing and Preferences

We 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. Using technology in this way is sometimes known as profiling.

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 at dataprotection support@hotspotgroup.in to update your contact preferences. You may also object to profiling relating to direct marketing by contacting us at dataprotection support@hotspotgroup.in

Analytics and Advertising Services Provided by Others

Third parties provide us with audience measurement and analytics services that analyze your online interactions (both with the HOTSPOT 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.

HOTSPOT Rooms is using Google Place API for place prediction. Please refer to their privacy policy. http://www.google.com/privacy.html

Sharing your information

We share your information within the HOTSPOT 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 whom 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:

• Other members of the HOTSPOT Group;
• With accommodation managers to enable them to provide the services you request, e.g. we share your name and expected check-in time;
• Third party suppliers who help deliver products or services on our behalf, or who have partnered with HOTSPOT 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;
• Your contact if you use a referral feature;
• 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 HOTSPOT 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;
• Third parties where we have a duty to or are permitted to disclose your personal information by law (e.g. law enforcement officials, government authorities);
• With the police in the exercise of their functions or with others as required by a court order;
• Third parties in connection with any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of the HOTSPOT 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.

Transfers outside of your country

HOTSPOT uses global information systems. As a result, HOTSPOT transfers your personal information to a country outside of your country, including to India and Singapore, for the purposes set out in this policy. Not all countries outside of EEA have data protection laws that are similar to those in the EEA and they may not be regarded by the European Commission as providing an adequate level of data protection.

HOTSPOT takes steps to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards. More information about these safeguards (including copies, where relevant) can be obtained by contacting support@hotspotgroup.in

Retention period

We retain your personal information in accordance with HOTSPOT’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 HOTSPOT’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:

• The currency of your relationship with us and the types of products or services you have with us;
• The length of time it is reasonable to keep records to demonstrate that we have fulfilled our obligations to you and under law;
• Any limitation periods within which claims might be made;
• Any retention periods prescribed by law or recommended by regulators, industry bodies or associations; and
• The existence of any relevant proceedings.

Your rights

Data protection laws in the EEA and some other countries provide individuals with rights in relation to the information that HOTSPOT 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.

The data protection laws in the EEA and in some other countries provide individuals with the following rights:

• 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.
• Right to rectification: The right to have inaccurate information about you rectified.
• Right to restriction of processing: The right to request that your personal information is only used for restricted purposes.
• Right to object: The right to object to the use of personal information (including the right to object to marketing and profiling relating to direct marketing).
• 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.
• 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.
• 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 do not 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, please contact support@hotspotgroup.in.

Data protection contacts

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 our Privacy Team at If you are not satisfied with the response from our Privacy Team, you can contact our Data Protection Officer] support@hotspotgroup.in

You also have a right to make a complaint to your local privacy supervisory authority. If you are in the EU, you can lodge a complaint with another supervisory authority which is based in the country or territory where:

• You are living
• You work, or
• The alleged infringement took place.

A list of the EU data protection supervisory authorities is here.

Guest Policies for HOTSPOT Hotels and Homes in India.

General Booking Policy:

1. Certain destinations may have different travel guidelines for specific times during the year. Please abide by all laws and guidelines as applicable.
2. Policies are booking specific and would be informed to the guest at the time of booking or upon Check-In.
3. Reference to HOTSPOT includes its affiliates, employees and officers. “Hotel” refers to the hotel or home in which you have made a valid booking through HOTSPOT.

Check-in Policy:

1. The primary guest must be at least 18 years of age to be able to check into the hotel.
2. The usual standard check-in time is 12 noon. HOTSPOT tries to ensure that you can check-in any time after that till your reservation is valid.
3. It is mandatory for all guests to present valid photo identification at the time of check-in. According to government regulations, a valid Photo ID has to be carried by every person above the age of 18 staying at the hotel. The identification proofs accepted are Aadhar Card, Driving License, Voter ID Card, and Passport. Note that PAN card is not acceptable. Without an original copy of a valid ID, you will not be allowed to check-in.
4. After reaching the hotel, if you face any difficulty in check-in and it cannot be resolved by the Hotel, you are requested to contact HOTSPOT immediately. HOTSPOT will verify the issue with the Hotel and post verification, you would be provided the following assistance:

   a. HOTSPOT will try to arrange for accommodation in the same Hotel

   b. HOTSPOT will try to provide you with alternate accommodation in its other listed properties if the same is available.

   c. If HOTSPOT is unable to provide alternative accommodation or you do not accept such alternate accommodation, you may be offered full refund.

   d. HOTSPOT will not be liable for compensation beyond your booking payment.

5. Unless specifically intimated, HOTSPOT shall not be held liable to refund the booking amount or any part thereof in case of unavailability of rooms due to natural disaster (earthquake, landslide etc.), terrorist activity, government guidelines or any force majeure act, beyond the control of HOTSPOT.

Early Check-in and Late Check-out:

1. Early Check-In: The standard check-in time in Hotels is 12 noon unless mentioned otherwise in your Booking voucher. Early check-in is subject to availability. Extra charges will usually apply as per below policy:

Complimentary breakfast will not be available to you for the day of early check in.

2. Late Check-out: The standard check-out time in Hotels is 11AM unless mentioned otherwise in your Booking voucher. Late check-out is subject to availability and cannot be confirmed with the Hotel in advance. Extra charges will usually apply as per the below policy:

Booking Extension Policy:

Any extension of stay at the Hotel is subject to availability of the rooms at the current ongoing rate and not at the rate at which the original booking was made.

Cancellation Policy:

• 1. You can cancel your booking using the HOTSPOT website or mobile app.
• 2. The applicable refund amount will be credited to you within 7-14 working days. HOTSPOT reserves the right to debit from HOTSPOT Money account, in case of cancellation amount being higher than money already paid by you.

  3. Some Hotels do not accept bookings from unmarried couples; do not accept local id proofs. This information is available to the Guest prior to making the booking. For any cancellations or check-in denial associated with such bookings that are dishonored by the Hotel, HOTSPOT shall be under no obligation to refund any amount to the Guest.

  4. Hotels reserve the right to deny check-in where customers are unable to provide a valid government id or where minor Guests are travelling unaccompanied or if the Hotel is suspicious of the Guests check-in at its Property. Under all such cases HOTSPOT shall be under no obligation to refund any amount to the Guest.

• 5. You can find the cancellation policies at:
• Website:

• Mobile app:
• 6. For corporate bookings, the cancellation policy mentioned on your contract will apply.
• 7. In case no cancellation policy is mentioned on the Hotel details page, the following cancellation policy shall apply:
• A. For bookings up to 3 rooms:

• No Show: In case you do not show up at the Hotel, charges for the first night shall be deducted.
• Mid Stay Cancellations: In case you decide to shorten your stay any time post Check-In, you will be charged for one extra night as cancellation fee.
• B. For Bulk bookings (4 or more rooms):
• You need to pay at least 25% of the total booking amount as advance to make a booking for 4 or more rooms.

• No Show: In case you do not show up at the hotel, 25% of the total booking amount would not be refunded.
• Mid Stay Cancellation: No refunds are applicable in case you decide to shorten your booking after the check-in date.

Long Stay Bookings

For bookings of more than 7 nights, you have to settle all outstanding payments on a weekly basis. Further accommodation is subject to settlement of the outstanding amount.

Triple Occupancy Policy:

Some Hotels allow triple occupancy by providing an extra mattress for the third person for extra fee. However no extra bed is usually provided.

Visitors Policy

1. You should check with the Hotel for its Visitor Policy.
2. In order to maintain privacy of guests and the tranquility of the Hotel, HOTSPOT encourages its Hotel Partners to have a visitor policy where:

   a. Visitors are generally allowed to meet guests in the guest rooms during the day, except if there is an emergency.

   b. Visitors are not to be allowed to stay overnight.

   c. The Hotel front desk requires all visitors to present a government approved photo identity prior to accessing guest floors/rooms.

Child Policy

1. Stay of 1 child up to 5 years of age is complementary without the use of an extra mattress.
2. Breakfast charges may be applicable for the child.

Policy for Pets

Please check with the Hotel.

Code of Conduct:

1. Illegal activities are not permitted in any HOTSPOT Hotel.
2. You should be aware that the Hotel may refuse service or evict you
   a) For refusal or failure to pay for accommodation,
   b) If you act in a disorderly fashion as to disturb the peace of other guests,
   c) If you destroy, damage, deface or threaten harm to hotel property or guests,
   d) Any of your actions are deemed inappropriate by the Hotel.
3. Please keep the Hotel room in a good condition and maintain hygiene and cleanliness. You may be held liable for any damage to Hotel assets (except normal wear and tear).

Smoking, Drugs and Alcohol

1. Smoking is prohibited in HOTSPOT Townhouse. Some Hotels may prohibit smoking in their guest rooms so it is prudent to check with the Hotel Front Desk.
2. Anyone found using or under the influence of illegal drugs or substances classified under the Narcotic Drugs and Psychotropic Substances Act, 1985 will be reported to the police and asked to leave the Hotel. Any evidence or suspicion of drug use at the Hotel will also be reported immediately to the police.
3. Drinking alcohol is prohibited in all public areas including; in the Hotel’s lobby, hallways, and parking areas of HOTSPOT Hotels. Please contact the Hotel Front Desk regarding consumption of alcoholic beverages within your room, without disturbing the discipline of the Hotel or other guests.

Safety and Security

• 1. For your own safety, please follow fire safety and emergency response procedures as directed by Hotel staff.
• 2. HOTSPOT/Hotel are not liable for lost, misplaced, damaged or stolen valuables or belongings.
• 3. Keeping your safety in mind, a SOS button is provided which gets activated in the HOTSPOT app upon check-in. This SOS button can be used in case of emergency. The Screenshot of the same is provided below.

Contact Policies:

1. You may be contacted any time before your check-in date to confirm your arrival status/arrival time through calls or messages. If HOTSPOT does not receive a response from you after multiple attempts, your booking may be put on hold or cancelled. HOTSPOT will reinstate your booking when you contact us back or make a payment through our secure payment options, subject to availability.
2. As we continue to strive to improve our services, we may reach out to you for your feedback on your experience through calls or messages.
3. We might reach out to you for offers.

Beware of Fraud:

1. HOTSPOT does not authorize any of its employees, consultants, third-party vendors, associates to collect payment in any other form other than payments from secure HOTSPOT gateway and its affiliated OTA payment gateway links.
2. Any instances where collection of payment is attempted from any unauthorized payment gateways other than the ones mentioned above are acts of fraud. Encountering and acting on the same is solely on your own accord and discretion. HOTSPOT will not be responsible for any loss/liability arising out of such an event.

Insurance

1. Travel Insurance provided as a part of HOTSPOT’s services shall be as per the terms and conditions of the third-party insurance company, Acko General Insurance (hereinafter “Acko”). Acko coverage shall only be applicable for check-in to HOTSPOT Hotels, HOTSPOT Homes, HOTSPOT Townhouse and Collection O establishments on bookings made only via the HOTSPOT App, website, mobile website, direct bookings and/or walk-ins. The list of HOTSPOT establishments covered by Acko may be changed from time without any intimation to you. HOTSPOT merely acts as a facilitator in connecting you with Acko. Please contact Acko directly for any claims or disputes. HOTSPOT shall not be held liable in case of partial acceptance or denial of the claims by Acko and HOTSPOT has no role or liability in claims settlement.
2. It is clarified that a claim raised under the relevant insurance policy would act as a bar against any endorsement in the policy which would include but not be limited to changes relating to extension/curtailment of stay period and addition/deletion of guests covered under the policy.
3. For any assistance related to insurance, you can write on “support@hotspotgroup.in”

Contact HOTSPOT

While HOTSPOT works with our Hotel Partners to enable a comfortable stay, we recognise that you may have some concerns. If they are not addressed by the Hotel during your stay at the hotel, you may escalate the same to HOTSPOT. No complaint would be entertained post check out. For any assistance from HOTSPOT, please contact support@hotspotgroup.in.

Grievances

Email: support@hotspotgroup.in

Grievance Officer:Gaurav