OYORooms Privacy Notice

OYORooms is committing 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.

Policy last updated: 21 November, 2018.

1. Information about OYO

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

Depending on where and how you interact with us (e.g. by using our app or website) different companies within OYO will process your information. You can find out more about the OYO companies that handle your information, including which company makes decisions about how your information is handled, by contacting us.

2. 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. We may give you additional privacy notices from time to time if required for specific interactions.

This privacy notice applies to individuals who acquire rights to make use of our products and services, such as when a user signs up with OYO, modifies their account, requests value-added services, contacts customer support, or otherwise communicates or interacts with OYO.

It describes how we handle your information, regardless of the way you contact us (e.g. app, website, email, phone 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/website, we may explain how that functionality uses your information.

3. Ways in which we obtain personal information

We obtain personal information from you and from our other products and services used by you.

We obtain personal information from you through your interactions with us, including by telephone, by email, via our websites, via our apps, via any form of written communication or face to face.

We also obtain your personal information from our other products and services used by you, for purposes set out in Clause 5.

4. Categories of personal information

We process two categories of personal information about you 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 or have chosen a language preference for product optimisation or ease of use).
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 OYO account], your profile picture; [country of residence, age, date of birth].
  • Location Information: We may derive your approximate location from your IP address and global positioning system so that we can authenticate your access to our app/website.. This will mean that we collect the precise location of your device when the app/website is running both in the foreground and the background.
  • Transaction Information: We collect transaction details related to your use of our products and services, e.g. type of value-added service requested, date and time the service was provided, amount charged and other related transaction details.
  • Account History:We collect details of your interactions 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 or other 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.
  • Call and SMS Data: We make it easier for you to contact your 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 also collect personal information about you by monitoring your access to our premises.
  • WiFi: If you use WiFi offered at our accommodation, we will collect login information (which may include your email) and usage information that tells us how you use the WiFi.

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 health may be revealed by special requests for assistance or disability-friendly place of work or if you require medical assistance during your working hours; 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.

5. 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 “+”[insert hyperlink to section below]. 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 accessing the app or website via login, 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 accessing the app or website
  • necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract;
  • in our or a 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;
  • 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 place of work, 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 defence of a legal claims

6. Legitimate interests

We process your personal information for a number of legitimate interests, including providing you with products and services for use, 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, send service communications, facilitate payments, send receipts and provide customer support;
  • to administer our relationship with you, our business and our third-party providers;
  • to ensure that you can interact with us securely, e.g. we authenticate users;
  • to improve our services and develop new features for the OYO app, website and offering, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends;
  • to send you marketing that we think will be of interest to you and to personalise your experience of us (in each case as permitted by law), including to provide or recommend features, content, social connections, , and advertisements. You can opt-out of marketing at any time by ●
  • 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 OYO, 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 OYO business.

7. Marketing and Preferences

We may 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@oyorooms.com to update your contact preferences. You may also object to profiling relating to direct marketing by contacting us at dataprotection@oyorooms.com.

8. Analytics and Advertising Services Provided by Others

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

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

9. Sharing your information

We share your information within the OYO Group and with others who help us provide services.. We also share your information in accordance with the law. For more information on who 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 OYO Group;
  • third party suppliers who help deliver products or services on our behalf, or who have partnered with OYO 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;
  • 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 where we (or any member(s) of the OYO Group) sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • third parties in connection with any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of the OYO 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.

10. Transfers outside of your country

OYO uses global information systems. As a result, OYO transfers your personal information to a country outside of your country and the European Economic Area ("EEA", i.e. EU member states including Norway, Liechtenstein and Iceland) to India and Singapore for the purposes set out in this policy. Not all countries outside of the 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.

OYO 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 [dataprotection@oyorooms.com].

11. Retention period

In general, we will keep your information in accordance with OYO’s records retention policies. However, there may be circumstances that mean we must retain your personal information for longer..

[We keep your information in accordance with OYO’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 our products or services provided for use to you;
  • 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.

12. Your rights

Data protection laws in the EEA and some other countries provide individuals with rights in relation to the information that OYO 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 erasure ('right to be forgotten'): The right to have certain personal information about you erased.
  • 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).
  • 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 are not able to 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 dataprotection@oyorooms.com.

13. 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 dataprotection@oyorooms.com.

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