Introduction to this Privacy Notice

Divya Sutra Plaza and Conference Centre Calgary Airport cares about privacy issues and wants you to be familiar with how we collect, disclose, and otherwise use (“Process”) information about you. This privacy notice (“Privacy Notice”) describes our practices in connection with the information we collect through our websites (the “Websites”), social media pages that we control (“Social Media Pages”), and software applications that we make available for use on or through computers and mobile devices (the “Apps”), that include a link to this Privacy Notice, and through any of our offline activities, such as when you provide your information on the telephone via our call centers or in person (“Offline Activities”) (collectively, including the Websites, Apps, Social Media Pages, and Offline Activities, the “Services”).

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, such that our practices may be more limited in such jurisdictions.

Please read the following to learn more about our privacy practices.

What Information Is Collected and How It Is Collected?

1. We may collect “Personal Information” (information that identifies you or relates to you as an identifiable person) about you such as your:

• Name
• Postal address (including billing and shipping addresses)
• Phone number
• Email address
• Credit card details
• Financial information in certain circumstances
• Social media account information
• Stay or trip information and preferences, such as your preferred location/facilities, dates and number of people/children traveling with you
• Special needs or conditions that may impact your stay
• Driver’s license, government-issued ID, or passport
• Geolocation information
• Communication, product, service or other preferences
• Demographic information
• IP address
• Account or Membership ID

2. We may collect information from you when you interact with us, such as when you:

• Register for, use, or make a payment for a product or service
• Contact us with a question or request
• Use our Services
• Make a reservation
• Stay at one of our properties
• Provide a testimonial or story, or submit a review or comment
• Participate in a competition, promotional activity or sweepstakes
• Participate in any loyalty or other programs
• “Like,” “Follow” or otherwise connect with or post to one of our Social Media Pages

3. Other information we collect about you:

We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities, and to improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may, in turn, use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.
As aggregated or anonymized information does not constitute Personal Information, we may use it for any purpose. If we combine anonymized or aggregated data with Personal Information, we will treat the combined information as Personal Information according to this Privacy Notice.

As aggregated or anonymized information does not constitute Personal Information, we may use it for any purpose. If we combine anonymized or aggregated data with Personal Information, we will treat the combined information as Personal Information according to this Privacy Notice.

4. Why and How We Use Your Information

We may Process Personal Information in connection with any of the following:

1. Our business transactions with you, including, but not limited to:
   • To enter into or perform a contract with you
   • To respond to your inquiries and fulfill your requests
   • To send administrative information to you, for example, information regarding the Services or an event in which you are attending
   • To complete and fulfill any purchases or requests for services
2. For our legitimate business interests, including, but not limited to:
   • To personalize your experience on the Services by presenting products and offers tailored to you
   • To allow you to participate in sweepstakes, contests, and similar promotions, and to administer these activities (each of which may have additional rules and could contain additional information about how we process your Personal Information)
   • To facilitate social sharing functionalities of your social media account(s)
   • To carry out data analysis, audits, fraud monitoring, and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, helping enforce compliance with our Terms of Use, helping protect our Services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities
   • Subject to your marketing preferences (which may include consent to marketing under applicable law), to send you newsletters or marketing communications we believe may be of interest to you, for our products and services, and on behalf of our Affiliates or selected third parties, via postal mail, email, telephone or text messaging
   • To allow you to send messages to a friend through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address
   • You have the right to decline to provide your consent and, if consent is provided, to withdraw your consent at any time.
3. As necessary or appropriate for legal reasons, including, but not limited to:
   • Under applicable law
   • To comply with the legal process
   • To respond to requests from public and government authorities, including those outside your country of residence
   • To enforce our terms and conditions
   • To protect our operations or those of any of our Affiliates or other third parties
   • To protect our rights, privacy, safety or property, or that of our Affiliates, you, or other third parties
   • To allow us to pursue available remedies or limit damages we, our Affiliates, or other third parties, may sustain

5. When We Disclose Your Information

We may disclose your information as follows:

• Affiliates: To any other entity that is, at the time you disclose your Personal Information, directly or indirectly controlled by, or under common control with us (“Affiliates”) for the purposes described in this Privacy Notice, including under “Why and How We Use Your Information” unless otherwise prohibited by applicable law. You can find more information about our primary operating Affiliates in our Annual Report as of the date the Annual Report was published or by contacting us at the contact information set forth below in the section titled “How Can You Contact Us?”.
• Vendors and Service Providers: We may disclose your information to vendors and service providers we retain in connection with our business such as travel services companies, financial services companies, vacation insurance companies, website hosting, data analysis, payment processing, order fulfillment, information technology, and related infrastructure provision, customer service, email delivery, credit card processing, tax and financial advisers, legal advisers, accountants or auditing.
• Business Partners, Sponsors, and Other Third Parties: We may disclose your Personal Information to business partners, co-sponsors of promotions, and other third parties in order to provide you with services that may be of interest to you. For example, we may share your Personal Information with the owners and operators of affiliated and unaffiliated hotels and resorts, airlines, car rental services, retail stores, credit agencies and other third parties to facilitate reservations, to offer you products or services, or in connection with our loyalty program or a loyalty program of one of our partners. We may also co-sponsor promotions, sweepstakes, or other events with a third party and may share your Personal Information in connection with these events. Further, we may share your Personal Information with third party providers located on-site at hotels or resorts, such as timeshare, spa, golf, concierge, and dining providers. If you provide additional information to any of these third parties, such information will be subject to such third parties’ privacy practices.
• Third Parties: Subject to your marketing preferences (which may include consent to marketing under applicable law), we may license, sell, or otherwise share your Personal Information with selected third parties for compensation for their business purposes. Such third parties may include timeshare organizations. Once we share your Personal Information with a third party for such purposes, the information shared becomes subject to such third party’s privacy practices.
• Message Boards: We may make reviews, message boards, blogs, and other such user-generated content facilities available to users. Any information disclosed in these areas becomes public information, and you should always be careful when deciding to disclose your Personal Information. We are not responsible for the privacy practices of other users, including website operators, to whom you provide information.
• Merger or Acquisition: We may disclose your Personal Information to a third party who acquires any part of our business or the business of any of our Affiliates, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets.
• Disclosure Permitted by Law: We may disclose your Personal Information to law enforcement authorities, government or public agencies or officials, regulators, and/or to any other person or entity having appropriate legal authority or justification for receipt of your information, if required or permitted to do so by law or legal process, to respond to claims, or to protect our rights, interests, privacy, property or safety, and/or that of our Affiliates, you or other third parties.

6. How Do We Safeguard Your Information?

• Security of Your Information: We will take reasonable steps to protect the information you provide us from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have implemented appropriate physical, electronic, and managerial procedures to help safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Unfortunately, no security system is 100% secure. Thus we cannot ensure the security of all information you provide to us via the Services.

7. Other Important Information

• Information Provided on Someone Else’s Behalf: If you provide us with information about someone else, please ensure you have the person’s permission to do so for the purposes detailed in this Privacy Notice.
• Links to Websites: The Services may have links to other websites that are not operated by us. We have no control over how these websites may collect your information and no liability for the practices, policies, and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them.
• Social Media Sites: Please note that we are not responsible for the collection, usage and disclosure policies and practices (including data security) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
• Changes to Our Privacy Notice: From time to time we may revise this Privacy Notice and/or use Personal Information for new, unanticipated uses not previously disclosed to meet changes in the regulatory or business environment, or to satisfy the needs of our customers and service providers. Updated and date stamped versions will be posted on the Services. Unless otherwise required under applicable law (e.g., obtaining consent from you for the relevant material changes), the revised Privacy Notice will take effect immediately upon such posting.
• Minors: We do not knowingly collect, maintain or use Personal Information from individuals under 18 years of age in connection with, and no part of our Websites, Social Media Pages, and Apps is directed to individuals under the age of 18. If we do incidentally collect or maintain Personal Information from individuals under 18 years of age, you may request the deletion of such information by contacting us as set forth under “How Can You Contact Us?” below.
• International Transfers: We are an international company and we may, subject to applicable law, transfer your information to our Affiliates or selected third parties outside the country where you are located and where information protection standards may differ (e.g., your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your Personal Information, such as an adequacy decision by the European Commission, Model Clauses, or other applicable adequacy mechanisms. If you would like further detail on the safeguards we have in place, you can contact us directly as outlined in “How Can You Contact Us” below.
• Retention Period: We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a more extended retention period is required or permitted by law.

8. Your Choices and Rights

• Changes to Your Marketing Preferences: You can opt-out from receiving future marketing communications from us at any time by:
  • Using the unsubscribe function in the email you receive from us; or
  • Contacting us as set forth under “How Can You Contact Us?” below.
• Withdrawing Your Consent: You may withdraw any consent that you have provided to us to process your information at any time.
• Accessing your Information: In accordance with applicable law, you may access the Personal Information we Process about you.

Any request to access or obtain copies of your Personal Information must be made in writing by contacting us as set forth under “How Can You Contact Us?” below. We may, depending on the applicable law in your country, be entitled to charge a nominal fee to cover some of our administration costs in connection with the provision of such information. We may also ask you to verify your identity and to provide further details relating to your request.

• Correcting your Information: We will take reasonable steps to ensure the accuracy of the Personal Information we retain about you. It is your responsibility to ensure you submit true, accurate, and complete information to us and timely update us in the event this information changes. You may request that any inaccurate or incomplete Personal Information held by us or on our behalf is corrected by contacting us as set forth under “How Can You Contact Us?” below.
• Deleting your Information: Under certain circumstances, you may request we delete Personal Information we hold about you by contacting us as set forth under “How Can You Contact Us?” below. We will assess your request and determine, under applicable law, whether we are required to delete this information.
• Objecting to Processing: If you would like us to stop processing your Personal Information, you can request this by contacting us as set forth under “How Can You Contact Us?” below. We will assess your request and determine, under applicable law, whether we have any justification for the continued Processing.
• Transferring your Information: Under certain circumstances, you may receive your Personal Information in a format that allows you to send it to another company or to direct us to transfer it directly to another company.

9. How Can You Contact Us?

• Contact Information: If after reviewing this Privacy Notice, you have any questions, complaints or privacy concerns, or would like to make any requests in relation to your Personal Information, or obtain further information on safeguards used for international transfers, please send an email to info@kudosholding.com or send a letter to:

Divya Sutra Plaza and Conference Centre Calgary Airport

3515 26 St NE,
Calgary, AB T1Y 7E3
Canada

Attn: Legal Privacy

If you have a complaint or concern about how we are processing your Personal Information, then we will work to address such concern(s). You may also direct your complaint/concern to the applicable data protection authority.