Data Protection Policy

DigiReg Hotel Management System — Protecting your guests, your partners, and your trust

 DPDP Act, 2023  IT Act, 2000  Indian Law Compliant  Version 1.0  Jurisdiction: Uttarakhand, India

 Table of Contents

1

Introduction & Commitment

DigiReg ("Platform", "We", "Us") is committed to protecting the personal data of hotel partners, their staff, and guests in full compliance with Indian law. This policy governs how data is collected, stored, processed, and protected across all modules of the DigiReg Hotel Management System.

 Modules covered: Guest Check-In, Reservations, Billing & Invoicing, OTA Channel Management, Room Management, and Admin Dashboard.

We believe privacy is a fundamental right. Every feature of DigiReg is designed with data minimisation and security as core principles, not afterthoughts.

2

Legal Framework

This policy is governed by the following Indian laws and regulations:

Law / RegulationRelevance
Digital Personal Data Protection Act, 2023 (DPDP Act)Primary data protection framework
Information Technology Act, 2000Cybersecurity and digital data obligations
IT (SPDI) Rules, 2011Sensitive personal data handling standards
Indian Contract Act, 1872Partner agreement obligations
Consumer Protection Act, 2019Guest / consumer rights
Aadhaar (Targeted Delivery) Act, 2016ID verification compliance
Income Tax Act, 1961Financial record retention periods
The Foreigners Act, 1946Foreign guest registration requirements
3

Definitions

TermMeaning
Data PrincipalThe individual whose personal data is collected (hotel guest, staff member)
Data FiduciaryDigiReg — the entity determining purpose and means of processing
Data ProcessorHotel partner processing guest data via the DigiReg platform
Personal DataName, mobile, email, address, ID number, photograph, signature
Sensitive Personal Data (SPDI)Aadhaar number, PAN, financial information, biometric data
PartnerAny registered hotel or lodging establishment using DigiReg
PlatformThe DigiReg Hotel Management System at digireg.online
4

Data We Collect

Guest Data (collected by hotel partners)
  • Full name, mobile number, email address
  • Home / permanent address
  • Government ID type and number (Aadhaar, PAN, Passport, Driving Licence, Voter ID)
  • ID photographs — front and back images
  • Digital guest signature
  • Check-in and check-out date & time
  • Room number, duration of stay, agreed rate
  • Payment details — advance paid, balance due, payment mode, transaction reference
  • Booking reference number and reservation linkage
  • Special remarks or requests
Hotel Partner Data
  • Hotel name, contact person name, address, city, state
  • Mobile number, email address
  • GST number and PAN number
  • Username and cryptographically hashed password
  • WiFi credentials (stored encrypted)
  • SMS API keys (stored encrypted, never exposed in UI)
  • Total rooms count and room configuration
Automatically Collected Data
  • Login timestamps and IP addresses
  • Session identifiers and activity logs
  • Browser and device information (user-agent)
  • Draft form data (temporary, cleared after submission)
5

Purpose of Data Collection

Data is collected strictly for the following lawful purposes under Section 4 of the DPDP Act, 2023:

#PurposeBasis
1Guest check-in registration as required under Hotel & Lodging House Rules and state police regulationsLegal obligation
2Reservation creation, confirmation, and managementContract
3Billing, invoice generation, advance and balance trackingContract
4Identity verification as mandated for lodging establishmentsLegal obligation
5OTA channel management — room availability synchronisation onlyLegitimate interest
6Operational analytics and occupancy reports for hotel managementLegitimate interest
7Compliance with police, tourism department, and tax authority requirementsLegal obligation
 Data is never used for advertising, profiling, or sold to any third party.
6

Legal Basis for Processing

Under the DPDP Act, 2023 and SPDI Rules, 2011, we process data on the following lawful bases:

  • Consent — Obtained from guests at check-in via digital signature on the registration form
  • Legal Obligation — Hotel establishments are legally required to maintain guest registers under state Police Acts and The Foreigners Act, 1946
  • Contractual Necessity — For executing reservations, issuing invoices, and managing room allocations
  • Legitimate Interest — For platform security, fraud prevention, session management, and service continuity
7

Partner Obligations

As a DigiReg partner (acting as Data Processor under the DPDP Act, 2023), registered hotels agree to:

  • Collect guest data only for lawful lodging and compliance purposes
  • Display a privacy notice at the front desk or on the check-in interface
  • Not share guest data with any third party without explicit written consent
  • Ensure all staff accessing the system are bound by confidentiality obligations
  • Report any suspected or confirmed data breach to DigiReg within 72 hours of discovery
  • Not retain guest data beyond the legally required retention period (generally 1–5 years depending on state regulations)
  • Ensure physical and device security for all terminals accessing the platform
  • Not use guest data for marketing, promotions, or upselling without a separate, explicit opt-in consent
  • Cooperate with DigiReg in any audit or investigation related to data protection
 Violation of partner obligations may result in suspension or termination of platform access as per the partner agreement.
8

Data Storage & Security

Storage
  • All data is stored on servers located in India in compliance with data localisation requirements
  • Guest ID photographs and signatures are stored as encrypted data
  • Database access is restricted by role-based access control (RBAC)
  • Each hotel can only access its own data — complete data isolation
Security Measures (as per Rule 8, SPDI Rules 2011)
  • Encryption — All sensitive data encrypted at rest and in transit via HTTPS/TLS
  • Access Control — Hotel staff see only their own hotel's guest data
  • Password Security — Passwords stored using one-way cryptographic hashing (never plain text)
  • Session Management — Automatic session timeout after inactivity
  • Audit Logs — All login events and data access actions are logged with timestamps
  • API Security — All API endpoints require authenticated hotel sessions
  • Draft Data — Form drafts cleared after successful submission or after 30 days
Data Retention Schedule
Data TypeRetention PeriodLegal Basis
Guest check-in records5 yearsState police / lodging house requirements
Reservation records3 yearsOperational / contractual
Financial / billing records7 yearsIncome Tax Act, 1961
Login / activity logs1 yearIT Act, 2000
Deleted hotel & dataPurged immediatelyDPDP Act, 2023
Draft / temporary form data30 days or on submissionLegitimate interest
9

Rights of Data Principals

Under the Digital Personal Data Protection Act, 2023, guests and individuals have the following rights:

Right to Access Know what personal data is held about you
Right to Correction Request correction of inaccurate data
Right to Erasure Request deletion where legally permissible
Right to Grievance Lodge complaints regarding data handling
Right to Nominee Designate a nominee for data rights
Right to Withdraw Withdraw consent where applicable
 To exercise these rights, contact the hotel directly or reach DigiReg at privacy@digireg.online. We respond within 30 days.
10

ID Data Special Provisions

Collection of Aadhaar numbers is governed by the Aadhaar Act, 2016. DigiReg and its partners:

  • Do not use Aadhaar for authentication purposes — only for identity recording as legally permitted
  • Do not store Aadhaar data in any central biometric database
  • Store all ID numbers in encrypted form with restricted access
  • Recommend hotels record only the last 4 digits of Aadhaar where the full number is not legally required
  • Do not share ID data with any third party except law enforcement with a valid legal order
  • ID photographs are stored locally per hotel and are not shared across the platform
 Partners must not photocopy or retain physical Aadhaar cards. Digital recording via the DigiReg platform is the approved method.
11

Data Breach Policy

In the event of a data breach, DigiReg will follow this response protocol:

StepActionTimeline
1. ContainIsolate affected systems immediately upon discoveryImmediate
2. AssessDetermine scope, type of data affected, and number of individuals impactedWithin 24 hours
3. Notify PartnersInform affected hotel partners with details of the breachWithin 72 hours
4. Notify AuthoritiesReport to the Data Protection Board of India as required under DPDP Act, 2023As per DPB timeline
5. Notify IndividualsInform affected individuals with clear information about the breachWithout undue delay
6. RemediatePatch vulnerabilities, strengthen controls, and conduct post-breach auditWithin 7 days
7. DocumentMaintain full record of breach and all remedial actions takenOngoing
12

Third-Party Data Sharing

 DigiReg does not sell, rent, or trade personal data under any circumstances.

Data may be shared only in the following strictly limited circumstances:

RecipientData SharedLegal Basis
Law Enforcement / PoliceGuest register as per legal orderLegal obligation
State Tourism DepartmentCompliance reporting where mandatedLegal obligation
OTA Platforms (Booking.com, Airbnb)Room availability only — no guest PII sharedContractual
SMS Service ProvidersMobile number for OTP / notification delivery onlyLegitimate interest
Payment ProcessorsMinimum required for transaction processingContractual
 All third-party processors are contractually bound to data protection standards equivalent to this policy.
13

Grievance Officer

As required under Rule 5(9) of the SPDI Rules, 2011 and Section 13 of the DPDP Act, 2023:

DigiReg Data Protection & Grievance Officer

 Platform: DigiReg Hotel Management System

 Website: digireg.online

 Email: privacy@digireg.online

 Response Time: Within 30 days of receiving a complaint

 Jurisdiction: Courts of Uttarakhand, India

14

Policy Updates

This policy may be updated periodically to reflect changes in Indian law, platform features, or operational practices.

  • Partners will be notified of material changes via email at least 30 days before they take effect
  • The updated policy will be published at digireg.online/data-protection-policy
  • Continued use of the platform after the effective date constitutes acceptance of the updated policy
  • Version history will be maintained and available on request
 Current Version: 1.0  |  Effective Date: April 2026  |  Next Review: April 2027
15

Partner Agreement

By registering and using the DigiReg platform, hotel partners confirm they have:

  • Read and fully understood this Data Protection Policy
  • Agreed to comply with all partner obligations as Data Processors under Indian law
  • Accepted responsibility for ensuring their staff follow data protection practices
  • Acknowledged that violations may result in suspension of platform access

Your Trust is Our Foundation

DigiReg is committed to responsible data stewardship. We protect your guests' data the same way you protect your guests — with care, professionalism, and accountability.

For questions, contact: privacy@digireg.online  |  digireg.online