1. Introduction

Kingston Hotels Group ("Kingston," "we," "us," or "our") owns and manages nine hotel properties in Bangkok's Sukhumvit district — Valia, Nysa, Aira, Eleven, Solitaire, Kingston Suites, Samala Hotel Bangkok, Samala Suites, and Pipa — together with their associated restaurants (Kwann, Florae, Mariga).

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit kingstonhotelsgroup.com or any of our individual hotel websites, subscribe to our newsletter, contact us, stay at one of our properties, or otherwise interact with us. It is written to comply with Thailand's Personal Data Protection Act B.E. 2562 (2019) ("PDPA") and reflects relevant obligations under the Hotel Act B.E. 2547 and the Immigration Act B.E. 2522, which require Thai hotels to record and report certain guest information to government authorities.

By using our websites or services, you acknowledge that your personal data will be processed as described in this Policy. Where we rely on your consent, you may withdraw it at any time as explained in Section 11.

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2. Who We Are (Data Controller)

The data controller responsible for personal data collected via kingstonhotelsgroup.com and group-level marketing activities is:

KINGSTON HOLDINGS COMPANY LIMITED
Corporate Office: 14 Sukhumvit Soi 11, Bangkok 10110, Thailand
Tel: +66 2078 3999
Email: [privacy@kingstonhotelsgroup.com]

Each individual hotel (Valia, Nysa, Aira, Eleven, Solitaire, Kingston Suites, Samala Hotel Bangkok, Samala Suites, Pipa) acts as a joint data controller for personal data collected in connection with a stay at that specific property (e.g., reservation details, registration card, in-stay preferences), since each hotel independently determines how guest-service data is used at property level. Contact details for each hotel are listed in Section 14.

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3. Personal Data We Collect

Depending on how you interact with us, we may collect:

- Identity data: full name, title, date of birth, nationality
- Government ID data: passport number, national ID card, visa details — collected at check-in as required by the Hotel Act and Immigration Act
- Contact data: email address, phone number, mailing address
- Booking & stay data: reservation dates, room type, rate, special requests, loyalty/membership details, stay history across Kingston properties
- Payment data: card type and last 4 digits, billing address, transaction confirmation — full card numbers are processed and stored by our booking engine and payment providers (Section 6), not by Kingston directly
- Sensitive data: dietary requirements linked to religion or health (e.g., halal, allergies), disability/accessibility needs, where voluntarily provided to enable service — collected only with your explicit consent
- Marketing data: newsletter subscription email, communication preferences
- Technical data: IP address, browser type, device identifiers, pages visited, cookies (Section 10)
- CCTV/security data: images captured by security cameras at hotel premises for safety purposes

We do not knowingly collect data from children under 20 without parental/guardian involvement (Section 12).

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4. How We Collect Personal Data

- Directly from you: website forms, the newsletter sign-up on kingstonhotelsgroup.com, phone or email enquiries, at check-in/check-out, or via social media (Instagram, Facebook, LinkedIn, YouTube).
- Through booking engines: when you book a room via a hotel's website, your reservation and payment data is collected by our third-party booking-engine providers, Profitroom (used by Valia, Aira, Eleven, Solitaire, Kingston Suites, Samala Hotel Bangkok, Samala Suites, and Pipa) and Roiback (used by Nysa), acting as our data processors.
- Automatically: via cookies and similar technologies when you browse our websites (Section 10).
- From third parties: travel agents, online travel agencies (OTAs), or corporate travel bookers acting on your behalf.

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5. Purpose and Legal Basis for Processing

- Processing your reservation and providing hotel services — necessary for performance of a contract with you
- Registering your ID/passport and reporting foreign guest stays — compliance with a legal obligation (Hotel Act, Immigration Act)
- Processing payment — necessary for performance of a contract with you
- Responding to enquiries and customer service — legitimate interest / contract performance
- Sending you the Kingston newsletter or promotional offers — consent (opt-in), withdrawable at any time
- Security, fraud prevention, and CCTV monitoring — legitimate interest
- Improving our websites and services (analytics) — consent (non-essential cookies) / legitimate interest
- Processing dietary/health/religious preferences — explicit consent (sensitive personal data)
- Complying with tax, accounting, and regulatory record-keeping — compliance with a legal obligation

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6. Who We Share Your Data With

We share personal data only as necessary, with:

- Kingston Hotels Group properties, for group-wide loyalty recognition and to fulfil multi-property bookings
- Booking engine providers Profitroom (Poland) and Roiback (Spain), who process reservation and payment data on our behalf
- Payment processors and banks to complete transactions
- IT, hosting, and email/newsletter service providers who support our websites and marketing
- Government authorities, including the Immigration Bureau, Royal Thai Police, and Revenue Department, where required by the Hotel Act, Immigration Act, or tax law
- Professional advisors (legal, audit) where necessary
- A successor entity, in the event of a merger, acquisition, or sale of hotel assets

We do not sell your personal data to third parties.

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7. International Data Transfers

Because Profitroom and Roiback are based in the European Union, your booking data may be transferred outside Thailand. Under PDPA Sections 28–29, we ensure such transfers are protected by appropriate safeguards — including standard contractual clauses or reliance on the EU's adequate data protection framework — or, where required, by obtaining your explicit consent to the transfer.

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8. How Long We Keep Your Data

- Guest registration records (ID/passport, stay dates) are retained for the period required under the Hotel Act and Immigration Act record-keeping rules, and for tax purposes as required by the Revenue Code.
- Reservation and payment records are retained for [5] years for accounting and dispute-resolution purposes.
- Marketing/newsletter data is retained until you unsubscribe or withdraw consent.
- CCTV footage is retained for [30] days unless required for an active investigation.
- When data is no longer needed, we securely delete or anonymize it.

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9. Data Security

We apply appropriate technical and organizational measures — including access controls, encryption in transit for booking/payment pages, and staff confidentiality obligations — to protect personal data against unauthorized access, loss, or disclosure. Payment card data is handled by PCI-DSS-compliant booking and payment partners; Kingston does not store full card numbers.

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10. Cookies and Similar Technologies

Our websites use cookies and similar technologies to:

- Operate core website functions (strictly necessary — no consent required)
- Understand site usage through analytics (requires consent)
- Support newsletter sign-up and, where used, marketing pixels (requires consent)

You can manage cookie preferences through your browser settings or any cookie banner presented on our site.

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11. Your Rights Under the PDPA

You have the right to:

- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erase your data, subject to legal retention requirements
- Restrict or object to certain processing
- Data portability — receive your data in a structured, machine-readable format
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
- Lodge a complaint with Thailand's Personal Data Protection Committee (PDPC) if you believe your rights have been violated

To exercise any of these rights, contact us at [privacy@kingstonhotelsgroup.com]. We will respond within the timeframe required by the PDPA.

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12. Children's Privacy

Our services are not directed at children. Where a minor stays with a parent/guardian, we process the minor's data only as necessary to provide accommodation and only with the accompanying adult's authority.

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13. Marketing Communications

If you subscribe to the Kingston Hotels Group newsletter, we will send you offers and updates by email. You may unsubscribe at any time using the link in any email or by contacting [privacy@kingstonhotelsgroup.com].

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14. Hotel-Level Contact Details

- Valia Hotel Bangkok — 95,370 Sukhumvit 22, 24, Bangkok 10110 — rsvn@valiahotelbangkok.com
- Nysa Hotel Bangkok — 73/7-8 Soi Sukhumvit 13, Khlong Toei Nuea, Watthana, Bangkok 10110 — reservations@nysahotelbangkok.com (please verify — the live site currently lists Solitaire's email here by mistake)
- Aira Hotel Bangkok — 14 Sukhumvit 11, Bangkok 10110 — reservations@airahotelbangkok.com
- Samala Hotel Bangkok — 43 Sukhumvit Soi 15, Khlong Toei Nuea, Watthana, Bangkok 10110 — info@samalahotelbangkok.com
- Solitaire Bangkok — 75/23 Sukhumvit 13, Bangkok 10110 — reservations@solitairebangkok.com
- Eleven Hotel Bangkok — 11 Sukhumvit 11, Bangkok 10110 — reservations@elevenbangkok.com
- Kingston Suites — 39/3-7 Sukhumvit Soi 15, Bangkok 10110 — reservations@kingstonbangkok.com
- Samala Suites — 47/1 Sukhumvit Soi 19, Bangkok 10110 — reservations@samalasuitesbangkok.com
- Pipa Hotel Bangkok — Sukhumvit 11, Bangkok 10110 — reservations@pipahotelbangkok.com

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15. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on this page with an updated "Last updated" date, and where required by law, we will notify you directly.

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16. Contact Us

KINGSTON HOLDINGS COMPANY LIMITED
14 Sukhumvit Soi 11, Bangkok 10110, Thailand
Email: [privacy@kingstonhotelsgroup.com]
Tel: +66 2078 3999