

CLUB ADION NOIDA – PRIVACY POLICY
1. INTRODUCTION
At Club Adion by Jaypee Infratech Limited (“Club Adion”, “Club”, “we”, “us” or “our”), we value your privacy and are committed to protecting the personal data that you share with us when you visit, access or use our website and the products, facilities and services made available through or in connection with the website.
This Privacy Policy (“Privacy Policy”) explains our practices regarding the collection, processing, use, storage, disclosure and protection of personal data when you access or use the Club Adion website (“Website”), submit an enquiry or form, apply for or obtain membership, make a reservation or booking, register for an event, make a payment, subscribe to communications, contact us, or otherwise interact with us through the Website.
The Website may provide information and services relating to Club Adion's membership, restaurants and dining facilities, sports and recreational facilities, swimming pool, gymnasium, spa and wellness facilities, banquet and event facilities, entertainment, events, promotions and other facilities and other services offered by Club Adion from time to time[KS1.1].
We are committed to processing and protecting your personal data in accordance with applicable privacy and data protection laws, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”), to the extent its provisions have been notified and are applicable from time to time, the rules framed thereunder, and the Information Technology Act, 2000 (“IT Act”), including the applicable rules and regulations framed thereunder, as amended, substituted or re-enacted from time to time (collectively, “Applicable Laws”).
You are advised to carefully read this Privacy Policy before accessing or using the Website or providing any personal data to us.
2. PERSONAL DATA WE MAY COLLECT
Depending upon the manner in which you interact with the Website, we may collect personal data including:
• your name;
• mobile number and telephone number;
• email address;
• residential or correspondence address;
• date of birth, age and gender, where required;
• membership details and membership preferences;
• information submitted in membership applications, enquiry forms or other forms available on the Website;
• details relating to reservations, bookings, events or services requested by you;
• transaction and payment-related information;
• details of communications, enquiries, complaints, feedback or requests submitted by you;
• information relating to your preferences and interests where voluntarily provided;
• photographs or documents uploaded by you, where any such facility is provided on the Website;
• IP address, browser type, device information, operating system and similar technical information;
• Website usage information, including pages visited, time spent on the Website and interactions with Website features;
• cookie identifiers and similar information collected through cookies or other technologies; and
• such other information as may reasonably be required for providing the requested services or complying with Applicable Laws.
We endeavour to collect only such personal data as is reasonably necessary for the purposes for which it is processed.
3. HOW WE COLLECT PERSONAL DATA
We may collect personal data:
• directly from you when you provide information through the Website;
• when you complete or submit a membership application, enquiry form, reservation request, registration form or other online form;
• when you communicate with us through the contact details or communication facilities available on the Website;
• when you subscribe to newsletters, updates, offers or promotional communications;
• when you make a booking, reservation or payment through the Website;
• automatically through cookies, server logs and similar technologies when you access or interact with the Website; and
• through authorized service providers or third parties where permitted under Applicable Laws.
4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
We may process your personal data for purposes including:
• operating, administering and maintaining the Website;
• responding to your enquiries, requests, feedback or complaints;
• processing membership enquiries, applications and renewals;
• processing reservations, bookings and registrations;
• facilitating access to Club Adion's facilities and services;
• processing transactions and payments;
• communicating confirmations, updates and other service-related information;
• administering events, promotions, offers and activities;
• providing customer and member support;
• personalizing and improving your Website experience;
• analysing Website usage, performance and functionality;
• maintaining the security and integrity of the Website;
• detecting, preventing and investigating fraud, misuse, unauthorized access and security incidents;
• maintaining appropriate business and administrative records;
• complying with contractual, statutory, regulatory, judicial or governmental requirements;
• establishing, exercising or defending legal claims; and
• sending marketing or promotional communications regarding Club Adion's memberships, facilities, events, offers and services where permitted under Applicable Laws and, where required, after obtaining your consent.
5. CONSENT AND PROCESSING OF PERSONAL DATA
Where consent is required under Applicable Laws for processing your personal data, Club Adion shall seek such consent in the manner prescribed or permitted under Applicable Laws.
Where you voluntarily submit personal data through the Website for a particular purpose, such information shall be processed for that purpose and for such connected purposes as are permitted under Applicable Laws.
Where processing is permitted on any basis other than consent under Applicable Laws, Club Adion may process personal data in accordance with such applicable statutory provisions.
Where consent is required for a particular processing activity, mere access to or use of the Website shall not, by itself, constitute consent for such processing.
6. COOKIES AND SIMILAR TECHNOLOGIES
The Website may use cookies, pixels, tags, server logs and similar technologies to enable Website functionality, maintain security, remember user preferences, understand Website usage and improve the performance and user experience of the Website.
Cookies may include:
• Essential Cookies, which are necessary for the Website to operate;
• Functional Cookies, which help remember your preferences and improve Website functionality;
• Analytics Cookies, which help us understand how visitors interact with the Website; and
• Advertising or Marketing Cookies, where used, which may help us provide relevant advertisements or measure the effectiveness of promotional campaigns.
Where consent is required under Applicable Laws for the use of any non-essential cookies or similar technologies, such cookies shall be deployed in accordance with the applicable consent requirements.
You may be able to manage or disable cookies through your browser settings or through the cookie-management mechanism made available on the Website. Disabling certain cookies may affect the availability or functionality of certain Website features.
7. WEBSITE ANALYTICS
We may use analytics tools and services to understand how users interact with the Website, including information relating to Website traffic, pages visited, duration of visits, referring websites, browser and device information and general interaction with Website functionality.
Such information may be used to analyse Website performance, identify technical issues, improve content and functionality and enhance the overall user experience.
Where third-party analytics providers are engaged, their processing of personal data shall be subject to applicable contractual arrangements and Applicable Laws.
8. MEMBERSHIP, ENQUIRY AND RESERVATION FORMS
The Website may enable you to submit enquiries, express interest in membership, apply for membership, request reservations, register for events or otherwise request information regarding Club Adion's facilities and services.
Information submitted through such forms shall be used for responding to and processing the relevant request and for connected administrative purposes.
Fields identified as mandatory are required for us to process the relevant request. If you do not provide mandatory information, we may be unable to process or respond to your request.
9. PAYMENT INFORMATION
Where the Website enables online payments, payments may be processed through banks, payment gateways or other authorized payment service providers.
Club Adion may not directly collect or store complete payment card, banking or other sensitive payment credentials where such information is processed directly by the relevant payment service provider.
Your use of a third-party payment gateway may also be subject to the privacy policy and terms of the relevant payment service provider.
10. MARKETING AND PROMOTIONAL COMMUNICATIONS
Subject to Applicable Laws and your consent wherever required, Club Adion may send you communications regarding:
• membership opportunities and benefits;
• Club facilities and services;
• events and activities;
• dining and entertainment;
• offers and promotions; and
• other Club Adion products or services that may be of interest to you.
Such communications may be sent through email, SMS, telephone, WhatsApp or other electronic communication channels.
You may withdraw your consent or opt out of receiving promotional communications at any time through the unsubscribe or opt-out mechanism provided in the relevant communication or by contacting us.
Withdrawal from marketing communications shall not prevent Club Adion from sending transactional, membership-related, booking-related, security or other communications necessary for providing services requested by you.
11. SHARING OF PERSONAL DATA
We may share personal data, to the extent reasonably necessary for the relevant purpose, with:
• Website hosting and technology service providers;
• IT and cybersecurity service providers;
• payment gateways, banks and payment processors;
• booking and reservation service providers;
• communication and messaging service providers;
• analytics and digital service providers;
• event and hospitality service providers;
• professional advisers, including legal, accounting and audit professionals;
• governmental, regulatory, judicial, statutory or law-enforcement authorities where required under Applicable Laws; and
• other persons where disclosure is necessary for providing a service requested by you or where you have authorized such disclosure.
Where third-party service providers process personal data on our behalf, we shall endeavour to ensure that appropriate contractual, confidentiality, privacy and security obligations are imposed upon such service providers, as applicable.
12. THIRD-PARTY WEBSITES AND LINKS
The Website may contain links to websites, applications, social-media platforms, payment gateways or other online services operated by third parties.
Once you leave the Club Adion Website or access a third-party website or service, the collection and processing of your information may be governed by that third party's privacy policy and terms.
Club Adion does not control and is not responsible for the privacy practices, security or content of independent third-party websites or platforms. You are encouraged to review their privacy policies before providing personal information.
13. DATA SECURITY
We adopt reasonable technical, administrative and organizational security measures designed to protect personal data under our control against unauthorized access, disclosure, alteration, misuse, loss or destruction.
Access to personal data is restricted, as appropriate, to authorized personnel and service providers who require such access for legitimate business purposes.
While we endeavour to maintain appropriate security safeguards, no electronic transmission, Website or storage system can be guaranteed to be completely secure. Accordingly, Club Adion cannot guarantee absolute security of information transmitted over the internet.
14. DATA RETENTION
We shall retain personal data only for such period as is reasonably necessary to fulfil the purposes for which it was collected or processed or for such longer period as may be required or permitted under Applicable Laws.
Personal data may also be retained where reasonably necessary for legal, regulatory, taxation, accounting, audit, security, dispute-resolution or enforcement purposes.
Upon expiry of the applicable retention period, personal data shall be deleted, erased, anonymized or otherwise dealt with in accordance with Applicable Laws.
15. CHILDREN'S PERSONAL DATA
Where personal data relating to a child is required to be processed through the Website, Club Adion shall process such personal data in accordance with Applicable Laws, including obtaining verifiable consent of the parent or lawful guardian where such consent is required under the Applicable Laws in force at the relevant time.
16. YOUR RIGHTS
Subject to Applicable Laws and the relevant provisions being in force and applicable, you may have the right to:
• obtain information regarding the processing of your personal data;
• seek correction, completion or updating of your personal data;
• request erasure of personal data where applicable;
• withdraw consent where processing is based on consent;
• avail the grievance-redressal mechanism provided by Club Adion; and
• exercise such other rights as may be available under Applicable Laws from time to time.
Requests relating to personal data may be submitted through the contact details specified in this Privacy Policy.
17. WITHDRAWAL OF CONSENT
Where processing of personal data is based on your consent, you may withdraw such consent at any time in the manner prescribed by us or permitted under Applicable Laws.
Withdrawal of consent shall not affect the lawfulness of processing undertaken prior to such withdrawal.
Where particular personal data is necessary for providing a service requested by you, withdrawal of consent may affect our ability to continue providing such service.
18. CROSS-BORDER PROCESSING
Certain technology, hosting, cloud, communication or other service providers engaged by Club Adion may process or store information using infrastructure situated outside India.
Any transfer or processing of personal data outside India shall be undertaken subject to the requirements and restrictions prescribed under Applicable Laws from time to time.
19. DISCLOSURES REQUIRED BY LAW
Club Adion may disclose personal data where such disclosure is required pursuant to Applicable Laws, an order of a court or tribunal, a direction of a governmental or regulatory authority or a lawful request from a law-enforcement agency.
We may also disclose information where reasonably necessary to protect the rights, property, safety or legitimate interests of Club Adion, its members, guests, employees or other persons, or to prevent, investigate or address fraud, security incidents or unlawful activities, subject to Applicable Laws.
20. CHANGES TO THIS PRIVACY POLICY
Club Adion may amend, modify or update this Privacy Policy from time to time to reflect changes in Applicable Laws, regulatory requirements, technology, Website functionality, facilities, services or our privacy practices.
Any updated Privacy Policy shall be published on the Website with the date of the latest update.
We encourage you to periodically review this Privacy Policy to remain informed about how we process and protect personal data.
21. APPLICABLE LAW
This Privacy Policy and the processing of personal data through or in connection with the Website shall be governed by the laws applicable in India, including the Digital Personal Data Protection Act, 2023, to the extent its provisions have been notified and are applicable from time to time, the rules framed thereunder, and the Information Technology Act, 2000 and the applicable rules and regulations framed thereunder, in each case as amended, substituted or re-enacted from time to time.
22. ACKNOWLEDGEMENT
By providing personal data through the Website, you acknowledge that you have been provided an opportunity to review this Privacy Policy and understand the purposes and manner in which your personal data may be processed, subject to Applicable Laws.
Where consent is required under Applicable Laws for any specific processing activity, Club Adion shall obtain such consent through an appropriate consent mechanism. Mere browsing, access to or use of the Website shall not, by itself, be treated as consent to processing for which express consent is required under Applicable Laws.
Last Updated: 25/082026