Privacy Policy

1. Introduction & Corporate Ownership

Welcome to 101 Circle ("101 Circle," "the Estate," "we," "us," or "our"), a private membership estate located on Golf Course Road, Gurugram, comprising The Club House, ARK by ADot (banquets and events), The Wellness House, and an upcoming boutique hotel.

Corporate Entity & Legal Disclosure:
101 Circle and its official public website (www.101circle.com) are wholly owned, developed, and legally operated by JSVP Hospitality Private Limited ("JSVP"), an incorporated entity under the SIPL Group ("SIPL," "the Group"). For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act") and applicable privacy frameworks, JSVP Hospitality Private Limited functions as the primary Data Fiduciary / Data Controller for all member, guest, and visitor interactions.

This Privacy Policy explains how we collect, use, disclose, store, and protect personal data of visitors to our website (www.101circle.com), prospective members, members, their guests, hotel patrons, event attendees, vendors, and other individuals who interact with us across our website, mobile platforms, physical premises, and services (collectively, "you").

This Policy is issued in accordance with the DPDP Act, 2023 and applicable Indian laws, and is drafted with reference to global best practices, including principles under the EU General Data Protection Regulation ("GDPR"), for the benefit of our international members and guests. By accessing our website, submitting your details, registering interest in membership, or visiting our premises, you acknowledge that you have read and understood this Policy.

2. Scope of This Policy

This Policy applies to personal data collected by JSVP Hospitality Private Limited and 101 Circle:

• Through our website (www.101circle.com), including the membership waitlist / "Register Your Interest" form
• During membership application, onboarding, KYC checks, and renewal
• While you use the Club House, ARK by ADot, The Wellness House, boutique hotel, and any other facility within the estate
• At events, private soirées, corporate gatherings, weddings, and bespoke celebrations hosted at 101 Circle
• Through official corporate correspondence with our team (emails hosted on @101circle.in, phone, WhatsApp, or in-person)
• Via CCTV and security access control systems operating on the premises
• Through third-party platforms you use to interact with us (e.g., LinkedIn, official social media, integrated payment gateways)

It does not apply to non-affiliated third-party websites, apps, or services that may be linked from our website or premises, which are governed by their own privacy policies.

3. Personal Data We Collect

3.1 Information You Provide Directly

When you register your interest in membership or otherwise contact us, we may collect:

• Identity data: full name, age, LinkedIn URL (optional)
• Contact data: email address, phone number, current city/location
• Financial and professional data: annual income range, employment status, company/organization name, designation/role
• Preference data: the membership experience you are interested in (Club House, ARK by ADot, Wellness House, boutique hotel), your interests, how you discovered 101 Circle, and your marketing communication preferences
• Membership and account data: application forms, KYC/identity verification documents, membership agreements, billing and payment details (once you proceed to membership or bookings)
• Guest and dependent data: where you register family members, dependents, or guests on your membership or reservation

3.2 Information Collected On-Premises

As a private estate offering club, wellness, hospitality, and event facilities, we may also collect:

• Access and security data: entry logs, vehicle and parking details, visitor sign-in records
• CCTV/surveillance footage captured across common areas and facilities for the safety and security of members, guests, and staff (excluding private areas such as washrooms and changing rooms)
• Wellness and health-related data: information you voluntarily share with our fitness, wellness, or recovery programs (e.g., health declarations, fitness assessments), collected only with your explicit consent and used solely for delivering the relevant service
• Hotel guest data: ID proof, stay preferences, and booking history, once the boutique hotel is operational
• Event data: details shared while booking or attending events through ARK by ADot, including dietary preferences, guest lists, and vendor coordination information

3.3 Information Collected Automatically

When you visit our website (www.101circle.com), we may automatically collect:

• Device and browser information, IP address, and approximate location
• Pages visited, time spent, referral source, and click behavior
• Cookies and similar tracking technologies (see Section 8)

3.4 Information From Third Parties

We may receive information about you from:

• Referral partners, brokers, or existing members who recommend you for membership
• Publicly available professional or social media profiles (e.g., LinkedIn), where relevant to assessing membership applications
• Payment processors, background verification agencies, and event or hospitality partners engaged on our behalf

4. How We Use Your Personal Data

We process personal data for the following purposes:

We do not use your personal data for any purpose incompatible with the purpose for which it was originally collected, without seeking fresh consent where required.

5. Legal Basis for Processing

Where applicable, we process your personal data on the basis of:

• Your consent — for example, when you submit the membership registration form or opt in to marketing updates
• Performance of a contract — to provide membership, hospitality, wellness, or event services you've signed up for
• Legitimate interests — such as ensuring the safety and security of our premises, members, and staff
• Legal obligation — where processing is necessary to comply with applicable statutory laws, tax requirements, and the DPDP Act, 2023

You may withdraw consent at any time (see Section 9), though this may affect our ability to process your membership application or provide certain services.

6. How We Share Your Information

We do not sell your personal data. We may share it with:

• Operating entities & Group affiliates within JSVP Hospitality Private Limited and the SIPL Group, for administration, corporate governance, and service delivery across the estate
• Service providers and vendors, such as IT/hosting providers, payment gateways, event and catering partners, security agencies, and hospitality management systems, bound by confidentiality and data protection obligations
• Professional advisors, including legal, financial, and audit consultants, where necessary
• Regulatory and law enforcement authorities, where required by law, court order, or to protect the rights, property, or safety of 101 Circle, JSVP Hospitality Private Limited, our members, or the public
• Successors, in the event of a merger, acquisition, or restructuring of JSVP Hospitality Private Limited or the SIPL Group, subject to equivalent privacy protections

All third parties who process data on our behalf are contractually required to keep it secure and use it only for the purposes we specify.

7. Data Storage, Security & Retention

• We implement reasonable technical and organizational safeguards — including access controls, encryption where appropriate, and restricted staff access — to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
• CCTV footage is typically retained for a limited period (e.g., 30–90 days) unless required for a longer duration for security or legal investigation.
• Membership, financial, and hospitality records are retained for as long as your membership is active and thereafter for the period required to meet legal, tax, and regulatory obligations under Indian law.
• Waitlist and enquiry data of individuals who do not proceed with membership may be retained for a reasonable period for follow-up, and deleted or anonymized thereafter upon request or after a defined retention window.
• Data may be stored on secure servers located in India and, where third-party enterprise cloud service providers are used, potentially outside India, subject to appropriate safeguards (see Section 10).

8. Cookies & Website Tracking

Our website (www.101circle.com) may use cookies and similar technologies to:

• Enable core website functionality (e.g., form submissions)
• Understand website traffic and usage patterns
• Remember your preferences

You can control or disable cookies through your browser settings; however, doing so may affect certain website features. We do not use cookies to serve targeted third-party advertising unless separately disclosed.

9. Your Rights

Subject to applicable law, including the DPDP Act, 2023, you have the right to:

• Access the personal data we hold about you
• Correct or update inaccurate or incomplete data
• Withdraw consent for processing based on consent, at any time
• Request erasure of your personal data, subject to our legal, tax, and contractual retention obligations
• Nominate another individual to exercise your rights on your behalf, in the event of death or incapacity
• Lodge a grievance with our Grievance Officer (see Section 13), and if unresolved, escalate to the Data Protection Board of India

International members and guests may have additional rights under their local data protection laws (e.g., GDPR rights of data portability and objection), which we will honor to the extent applicable.

To exercise any of these rights, please contact us using the details in Section 13.

10. Cross-Border Data Transfers

Where personal data is transferred outside India — for example, to cloud service providers, international payment processors, or global hospitality partners — we take steps to ensure such transfers are subject to appropriate contractual and security safeguards consistent with applicable law.

11. Children's Data

101 Circle membership and services are intended for adults. We do not knowingly collect personal data from individuals under the age of 18 through our website registration form, except where a parent or legal guardian provides information about a minor dependent in connection with family membership or event attendance, in which case such data is processed only with verifiable parental/guardian consent and solely for the stated purpose.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services (including the launch of the boutique hotel), or legal requirements. The "Last Updated" date at the top of this Policy indicates when it was last revised. Material changes will be notified to members through appropriate channels (e.g., email or website notice).

13. Contact Us / Grievance Officer

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, or wish to file a grievance, please contact:

Data Protection & Grievance Officer
JSVP Hospitality Private Limited
(Operating Unit: 101 Circle)
Golf Course Road, Gurugram, Haryana, India

Official Communication: info@101circle.in
Phone: +91 9194000101

We aim to acknowledge and address grievances within the timelines prescribed under applicable law.