Last Updated in March 2020
1. Collection - We may collect information about you, such as your name, phone number, email address, and credit card details through your use of the Site.
2. Use - We may use your information to provide the requested services, maintain and improve the Site, and send you marketing communications.
3. Mobile Devices - With your consent, we may send you push notifications with information about your reservations and GRH programs of your choosing.
4. Sharing - We may share your information with suppliers, service providers, and our affiliates.
5. Country-Specific Privacy Rights - Depending on your country of residence, you may have rights to request information from us including how we share certain categories of your information with third parties.
7. Opting out of Marketing Emails - You may opt-out of GRH's email marketing communications by using the unsubscribe link in our marketing emails or by changing your account settings.
8. International Transfers - We maintain appropriate protections for cross-border transfers as required by law for international data transfers.
9. Information from Other Partners - We may collect information from affiliated entities, business partners, or other third party providers and you may opt-out of this collection.
10. Security - We maintain reasonable security measures to protect your information and require our service providers to do the same.
11. Data Subject Rights - You may exercise certain rights of access, correction, deletion, portability, or object to certain processing of your information.
13. Third Party Links - We may provide links to Third Party Websites that are not owned or controlled by us, and are governed by separate user terms and privacy statements.
1. Information We Collect
We collect information about you that you provide to us when using the Site, such as your name, address, phone number, credit card details, e-mail address, accommodation name, accommodation location and/or length of stay, and your GRH account password for accommodation reservations. In addition for flight reservations, we may also collect guest name, date of birth, nationality and passport details including passport number, country of issue and expiry date.
By visiting our Site, we may also automatically collect certain usage information, such as your IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device's operating system, application version, language settings, and pages that have been shown to you. If you are using a mobile device to access our mobile app or mobile optimized Site, we might also collect information that identifies your mobile device, such as the device ID, location of the device (with your consent), and device-specific settings and characteristics.
If you participate in our GRH program, there may be limited additional information that we may collect from the accommodation about your stay; for example, see the information below collected as part of the GRH program. When you make a reservation, our system registers through which means and from which websites you have made your reservation. We may also collect certain information through cookies, tags, and similar technologies as detailed below.
If you need to get in touch with our customer support team, or reach out to us through other means (such as through social media, or communicating with your accommodation through us), we will collect information from you there too.
Where you submit reviews regarding your accommodation or other ancillary services available on our website through us, we will collect information from you included in your reviews, including your first name and country of residence.
You can decide to participate in our referral programs or other promotions, and doing this will also mean providing us with personal data. In addition to that, you can provide us with feedback or ask for help with using the Sites or our various communications platforms.
Accommodation partners may share information about you with us too – this may happen if you have questions about your pending booking or if disputes arise regarding your booking.
The GRH Program
Where required by law, we rely on the following legal bases to process personal information:
Necessity to Perform Contract with You - we need to process your information in order to provide our reservation services to you, answer questions and requests from you, and provide customer support;
Our Legitimate Interests - we process your information for security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; to customize and provide our reservation travel services to you; and to respond to lawful requests, court orders, and legal process;
Compliance with Legal Obligations - we need to process your information to comply with relevant laws and regulatory requirements;
Protect Vital Interest - we may need to process your information in case of emergency involving an individual's life or health.
2. How We Use the Information We Collect
We may use information collected through the Site to:
Provide you with the requested services, such as creating a user account, processing and confirming your reservation, and communicating with you about services requested (e.g., pre-reservation or post booking chat support (excluding credit card number), special request, cancellations, rewards
Send you email marketing communications about products and services that may be relevant to you
Conduct surveys or provide you with information about our services on our Site or on other websites you may visit
Maintain and improve the Site, tailor the user experience, and for internal training
Protect the security of you and the Site
Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands
When you make a reservation on one of our business partners’ websites or apps, we may also receive certain information such as your name and reservation information, including the accommodation reserved, in order to process your reservation and identify which channel your reservation has originated from.
During calls with our customer support team, live listening may be done or calls may be recorded for quality and reference purposes which includes the usage of the recordings for the handling of claims, training and fraud detection purposes. If you would prefer that your call was not recorded, you can opt out by stating this, or by hanging up. Call recordings are kept for a limited amount of time and automatically deleted thereafter, unless GRH has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.
If you have not finalized a reservation online, we may send you a reminder to continue with your reservation. We believe that this additional service is useful to you because it allows you to carry on with a reservation without having to search for the accommodation again or fill in all the reservation details from scratch. You may opt-out of receiving these reminders as detailed below under "Opting Out of Marketing Communications from Us."
Please note that the confirmation emails and text messages sent after your booking, as well as the guest review emails sent after your departure, are not marketing messages. These messages are part of your accommodation reservation process. Respectively, they contain information for you to check in at your booked accommodation, and tools to optionally rate that accommodation after your stay. You will continue to receive them, even if you have opted out of our marketing messages. Similarly, opting into receiving Price Alerts will not affect any other choices you have made regarding receiving communications from us. If you elect to receive Price Alerts, you will be able to opt out of receiving the same by clicking on the “turn off price alerts” or a similar message found in the Price Alert sent to you.
If you have selected a Mix and Save offer but look to have only finalized part of the offer (e.g. only finalized the booking for one but not both rooms), we may send you an email confirming you selected Mix and Save and to remind you to complete all bookings for your selected Mix and Save offer. This message is part of the Mix and Save booking process confirming your selection and in case you have overlooked completing all bookings. In addition to this, we may also send you a pre-check in email reminding you about changing rooms during your stay at the accommodation.
As mentioned above, if you are completing the booking for another person who will stay at the reserved accommodation, you also have the option to insert the guest’s email address for the purpose that the guest will receive the reservation confirmation and a separate invitation to complete a guest review.
Communications on the Site
We offer you and accommodation partners various means to communicate about accommodations and existing reservations, directing the communications through the Site. You can contact us with questions about your reservation or about your accommodation via the Site, and via other channels that we may make available.
We may access communications and may use automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you or, accommodation partners, us, or others. Note, all communications sent or received using the Site’s communication tools will be received and stored by us. Business partners through whose platform you made the reservation and accommodation partners may choose to communicate with you directly via email or other channels that we do not control.
3. Mobile Devices
With your consent, we may send you push notifications with information about your reservation, potential future stays, or as part of any GRH programs that you participate in, including coupons. You may grant us access to your location information or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such information or the receipt of (or opt out of receiving) push notifications (including Software Development Kit ("SDK") and push token data). Different device operating systems may have different default settings, so please familiarize yourself with such settings governing push notifications.
4. Sharing Your Information
In connection with your visit to our Site and use of our services, we may share your information as follows:
Travel Suppliers such as accommodation properties (e.g., the specific accommodation that you have requested us to reserve) and/or third party accommodation supplier, airline, car rental, insurance, and, where available, activity providers, who fulfil your travel reservations. These suppliers may contact you as necessary to obtain additional information about you, facilitate your travel reservation including communicating with you prior to arrival about your upcoming stay, or respond to a review you may submit in accordance with their own independent privacy policies.
Third Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process personal information for purposes such as credit card and payment processing, business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your personal information with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
Our Affiliated Group Companies - our affiliated (group) companies' employees who have access to this information with our permission and who need to know or have access to this information to perform the service requested by you (including customer services) and internal (audit/compliance) investigations.
Where Required or Permitted by Law - such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of GRH, our users, or others.
Business Reorganization - such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.
Our Site uses and allows third parties to place cookies (session and persistent), pixels/tags, SDKs, application program interfaces ("APIs"), and other technologies (collectively, "Cookies") on our Site that collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the Site to you, such as to keep you logged in while your visit our Site, while other Cookies are used to provide you with a better user experience, such as:
Perform website analytics, such as impression reporting, demographic reporting and interest reporting. This may include the recording of mouse clicks, movements, page scrolling and restricted text entered into our Site forms through selected third parties but we will take sufficient precautions to ensure that personal information will not be collected during such recordings e.g. through the adoption of irreversible masking. Website analytics is used to improve our Site and services; and
To provided you advertising tailored to your interest (see below for details)
Interest Based Advertising
We may also allow certain third parties to place Cookies on our Site in order to collect information about your online activities on our Site (e.g., pages visited on the Site and searches you performed) and over time and across different websites you may visit. This information is used to provide advertising tailored to your interests from us (via email, on our Site, and on other websites) and by third parties on other websites you may visit, also known as interest based advertising, and to analyze the effectiveness of such interest based advertising. We may also share one-way hashed information with third party partners (e.g., Facebook) who may combine hashed information with other identifiers in order to serve custom GRH advertisements on other websites or mobile apps based on your prior visits to the Site. GRH neither supports nor endorses the goals, causes, or statements of any websites or mobile apps that display our advertisements.
We may also combine information collected through Cookies and certain usage information from a particular browser or mobile device with another computer or device that may be linked to you (cross-device tracking) in order to optimize our services and provide tailored GRH communications and advertisements to you. If you do not want GRH to combine such information for its optimization of communications to you please unsubscribe from the GRH communications i.e. the newsletter.
Please review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.
To learn more about certain Cookies used for interest based advertising (including through cross-device tracking) and to exercise certain opt-out choices you may have regarding Cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or for our mobile app, by updating your device settings or downloading the AppChoices app.
Please also visit the following third parties' websites to exercise certain opt-out choices over
Google Analytics - https://tools.google.com/dlpage/gaoptout?hl=en
Appsflyer (mobile app analytics) - By emailing appsflyer at: firstname.lastname@example.org
Baidu - http://www.baidu.com/duty/safe_control.html
Apple - https://support.apple.com/en-us/HT202074
Facebook - https://www.facebook.com/ads/settings
Google Ads - https://adssettings.google.com/
Criteo - https://www.criteo.com/privacy/
Mouseflow recording - https://mouseflow.com/opt-out/
SecuredTouch - https://www.securedtouch.com/privacy/
By exercising such choice regarding interest based advertising, you may still receive advertisements, but the network from which you opted out will no longer deliver ads tailored to your interests. You should also know that logging out of your user account will not actually mean that you opt out of personalized advertisements.
You may need to make such choices on each browser and device you may use to exercise choice regarding certain Cookies. Lastly, at this time the Site is not configured to honor browsers' "Do Not Track" signals, except where required by applicable law.
6. Opting Out of Marketing Communications from Us
You can opt out of receiving marketing communications from us at any time by using the "Unsubscribe" link in each newsletter or communication, or through your GRH account (if you've created one) - the email subscriptions settings is under "Profile".
7. International Transfers
In connection with the purposes described above, your information may be stored in locations outside of your home country, which may have different standards of data protection than your home country. We provide appropriate protections for cross-border transfers as required by law in our jurisdiction for international data transfers, including information transferred to third parties.
8. Information from Other Partners
On occasion, affiliated entities, business partners, or other third party providers may share information with us. One example is if you access or sign in to our Site through social media, such as Facebook Connect, we may collect information from you such as your username, and other information made available to us via such services. In general, your ability to provide such information is through the service provider themselves and you can change those settings in your account settings of the relevant service provider. In general, we may work with our partners to improve and personalize your use of our website in accordance with this policy.
9. Protecting Your Information
We maintain reasonable physical, electronic, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. We use Secure Socket Layer technology to encrypt credit card information during transit. Through your personal account, you also have the ability to save credit card details for faster future bookings and payments. Your card details are encrypted and you can always log in to your personal account to delete, edit, or add certain credit card details. For security reasons, the number cannot be edited (but the card details can be deleted). When viewing card details, only the last 4 digits of the number will be visible. Please note that we will store the last 4 digits of your credit card securely upon any booking made (this is required to manage any refund requests for that booking).
10. How You Can Access or Change Your Information
You can easily correct your account name, the booking holder name (subject to the cancellation policy attached to the booking) and contact number at any time by signing in to your account on the website. Alternatively, please contact us via our Customer Support page or at email@example.com to exercise any of the following rights:
Access: You are entitled at any time to obtain information about your personal information that we store, in accordance with applicable law and without any fee. However, in exceptional cases we ask you to pay reasonable fees before we provide the information if permitted by applicable law.
Rectification: You may request that we rectify any of your personal information that is incomplete or incorrect.
Deletion: You may request that we delete your account.
Restrictions of Processing: You may ask us to cease processing of your personal information for example if you have objected to the processing and the existence of legitimate grounds is still under consideration.
Objection: You may object, at any time, to your personal information being processed for direct marketing purposes.
Right to Revoke Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn.
Data Portability: If applicable, you may request us to send you your personal information which we store, in a commonly used and machine readable format which shall be decided at our sole discretion.
To protect your privacy and security, we will verify your identity before responding to such request, and your request will be answered within a reasonable time frame. We may not be able to allow you to access certain personal information in some cases e.g. if your personal information is connected with personal information of other persons, or for legal reasons. In such cases, we will provide you with an explanation why you cannot obtain this information. We may also deny your request for deletion or rectification of your personal information due to statutory provisions, especially those affecting our accounting processes, processing of claims, for fraud detection or prevention purposes, and mandatory data retention, which may prohibit deletion or anonymization.
12. Links to Third Party Websites
13. Additional Considerations
A Special Note About Minors
Our Site is not directed to minors under the age of 18. However, minors can normally accompany their parent(s) or legal custodian(s) who have booked an accommodation, unless prohibited by an accommodation property's policies.
14. Contacting Us
16-05, Tower B, Vertical Suite II, Avenue 3, Bangsar South City, 59200 Kuala Lumpur