1. Introduction

RepUp provides a Guest Experience platform including its concierge apps, marketing platform, survey platform and review analytics solution through a Software as a Service (SaaS) model. At RepUp the privacy and security of our customers, hotel guests and site visitors are of paramount importance. RepUp is committed to protecting the Personal Data shared with us. This Privacy Policy explains how RepUp processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and platform. Any information stored on RepUp’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. RepUp implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

2. General

2.1 This Privacy Policy applies to all the products, services, guest experience platform including its concierge apps, marketing platform, survey platform and review analytics solution through a Software as a Service (SaaS) model and websites offered by RepUp, except where otherwise noted.

2.2 Your privacy is important to us, therefore, we take the protection of your Personal Data very seriously. 2.3 Your Personal Data is sourced from publicly available sources and RepUp does not intend to or seek any private information.

3. Definitions

3.1 Guest: Any individual who interacts directly or indirectly with any platforms powered by RepUp or who is included as a contact in a User’s account.

3. 2 Personal Data: Personal Data may comprise of your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in RepUp products, and certain information about the company you are working for (company name and address). 3.3 Processing: Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3.4 User: An entity with which RepUp has an established relationship.

3.5 Visitor: An individual that visits our front-end website.

4. Collection and use of Personal Data

4.1 .General The following sections cover the specifics of each of the three groups from which data is collected: website Visitors, Guests and Users.

4.2 Website Visitors If you are a Visitor to our website only, and not a Guest to a client property or a user of our platform, then this section is relevant for you. By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible. RepUp may: collect, record and analyse information of Visitors to its website; Record your IP address and use cookies; Add information collected by way of pageview activity; Collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you register for events or sign up for information and newsletters; collect publicly available information about you from social media, if you provide RepUp with your social media details; and gather data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.

4.2.1 Purpose of processing personal data RepUp uses the collected Personal Data to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its website by analyzing how Visitors navigate its website.

4.2.2 Sharing personal data RepUp may share such information with service vendors or contractors in order to provide a requested service or transaction. Any Personal Data collected through the website is strictly kept for sales and hiring purposes and not shared with anyone beyond its original purpose. You have the right to request RepUp to delete your Personal Data stored with us.

4.2.3 Cookies Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. The use of cookies is widespread and benefits the surfer. For further information, see HTTP Cookies.

4.2.4 Links to other sites Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. RepUp is not responsible for the content or Privacy Policy of these other sites. RepUp does not control or take any responsibility for the confidentiality of Personal Data shared by you on third party website or web page.

4.3 Guests Guests should be aware that in interacting with our platforms e.g. through emails sent by our platform, by logging in to our apps and by filling surveys on our platform, they could be disclosing information that could make them personally identifiable to RepUp Users. The security and privacy protection implemented on RepUp’s platform does not cover this type of transfer or disclosure of Personal Data. Guests making the above interactions should be aware that only they are responsible for the privacy of their shared information and they should contact the hotel for any concerns arising due to this. For more detailed information concerning the protection of privacy when interacting with these platforms, Guests may contact the entity which provided them access to these platforms. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. RepUp will not process Personal Data of Guests for any purposes other than guest data analysis and profiling to be shared with its User processing the guest information. This information is kept strictly confidential and is not shared by RepUp. However, RepUp assumes no responsibility for the User misusing or sharing this data.

4.3.1. Inquires If you wish to inquire about your Personal Data that may have been collected in a RepUp platform, we recommend that you contact the entity that created or sent you the links for the platform. As RepUp is a Processor, it does not control the Personal Data used or stored in the survey, but processes it on behalf of its Users.

4.3.2. Guest Data RepUp collects data such as feedback, preferences, contact data and purchase data (through RepUp interface) from hotel guests. As a guest, you can view or delete this data by going to “My profile” section in the concierge link sent to you. We collect email addresses from the guest to give this information to the hotel for them to send transactional and promotional emails. RepUp does not use these emails directly in any form We collect preferences and feedback to improve service quality at the hotel you are staying in. Any personal data stored in the profile can be deleted by going to “My profile” section. Hotel guests can reach out to [email protected] for any inquiries related to their data being stored in RepUp systems.

4.4 Users

4.4.1. General In order to provide services to its Users, RepUp collects certain types of data from them. Furthermore, RepUp’s Users collect information from Guests when they interact with them using RepUp’s various platforms. This section will describe how these two types of data are collected and used by RepUp as well as geographical differences that effect this policy. Data entered or transferred into RepUp by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by RepUp without express consent from the User.

4.4.2 Collection of User data During a User’s registration and later on RepUp’s platform, they provide information such as name, company name, email, address, telephone, public URLs, competitor list and other relevant data. This information is used by RepUp to identify the User and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations. RepUp Users can at any time access and edit, update or delete their contact details by logging in with their username and password to RepUp’s platform. RepUp Users may create more Users with different privilege levels within their account. It is the responsibility of the User that creates other User accounts, to choose the level of access each User should have. Once these new Users log into RepUp, they meet the definition of User in this policy. RepUp will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

4.4.3 Collection of Guest data Guest data collected by the User by various means including that collected from PMS, CRS, Channel Manager, Booking Engine, and directly from the Guest is the responsibility of the User. RepUp only processes such data and generates analytics over it. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. RepUp will not process Personal Data for other purposes or by other means than instructed by its Users. Guest data includes data from individuals uploaded, transferred or manually entered by a RepUp User into their account for the different purposes as decided by the User. Personal Data may include, personal contact information such as name, home address, home telephone or mobile number, email address, information concerning family, lifestyle and social circumstances including age, date of birth, marital status, number of children, employment details, education/qualification, business contact details, gender, religion, race, health detail and other sensitive Personal Data. Answers to questions by Guests and interaction with the User, may also include Personal Data. The purpose of collecting Personal Data as part of the platform will vary depending on the RepUp products being used by the User. As RepUp provides its platforms to a wide group of customers and businesses, the purpose may vary greatly. For Users in the EEA, or for Users interacting through Repup’s platforms to Guests in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by RepUp’s User.

5. Retention and deletion

RepUp will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Guest data, RepUp’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Guest data, Users with an active account will therefore have the responsibility to delete data when required. When a Users’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.

6. Your Rights

Generally RepUp Users have control of the purpose for collecting Personal Data. However, You have certain legal rights to obtain information about whether we hold any Personal Data about you, to access Personal Data we hold about you, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. Your principal rights are as follows:

6.1 Right to access, rectify or delete your information: You have the right to request RepUp to access, rectify or delete your Personal Data stored with us. You can ask us to verify whether we are processing Personal Data about you. You can ask us to rectify our records if you believe they contain incorrect or incomplete information about you. Lastly, you can ask us to delete your Personal Data if you withdraw your consent or when we no longer need it for the purpose it was originally collected for. How to access, rectify or delete your Personal Data: You can access, rectify or delete your Personal Data by sending your queries at [email protected]

6.2 Right to restrict processing: You have the right to restrict processing of your Personal Data in circumstances where: you contest the accuracy of Persona Data; prefer to restrict its use rather than having us erase it; you believe we no longer need the Personal Data for the purpose of processing, but you require Personal Data for establishment, exercise or defence of legal claims; you have objected to processing, pending the verification of that objection. Please note that RepUp will duly inform you before lifting the restriction of processing. How to restrict processing: You can restrict processing of your Personal Data by sending your queries at [email protected]

6.3 Right to object to processing You have the right to object to our processing of your Personal Data on grounds pertaining to your particular situation, but only to the extent that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims. How to make an objection: You can object to processing of your Personal Data by sending your objections at [email protected]

6.4 Right to object to processing for direct marketing purpose: We may contact you via email to inform you about new products and Services. However, you have the right to object to our processing of your Personal Data for direct marketing purposes including profiling. If you make such an objection, then we will cease to process your Personal Data for this purpose. How to make an objection: You can object to processing by sending your objections at [email protected] or You can select the opt-out link given in each email invitation.

6.5 Right to object for scientific or historical research purposes or statistical purposes: You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. How to make an objection: You can object to processing by sending your objections at [email protected].

6.6 Right to data portability: Where you have provided Personal Data to us, you can ask us to transmit that Personal Data (in a structured, commonly used, and machine-readable format) directly to you or to another company if is technically feasible.

6.7 Right to erasure: You have the right to erase/ delete your Personal Data without undue delay in circumstances where: Personal Data is no longer necessary in relation to the purpose for which they were collected or processed; you withdraw consent on which processing is based; you object to the processing under certain data protection rules; processing is for direct marketing purposes and the Personal Data have been unlawfully processed; Personal Data has to be erased for compliance with a legal obligation. Please note that there are certain exclusions of the right to erasure. Such exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. How to delete your Personal Data: You can delete your Personal Data by: sending your request at [email protected] or Logging into your account and deleting your Personal Data.

6.8 Right to withdraw consent You can withdraw your consent or terminate your account any time. Withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. You can withdraw your consent by: Logging in to your account and deleting your account; or Sending your request at [email protected] or Selecting the opt-out link given in each email invitation. If you withdraw your consent, you will not receive any further invitations from us. RepUp will only retain your Personal Data for the establishment, exercise or defence of legal claim. Even after you withdraw your consent, RepUp will continue to protect such Personal Data in accordance with this Privacy Policy.

6.9 Right to complaint to a supervising authority If you consider that our processing of your Personal Data infringes data protection laws, you have a legal right to lodge a complaint with a responsible authority responsible for protection of your Personal Data. The responsible authority for processing of your Personal Data is: RepUp (Piquor Technologies Pvt Ltd), AltF Coworking, Suncity Success Tower, Sector 65, Gurugram, Haryana, India – 122101 [email protected]

7. Acceptance of these Conditions We assume that all Visitors of our website, Guests to platforms powered by RepUp and users RepUp’s platform have carefully read this document and agree to its contents. If someone does not agree with this Privacy Policy, they should refrain from using our website and platform. We reserve the right to change our Privacy Policy as necessity dictates. Continued use of RepUp website and platform after having been informed of any such changes to these conditions implies acceptance of the revised Privacy Policy.

8. Our Legal Obligation to Disclose Personal Data We will reveal a user’s Personal Data without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to RepUp or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose Personal Data when we have good reason to believe that this is legally required.

9. RepUp’s Data Protection Officer RepUp has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address: RepUp (Piquor Technologies Pvt Ltd), AltF Coworking, Suncity Success Tower, Sector 65, Gurugram, Haryana, India – 122101 [email protected] 10. Refund Policy RepUp has a no refund policy. 11. For Further Information If you have any further questions regarding the data RepUp collects, or how we use it, then please feel free to contact us by email at: [email protected] or in writing at: RepUp (Piquor Technologies Pvt Ltd), AltF Coworking, Suncity Success Tower, Sector 65, Gurugram, Haryana, India – 122101 RepUp follows zero tolerance policy for objectionable content or abusive users. Such behaviour may lead to account suspension.