Privacy Policy

HAPPY LODGINGS

Effective Date: 22 March 2015
Last Updated: 1 April 2025

1. INTRODUCTION

This Privacy Policy explains how Felda Rental Services Private Limited, operating under the brand name Happy Lodgings (“Happy Lodgings“, “Felda Rental Services“, “Company“, “we“, “us” or “our“), collects, uses, stores, discloses, transfers and otherwise processes Personal Data in connection with the Happy Lodgings website, platform and related services.

We recognise the importance of privacy and are committed to handling Personal Data responsibly and in accordance with Applicable Data Protection Law.

Where applicable to our Processing activities, this includes Regulation (EU) 2016/679 of the European Parliament and of the Council, commonly known as the General Data Protection Regulation (“GDPR”).

This Privacy Policy is intended to provide information about:

• the Personal Data we collect;
• how and why we Process Personal Data;
• the legal bases on which Processing may take place;
• how Personal Data may be shared;
• international transfers of Personal Data;
• how long Personal Data may be retained;
• the rights available to individuals under Applicable Data Protection Law;
• the security measures applied to Personal Data; and
• how to contact us regarding privacy-related matters.

Please read this Privacy Policy carefully before using Happy Lodgings.

2. WHO WE ARE

Happy Lodgings is operated by:

Felda Rental Services Private Limited

Registered Address:
26, Second Floor, Building Number 6
Badarpur
New Delhi – 110044
India

Website: Happy Lodgings

Privacy Contact Email:
[email protected]

For the purposes of this Privacy Policy, Felda Rental Services Private Limited is generally responsible for determining the purposes and essential means of Processing Personal Data in connection with the operation of Happy Lodgings where it acts as a Controller.

The precise role of the Company in relation to a particular Processing activity may depend upon the factual circumstances and the nature of the service involved.

3. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to Personal Data Processed in connection with the Happy Lodgings website, platform and related services.

It applies to, among others:

• Hosts;
• Property Owners;
• subscribers;
• Guests and prospective Guests;
• website visitors;
• individuals submitting enquiries;
• account holders;
• individuals contacting customer support;
• individuals receiving communications from us; and
• other identifiable individuals whose Personal Data we Process in connection with our services.

This Privacy Policy applies to Personal Data Processed by or on behalf of Happy Lodgings.

It does not automatically apply to the independent privacy practices of:

• Hosts;
• Property Owners;
• independent third-party service providers;
• payment service providers;
• third-party websites; or
• other organisations that may independently determine the purposes and means of Processing Personal Data.

4. DEFINITIONS

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below.

Where a term has a specific meaning under Applicable Data Protection Law, including the GDPR, that statutory meaning shall apply to the extent required by the relevant law.

Unless the context requires otherwise, references to the singular include the plural and vice versa.

4.1 “Applicable Data Protection Law” or “Applicable Law”

“Applicable Data Protection Law” or “Applicable Law” means any applicable law, regulation, legally binding requirement or enforceable rule relating to privacy, Personal Data, data protection, electronic communications, Cookies or the Processing of Personal Data.

Depending on the relevant Processing activity, this may include:

• the GDPR;
• applicable laws and regulations in India;
• applicable data protection laws in jurisdictions where users are located; and
• other applicable privacy, electronic communications and information security laws.

The applicability of a particular law depends on the circumstances of the relevant Processing activity.

4.2 “Personal Data”

“Personal Data” means any information relating to an identified or identifiable natural person.

An identifiable natural person is an individual who can be identified directly or indirectly, including by reference to information such as:

• name;
• contact information;
• identification number;
• location data;
• online identifier;
• IP address;
• device identifier;
• account information; or
• other information relating to that individual’s identity.

Information may constitute Personal Data even where it does not identify an individual on its own if it can reasonably be combined with other information to identify that individual.

4.3 “Data Subject”

“Data Subject” means an identified or identifiable natural person to whom Personal Data relates.

Depending on the circumstances, a Data Subject may include a Host, Property Owner, Guest, prospective Guest, subscriber, account holder, website visitor or another identifiable individual.

4.4 “Processing” or “Process”

“Processing” or “Process” means any operation or set of operations performed on Personal Data, whether or not by automated means.

Processing may include:

• collection;
• recording;
• organisation;
• structuring;
• storage;
• adaptation or alteration;
• retrieval;
• consultation;
• use;
• disclosure by transmission;
• dissemination;
• making information available;
• combination;
• restriction;
• erasure; or
• destruction.

4.5 “Controller”

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and essential means of Processing Personal Data.

Felda Rental Services Private Limited may act as a Controller where it determines why and how Personal Data is Processed in connection with Happy Lodgings.

4.6 “Processor”

“Processor” means a natural or legal person, public authority, agency or other body that Processes Personal Data on behalf of a Controller.

Processors may include service providers supporting services such as hosting, infrastructure, security, communications or technical operations.

4.7 “Recipient”

“Recipient” means a person, organisation, public authority or other body to which Personal Data is disclosed, whether or not that recipient is a Third Party.

4.8 “Third Party”

“Third Party” means a person or organisation other than the relevant Data Subject, Controller, Processor and persons authorised to Process Personal Data directly under the authority of the Controller or Processor, subject to the meaning provided under Applicable Law.

4.9 “Consent”

“Consent” means a freely given, specific, informed and unambiguous indication of a Data Subject’s wishes by which the Data Subject signifies agreement to the Processing of Personal Data relating to that individual through a statement or clear affirmative action.

Where Processing is based on Consent, Consent may be withdrawn in accordance with Applicable Law.

4.10 “Personal Data Breach”

“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to Personal Data transmitted, stored or otherwise Processed.

4.11 “Host”

“Host” means an individual, business, property manager, authorised representative or other person or entity that uses Happy Lodgings to advertise, promote, manage or provide information relating to holiday accommodation.

A Host may be the Property Owner or may act with the authority of the relevant Property Owner.

4.12 “Property Owner”

“Property Owner” means an individual or legal entity that owns, controls, manages or otherwise has lawful authority in relation to a property advertised or promoted through Happy Lodgings.

4.13 “Guest”

“Guest” means an individual who searches for, views, enquires about or may independently arrange accommodation with a Host or Property Owner.

The term may include prospective Guests, travellers and individuals submitting enquiries.

4.14 “Subscription Services”

“Subscription Services” means paid or subscription-based services made available by Happy Lodgings to Hosts, Property Owners or other authorised users.

Such services may include access to property listing functionality, listing management tools, account features, support services and other features included in the applicable subscription plan.

4.15 “Cookies and Similar Technologies”

“Cookies and Similar Technologies” means Cookies and other technologies capable of storing, accessing, collecting or recognising information relating to a device, browser or interaction with an online service.

These may include Cookies, pixels, web beacons, local storage, device identifiers and similar technologies.

4.16 “GDPR”

“GDPR” means Regulation (EU) 2016/679 concerning the protection of natural persons with regard to the Processing of Personal Data and the free movement of such data.

5. OUR PLATFORM AND SERVICES

Happy Lodgings operates an online platform through which Hosts and Property Owners may advertise, promote and manage information relating to holiday accommodation.

Depending on the services selected, our platform may provide:

• property listing functionality;
• property information management;
• account management;
• subscription services;
• property discovery and search functionality;
• enquiry and communication functionality;
• customer support;
• technical and administrative services; and
• other services made available through the platform.

Happy Lodgings may modify, update, add or discontinue services and features from time to time.

6. DIRECT ARRANGEMENTS BETWEEN GUESTS AND HOSTS

Happy Lodgings primarily provides an online listing and subscription platform.

Unless expressly stated otherwise in connection with a specific service, Happy Lodgings does not collect, receive, hold or process accommodation payments made by Guests to Hosts or Property Owners.

Accommodation arrangements, rental payments and other financial arrangements relating directly to a stay may be made independently between the relevant Guest and the relevant Host or Property Owner.

Hosts and Property Owners are responsible for their own accommodation services and their independent relationships with Guests.

Where a Host or Property Owner independently collects or Processes Personal Data relating to a Guest, the Host or Property Owner may have independent obligations under Applicable Data Protection Law.

7. PERSONAL DATA WE COLLECT

The categories of Personal Data we Process depend on how an individual interacts with Happy Lodgings.

We may collect Personal Data directly from individuals, automatically through the use of our website or services, or from third parties where permitted by Applicable Law.

7.1 Information You Provide Directly

We may collect information provided directly to us, including:

• name;
• email address;
• telephone number;
• postal or business address;
• account credentials;
• username;
• profile information;
• communications;
• support requests;
• enquiry information; and
• other information voluntarily provided through our website or services.

7.2 Host and Property Owner Information

Hosts and Property Owners may provide information necessary to create and manage accounts and property listings.

This may include:

• name or business name;
• contact information;
• account information;
• property location;
• property name;
• property descriptions;
• accommodation type;
• amenities;
• photographs and other media;
• availability information;
• pricing information displayed on listings;
• property rules; and
• other information submitted for publication or administration.

Certain information submitted for a property listing may be made publicly available through Happy Lodgings.

Hosts and Property Owners should avoid including unnecessary Personal Data or sensitive information in publicly accessible listing content.

7.3 Guest and Enquiry Information

Individuals who search for or enquire about a property may provide information including:

• name;
• email address;
• telephone number, where provided;
• travel dates or intended travel periods;
• accommodation preferences;
• number of guests;
• messages;
• enquiries; and
• other information voluntarily submitted.

Relevant information may be shared with the Host or Property Owner associated with the relevant listing where necessary to respond to or manage the enquiry.

7.4 Communications and Customer Support

We may Process Personal Data contained in:

• emails;
• contact forms;
• support requests;
• complaints;
• feedback;
• enquiries; and
• other communications.

We use such information to respond, provide support, investigate concerns and maintain appropriate records.

7.5 Information Collected Automatically

When you access or use Happy Lodgings, we may automatically collect certain technical and usage information, including:

• IP address;
• browser type and version;
• device type;
• operating system;
• language preferences;
• pages viewed;
• website interactions;
• referring pages;
• date and time of access;
• approximate location derived from IP information; and
• information collected through Cookies and Similar Technologies.

8. HOST SUBSCRIPTIONS AND PAID SERVICES

Happy Lodgings may offer Subscription Services to Hosts and Property Owners.

Depending on the applicable plan, Subscription Services may provide access to:

• property listing creation;
• publication and management tools;
• account functionality;
• listing features;
• support services; and
• additional services or benefits included in the applicable plan.

8.1 Subscription Information

We may Process information necessary to:

• create and administer subscriptions;
• identify subscribers;
• manage accounts;
• provide the selected service;
• maintain subscription records;
• communicate regarding subscriptions;
• provide support;
• maintain accounting and business records; and
• comply with legal obligations.

This information may include:

• subscriber name;
• business or account information;
• contact information;
• selected subscription plan;
• subscription status;
• invoice references;
• transaction references;
• payment status information; and
• subscription-related communications.

8.2 Subscription Payments

Where payment processing is required for a Happy Lodgings Subscription Service, payment-related information may be Processed through an authorised payment arrangement or third-party payment service provider.

The specific information Processed depends on the applicable payment method and provider.

Subscription-related payments are separate from accommodation payments between Guests and Hosts or Property Owners.

9. HOW WE USE PERSONAL DATA

We may Process Personal Data for the following purposes.

9.1 Providing Our Services

Including to:

• create and manage accounts;
• provide access to our platform;
• enable Hosts to create and manage listings;
• publish property information;
• enable users to discover listed properties;
• manage Subscription Services;
• respond to enquiries; and
• provide requested functionality.

9.2 Facilitating Property Enquiries

We may Process information to:

• receive enquiries;
• manage communications;
• respond to users;
• share relevant enquiry information with the appropriate Host or Property Owner; and
• facilitate communication relating to a listed property.

9.3 Managing Host Relationships

We may Process information to:

• administer Host accounts;
• manage subscriptions;
• communicate about our services;
• provide support;
• maintain business records; and
• improve our services.

9.4 Improving Happy Lodgings

We may use Personal Data and usage information to:

• understand how users interact with our website;
• identify technical problems;
• improve functionality;
• develop features;
• improve performance; and
• improve user experience.

Where appropriate, we may use aggregated or anonymised information.

9.5 Customer Support

We may Process Personal Data to respond to:

• questions;
• technical issues;
• complaints;
• service requests; and
• other communications.

9.6 Security and Fraud Prevention

We may Process Personal Data where reasonably necessary to:

• protect our systems;
• prevent unauthorised access;
• investigate suspicious activity;
• detect misuse;
• prevent fraud;
• enforce our policies; and
• protect our users and business.

9.7 Marketing and Communications

Where permitted by Applicable Law, we may send communications relating to:

• our services;
• platform developments;
• promotions;
• relevant offers; and
• other marketing communications.

Where Consent is required, we will seek Consent before sending relevant marketing communications.

Individuals may opt out of marketing communications at any time.

Service-related or administrative communications may continue where necessary for account or service administration.

9.8 Legal and Regulatory Purposes

We may Process Personal Data where necessary to:

• comply with Applicable Law;
• respond to lawful requests;
• maintain required records;
• establish, exercise or defend legal claims; or
• protect our rights and interests.

10. LEGAL BASIS FOR PROCESSING

Where the GDPR or another Applicable Data Protection Law requires a lawful basis for Processing, we may Process Personal Data based on one or more applicable legal grounds.

10.1 Performance of a Contract

Processing may be necessary to:

• provide requested services;
• administer accounts;
• manage Subscription Services;
• perform contractual obligations; or
• take steps requested before entering into a contract.

10.2 Legitimate Interests

We may Process Personal Data where necessary for legitimate interests pursued by the Company or another relevant party, provided that those interests are not overridden by the rights and freedoms of the relevant Data Subject.

Such interests may include:

• operating and improving Happy Lodgings;
• maintaining security;
• preventing fraud;
• protecting legal rights;
• improving services;
• managing business operations; and
• communicating with users where permitted.

10.3 Consent

Where required, we may Process Personal Data based on Consent.

Consent may be relevant to certain:

• marketing communications;
• Cookies; and
• other Processing activities requiring Consent.

Consent may be withdrawn where permitted by Applicable Law.

10.4 Legal Obligations

We may Process Personal Data where necessary to comply with legal, regulatory, accounting or other applicable obligations.

11. HOW WE SHARE PERSONAL DATA

We do not sell Personal Data.

We may disclose or make Personal Data available where necessary to operate our services, provide requested functionality, comply with Applicable Law or protect our legitimate interests.

11.1 Hosts and Property Owners

Where a user submits an enquiry relating to a property, relevant information may be shared with the Host or Property Owner associated with that property.

This may include:

• name;
• contact information;
• enquiry details;
• travel information voluntarily provided; and
• messages.

The relevant Host or Property Owner may independently Process information received in connection with their accommodation activities.

11.2 Public Listings

Information submitted by Hosts and Property Owners may be displayed publicly as part of a property listing.

This may include:

• property information;
• property descriptions;
• location information;
• photographs;
• amenities;
• availability information;
• displayed pricing; and
• other listing-related information.

11.3 Service Providers

We may share Personal Data with service providers supporting:

• website hosting;
• cloud infrastructure;
• technical operations;
• communications;
• security;
• analytics;
• customer support; and
• other operational services.

Where required, appropriate contractual and organisational safeguards may be implemented.

11.4 Legal and Regulatory Disclosures

We may disclose Personal Data where reasonably necessary to:

• comply with Applicable Law;
• respond to lawful requests;
• protect our rights;
• investigate unlawful activity;
• protect users;
• maintain security; or
• establish, exercise or defend legal claims.

11.5 Business Transactions

Personal Data may be Processed or disclosed where reasonably necessary in connection with a corporate transaction, including a restructuring, acquisition, merger, financing or sale of assets, subject to Applicable Law.

12. INTERNATIONAL DATA TRANSFERS

Personal Data relating to individuals located in the European Economic Area (“EEA”), the United Kingdom or other jurisdictions may therefore be transferred to, stored in or Processed in India and other countries where relevant service providers operate.

Where Applicable Data Protection Law requires safeguards for an international transfer of Personal Data, we will take appropriate steps to implement a lawful transfer mechanism and appropriate protections.

Depending on the circumstances, these safeguards may include:

• Standard Contractual Clauses;
• contractual safeguards;
• technical and organisational measures;
• transfers to jurisdictions recognised as providing an adequate level of protection; or
• another lawful transfer mechanism available under Applicable Law.

13. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected and Processed.

Retention periods may depend on:

• the type of Personal Data;
• the purpose of Processing;
• the relationship between the individual and Happy Lodgings;
• whether an account remains active;
• contractual requirements;
• legal and regulatory obligations;
• accounting requirements;
• dispute resolution needs; and
• security and fraud prevention requirements.

13.1 Account Information

Account information may be retained while an account remains active and for an appropriate period thereafter where reasonably necessary.

13.2 Host and Subscription Records

Information relating to Hosts and Subscription Services may be retained where necessary to:

• administer services;
• maintain business records;
• comply with accounting or tax obligations;
• resolve disputes; and
• protect legal rights.

13.3 Property Listings

Property listing information may be retained while the listing remains active and for an appropriate period thereafter where reasonably necessary.

13.4 Enquiries and Communications

Enquiries, communications and support records may be retained where reasonably necessary to:

• respond to users;
• provide support;
• maintain service records;
• investigate complaints;
• resolve disputes; and
• protect legal rights.

13.5 Deletion and Anonymisation

When Personal Data is no longer required, we may delete, anonymise or securely dispose of it unless continued retention is required or permitted by Applicable Law.

14. YOUR PRIVACY RIGHTS

Where applicable, including under the GDPR, Data Subjects may have certain rights regarding their Personal Data.

These may include the following.

14.1 Right of Access

You may have the right to request confirmation as to whether Personal Data relating to you is being Processed and, where applicable, obtain access to such information.

14.2 Right to Rectification

You may have the right to request the correction of inaccurate or incomplete Personal Data.

14.3 Right to Erasure

In certain circumstances, you may have the right to request deletion of Personal Data.

This right is subject to Applicable Law and may not apply in all circumstances.

14.4 Right to Restrict Processing

You may have the right, in certain circumstances, to request that Processing of your Personal Data be restricted.

14.5 Right to Object

You may have the right to object to certain Processing activities, including Processing based on legitimate interests where the applicable legal requirements are met.

You may also have rights relating to direct marketing.

14.6 Right to Data Portability

Where applicable, you may have the right to receive certain Personal Data in a structured, commonly used and machine-readable format.

14.7 Right to Withdraw Consent

Where Processing is based on Consent, you may have the right to withdraw Consent.

Withdrawal does not generally affect the lawfulness of Processing carried out before withdrawal.

15. HOW TO EXERCISE YOUR RIGHTS

To exercise an applicable privacy or data protection right, please contact:

[email protected]

Please provide sufficient information to allow us to understand and process your request.

Where necessary, we may request information to verify your identity before responding.

We will assess requests in accordance with Applicable Law.

Where applicable, you may also have the right to lodge a complaint with the competent data protection authority.

16. SECURITY OF PERSONAL DATA

We implement appropriate technical and organisational measures designed to protect Personal Data against:

• unauthorised access;
• unlawful Processing;
• accidental loss;
• destruction;
• alteration;
• misuse; and
• unauthorised disclosure.

Depending on the nature of the Processing and associated risks, these measures may include:

• access controls;
• authentication procedures;
• restrictions on access to Personal Data;
• technical security measures;
• organisational policies and procedures;
• system monitoring; and
• other security practices designed to reduce relevant risks.

No method of electronic transmission, storage or Processing can guarantee absolute security. We therefore cannot guarantee that Personal Data will always be completely secure.

17. DATA BREACH AND SECURITY INCIDENT MANAGEMENT

We take security incidents involving Personal Data seriously.

Where we become aware of an actual or suspected security incident, we may take steps appropriate to the circumstances to:

• investigate the incident;
• contain and mitigate potential effects;
• preserve relevant information;
• assess whether Personal Data has been affected;
• determine whether the incident constitutes a Personal Data Breach;
• implement remedial measures; and
• comply with applicable notification and reporting obligations.

Where required by Applicable Data Protection Law, we may notify the relevant supervisory authority, affected Data Subjects or other relevant parties.

The timing and content of any notification will depend upon the nature of the incident, the applicable legal requirements and the level of risk presented to affected individuals.

Not every security incident constitutes a Personal Data Breach or requires notification.

18. COOKIES AND SIMILAR TECHNOLOGIES

Happy Lodgings may use Cookies and Similar Technologies for purposes including:

• enabling essential website functionality;
• maintaining sessions;
• remembering user preferences;
• improving website performance;
• understanding website usage;
• analysing website traffic;
• maintaining security; and
• improving user experience.

Where required by Applicable Law, we will obtain Consent before placing or accessing non-essential Cookies or Similar Technologies.

Users may be able to manage certain Cookies through browser settings or other tools made available through our website.

Disabling certain Cookies may affect website functionality.

Where applicable, additional information may be provided through a Cookie Policy or Cookie Notice.

19. CHILDREN’S PRIVACY

Happy Lodgings is not intended to knowingly collect Personal Data from children where such collection is prohibited by Applicable Law.

We do not knowingly Process Personal Data relating to individuals under the age of 16 where Applicable Law requires additional protection or authorisation.

If we become aware that Personal Data relating to a child has been collected or Processed in violation of Applicable Law, we will take appropriate steps to investigate and address the matter.

If you believe that a child has provided Personal Data to Happy Lodgings, please contact:

[email protected]

20. THIRD-PARTY WEBSITES AND SERVICES

Happy Lodgings may contain links to third-party websites, services or platforms.

This Privacy Policy applies to Personal Data Processed by or on behalf of Happy Lodgings in connection with our services.

We are not responsible for the independent:

• privacy practices;
• security practices;
• content; or
• Personal Data Processing

of third-party organisations.

Users should review the privacy policies and terms applicable to third-party services before providing Personal Data to those organisations.

21. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

Updates may be made to reflect:

• changes to our services;
• changes to our Processing activities;
• changes in Applicable Law;
• technological developments;
• security developments; or
• changes in business operations.

The updated Privacy Policy will be published on the Happy Lodgings website.

The “Last Updated” date may be amended when changes are made.

Where required by Applicable Law or appropriate in the circumstances, we may provide additional notice of significant changes through:

• email;
• website notifications; or
• platform announcements.

We encourage users to review this Privacy Policy periodically.

22. CONTACT INFORMATION

For questions, concerns or requests relating to this Privacy Policy or the Processing of Personal Data, please contact:

Felda Rental Services Private Limited

Website: Happy Lodgings

Privacy Contact Email: [email protected]

23. FINAL PROVISION

This Privacy Policy is intended to explain the Company’s general privacy practices in connection with Happy Lodgings.

The application of specific rights, obligations and legal requirements may vary depending on:

• the relevant Processing activity;
• the nature of the Personal Data;
• the location of the individual;
• the role of the relevant parties;
• the services being used; and
• the Applicable Law governing the Processing.

Where Applicable Data Protection Law imposes requirements that differ from or supplement the information contained in this Privacy Policy, the relevant legal requirements shall apply to the extent required by law.