Privacy Policy

Haltn.com and its associated mobile applications are owned and operated by M/S Circous Hospitality Private Limited.

Objective, Scope and Applicability of the Policy

The privacy policy (“Policy”) is applicable to the online interfaces of Circous Hospitality Pvt Ltd. (“Circous Hospitality”, “us”, “we” or “our”) including https://www.Haltn.com, the mobile site/applications (including but not limited to the Circous Hospitality, Milo, or any other app) for iOS, Android, or any other windows operating system (collectively referred to as “Site”). This Policy along with its Terms of Use is effective from the date and time a user registers with https://www.Haltn.com by filling up the Registration form and accepting the terms and conditions laid out in the Site Policy. The purpose of this Policy is to describe how Circous Hospitality collects, uses, maintains and shares information about you (“user” or “you” or “your”) on account of you accessing and using the Site. This information may include but is not limited to any information you upload, emails that you exchange with Circous Hospitality and other users of the Site and any information submitted/ provided by you to Circous Hospitality.

We recognize the importance of your privacy and we are committed to ensuring that you are aware of how your information is being used. Please read this Policy carefully to understand how we collect and use your information. Your use of the Site is also governed by our Terms of Use. You are free to use the Site only if you agree with our policies and practices encapsulated in this Policy read in conjunction with the Terms of Use. By using the Site and/or by providing your information to us, you consent to the collection and use of the information you disclose on the Site in accordance with this Policy.

If you wish to contact Circous Hospitality in connection with any matter relating to this Policy or privacy related issues you may send an email to data.privacy@haltn.com. Alternatively, you may raise your concern using your Account (as defined below). By browsing, visiting, accessing and/or using the services on the Site, you consent and agree to the terms of Circous Hospitality’s Policy as detailed herein.

You also agree that the information furnished by you is lawful, true and correct and does not violate or infringe any laws. In case of any violations, infringement, furnishing of wrongful or unauthorized information, Circous Hospitality shall not be liable to you or to any third party for the same. You also agree that your information will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005 or any other law for the time being in force. We use data collection devices such as "cookies" on certain pages of the Site to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. The term "cookies" means small files placed on your hard drive that assist us in providing our services.

We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site. Additionally, you may encounter "cookies" or other similar devices on certain pages of the Site that are placed by third parties. Circous Hospitality does not control the use of cookies by third parties.

Types/ Nature of Information we collect:

There are three (3) general categories of information we collect:

  • A. Information you provide us, to enable your use of the Account/Site.
  • B. Information you choose to give us.
  • C. Information that is necessary for payment-related services.

Further to each of the aforementioned categories set out in Section II: Sub-Sections A, B, and C above, we collect the following types of information from you (collectively referred to as “Information”):

  • i) Personally Identifiable Information – Information that could be used to identify you, such as your name, email address, age, gender, IP address, and other similar information.
  • ii) Sensitive Personal Information – Such as encrypted passwords and secured financial/payment-related information.
  • iii) Non-Personal Information – Information that cannot be used to identify you, such as web pages you have viewed and your usage patterns.
  • iv) Device Information – Information automatically collected about the device from which the Site is accessed.

A. Information You Provide Circous Hospitality to Enable Your Use of the Account/Site

We ask for and collect the following Personally Identifiable Information and Sensitive Personal Information about you when you use the Site. This information is necessary for the performance of the agreement between you and us, and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with the requested services.

  • i) Account Information: To use certain features on the Site, Circous Hospitality may require you to create a user account (“Account”) which includes your user profile (“Profile”). You may be asked to provide your first name, last name, email address, date and place of birth, employer name, phone number, interests, gender, and marital status.
  • ii) Profile and Listing Information: We may ask for additional information such as your address, phone number, and a profile picture to support features like booking or listing creation.
  • iii) Identity Verification Information: To maintain a trusted environment, we may collect images of government-issued identification (e.g., passport, national ID card, or driving license), or any other details required for identity verification.
  • iv) Payment Information: We may require financial information (see Section C) to process payments when using certain features.
  • v) Communications: We collect communications exchanged with Circous Hospitality, its affiliates, authorized service providers/agents, or other users of the Site.

B. Information You Choose to Give Us

You may choose to provide additional Personally Identifiable Information to enhance your user experience on the Circous Hospitality platform.

  • i) Additional Profile Information: You may add preferred language(s), city, or a personal description. Depending on your settings, some of this may be publicly visible.
  • ii) Address Book Contact Information: You may import or manually add your address book contacts to use specific features.
  • iii) Other Information: You may provide additional information by filling forms, conducting searches, responding to surveys, participating in forums or promotions, or updating your account details.

Information That Is Necessary for the Payment-Related Services

Circous Hospitality needs to collect the following Sensitive Personal Information, as it is necessary for the adequate performance of its agreements with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use the payment services offered by Circous Hospitality on the Site:

  • i) Payment Information: When you use any payment services on the Site, certain financial information may be required to facilitate the processing of such payments. Please note that Circous Hospitality engages with third-party payment service providers to process payments. You will be required to provide certain Sensitive Personal Information to these providers. In such cases, you will be subject to the terms of use and privacy policy of the respective third-party service provider.
  • ii) Identity Verification and Other Information: In connection with the collection of payment information and processing of your payments, we may require certain information to verify your identity—such as government-issued identification (e.g., passport, national ID card, or driving license), KYC documents, your date of birth, address, email address, phone number, invoice amount, and other relevant data. This enables us to provide you with payment services and ensures compliance with applicable law.

III. Sharing Your Information

We may share your information as described below:

  • a) Within Circous Hospitality’s group of companies, for business purposes.
  • b) With accommodation managers, landlords, tenants, prospective tenants, or occupants to provide the services you request.
  • c) With third-party service providers and vendors helping us deliver products and services, including community apps, utilities, living services (e.g., water, laundry, mobility), and payment services. For example:
    • i) Verifying your identity or authenticating ID documents;
    • ii) Verifying your information against public databases;
    • iii) Conducting background checks, fraud prevention, or risk assessments;
    • iv) Product development, website maintenance, and debugging;
    • v) Providing our services through integrated third-party platforms and tools (e.g., APIs);
    • vi) Customer service, advertising, or payment services.
    These providers access your data only as needed to perform their services and are contractually obligated to protect your information.
  • d) With operators of other applications or websites that integrate with our services or APIs (or vice versa).
  • e) With members of curated networks (e.g., tenants, users, employees) if you post content in shared forums such as blogs, community networks, or social feeds.
  • f) With the general public, if you submit content in public forums (e.g., blog comments, social media). Social sharing tools may share your information publicly, based on your settings. Refer to each platform's privacy policy for details.
  • g) With third parties where required or permitted by law (e.g., law enforcement, government authorities).
  • h) With police or others when required by court orders.
  • i) With prospective buyers or sellers if Circous Hospitality or any group company sells or buys business assets.
  • j) With third parties in case of mergers, acquisitions, restructuring, or sale of company assets, where user data may be among the transferred assets.

Where we share your Sensitive Personal Information or Personally Identifiable Information, we ensure adequate protections are in place, in accordance with applicable data protection laws.

In some cases, we may share aggregated, pseudonymized, or anonymized information, which cannot reasonably be used to identify an individual.

Purposes for Which We Use Your Information

We may use your information for the following purposes:

  • a) Corresponding or communicating with you after you register an Account or use the Site;
  • b) Verifying your Account;
  • c) Ensuring the content on the Site is displayed effectively for you and your device;
  • d) Providing newsletters, information, products, or services that you request or that we believe may interest you (with your consent);
  • e) Notifying you about changes to the Site, this Privacy Policy, or our Terms of Use;
  • f) Studying your usage patterns;
  • g) Performing analytics, including assessing usage data, estimating audience size, and analyzing usage trends;
  • h) Any other purpose described at the time you provide the information;
  • i) Detecting and preventing fraud, spam, abuse, security incidents, and other harmful activities;
  • j) Conducting security investigations and risk assessments;
  • k) Verifying or authenticating the information or identification you provide (e.g., verifying your address or comparing identification photos);
  • l) Conducting checks against public or private databases (including background or police checks), where permitted by law and with your consent if required;
  • m) Complying with legal obligations and applicable laws;
  • n) Monitoring compliance with our contractual obligations to you;
  • o) Resolving disputes with you or other users, and enforcing our agreements with third parties.

In connection with the purposes above, we may also conduct profiling based on your interactions with Circous Hospitality, your profile details, submitted content, and information obtained from third parties.

In limited cases, automated processes may restrict or suspend your access to the Site if such activity is detected to pose a safety, security, or legal risk to Circous Hospitality, its users, or third parties.

DATA SECURITY

The Information that you provide, subject to disclosure in accordance with this Policy and Terms of Use, shall be maintained in a safe and secure manner. Circous Hospitality’s databases and Information are stored on secure servers with appropriate firewalls owned by Circous Hospitality or by third parties. Circous Hospitality gives the user right to withdraw his consent by sending an email at data.privacy@Haltn.com Given the nature of internet transactions, Circous Hospitality does not take any responsibility for the transmission of Information including the Information you provide to Circous Hospitality. Any transmission of your Information on the internet is done at your risk. Circous Hospitality does not take any responsibility for you or any third party circumventing the privacy settings or security measures contained on the Site. While Circous Hospitality will use all reasonable efforts to ensure that your Information is safe and secure, it offers no representation, warranties or other assurances that the security measures are adequate, safe, fool proof or impenetrable. You acknowledge that as a registered user you are responsible for maintaining the security of your Account such as your Account login credentials and passwords, and that you should not provide these credentials to any third party. If it comes to your knowledge that or if you have reason to believe that your Account credentials have been stolen or been made known to others, you must contact us immediately at data.privacy@Haltn.com. You acknowledge that you are responsible for all acts

Your Rights

a) Managing Your Information You may access and update your Personally Identifiable or Sensitive Personal Information through your Account settings. Please note that you do not have the option to connect to third party applications using your Account. Do note however, Circous Hospitality reserves the rights to save any NonPersonal, Device Information and usage Information and you are not entitled to seek the deletion of the same. Circous Hospitality at its sole discretion may permit or deny the change of any Information, if it is believed such Information is required to comply with applicable laws. b) Rectification of Inaccurate or Incomplete Information You have the right to ask us to correct inaccurate or incomplete Personally Identifiable Information or Sensitive Personal Information concerning you (and which you cannot update yourself within your Account) by contacting data.privacy@Haltn.com.

Data Retention and Erasure

We retain your Information as long as it is required for it discharges its obligations towards you and/or as may be required under law. However, there may be circumstances that mean we must retain your personal information for longer (e.g. in the event of a dispute or if you make a claim in relation to a booking). We may retain some of your Personally Identifiable information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. Information you have shared with others (e.g. reviews, forum postings) may continue to be publicly visible on the Site, even after your Account is cancelled. VIII

International Privacy Rights

Circous Hospitality website and/or databases are operated and managed on servers that may be located and operated in different jurisdictions. By using and accessing the Site, you consent to the transfer to and processing of your Information including the Sensitive Personal Information and the Personally Identifiable Information, on servers that may be located in a jurisdiction different from where you are located, and that the protection of such Information may be different than required under the laws of your residence or location.

Age restrictions

The Site is only intended for users who are competent to contract under applicable law. If you are not of the requisite age, you are not to provide any Personally Identifiable Information or Sensitive Personal Information. If it comes to Circous Hospitality’s attention that any such information pertains to an individual who is not competent to contract under applicable law, such Information may be deleted without notice to you.

Amendments to the Policy

This Policy is subject to change at Circous Hospitality’s sole discretion. Any changes to the Policy will be notified by way of a notice on the home page. XI

Terms of Us

This Policy shall form a part of the Terms of Use.

Data protection contacts

If you have any questions, comments, complaints or suggestions in relation to this Policy, or any other concerns about the way in which we process information about you, please contact our Grievance Redressal Officer (detail mentioned below) at data.privacy@Haltn.com. We shall endeavour to address all requests/complaints within thirty (30) days from the date of such a request/complaint being made.

Miscellaneous

All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed shall lie on Circous Hospitality nor will Circous Hospitality in any way be responsible to verify any information obtained from You.

Refund Policy

There will be one month notice for checkout if any one not inform before one month (30 days) so the amount will be deducted from his/her security amount and remaining security ammount will be refund in one month (30 days) of checkout date.

© 2025 Circous Hospitality Pvt Ltd.