Club Travalet Privacy Policy – Your Data Protection & Rights

INTRODUCTION

This Privacy "Policy" applies to the securing and processing of personal data by Club Travalet (hereinafter "Club Travalet" ) in connection with personal data provided by any person "User" who has purchased or intends to purchase or inquires about any product or service made by Club Travalet through any of Club Travalet"s interface channels including website, mobile site, and mobile app collectively referred herein as "Sales Channels"

For the purpose of Privacy Policy:

References in this policy to "you" or "your" are references to "User"
References to "we", "us" or "our" are references to "Club Travalet"
References to "website" mean a reference to "website", "mobile site" and mobile app

By accessing or using the website or any other sales channel, the User agrees with the terms of the Privacy Policy and the contents herein. If you disagree with the Privacy Policy, please do not access or use our website or any other Sales Channels.

This privacy policy does not apply to any third-party website, mobile site, and mobile app. Users are requested to take note that information and privacy practices of Club Travalet"s business partners, advertisers, sponsors, or other sites to which Club Travalet provides hyperlink, may be different from this privacy policy. Hence, it is recommended that you review the privacy policy of any such third parties before you interact.

Your privacy is important to us and we recognize that the use and disclosure of personal data has important implications for us and for the users whose personal data we process.

PURPOSE OF THIS POLICY

We respect your need to understand how and why information is being collected, used, disclosed, transferred, and stored. Thus, we have developed this Policy to familiarize you with our practices. This policy sets out the way in which we process your information when you use our Website or other digital platforms in accordance with applicable data protection laws. It is important that you read this policy together with any other policies we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your personal data. This policy supplements the other notices and is not intended to override them.

DEFINING CONTROLLER & PROCESSOR OF PERSONAL DATA

A "Controller" is a person or organization who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This notice is issued on behalf of Club Travalet as Controller. Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller. Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller.

TYPE OF PERSONAL DATA WE COLLECT

Personal data includes any information about any user from which that person can be identified. It does not include personal data where the identity has been removed (anonymous data). You may be asked for personal data anytime you are in contact with Club Travalet directly or indirectly through a third party. We collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy. We do not collect any special categories of personal data about you through our Website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, or data on or about children). Nor do we collect any information about criminal convictions and offences. We collect, use, store, and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this Notice:

"Contact Data": including your residential address, work address, email address, and telephone numbers;
"Identity Data": including your first name, last name, username or similar identifier, and title;
"Website User Data": Usernames, Passwords, and other security-related information used by you in relation to our services;
"Transaction Data": Transactional history about your e-commerce activities and buying behavior. Information pertaining to any other traveler for whom you made a booking through your registered Club Travalet account. In such a case, you must confirm and represent that each of the other traveler for whom a booking has been made has agreed to have the information shared by you disclosed to us and further be shared by us with the concerned service provider.
"Marketing and Communications Data" : including your marketing and communication preferences. We also track when you receive and read marketing communications from us, which information we use to improve our marketing services, provide you with more relevant information, and improve the quality of our marketing materials. Additional information about the personal data we process in connection with marketing is included with the marketing communications we send you;
"Public Domain or Third Party Data": Data available in the public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures, or any other information that is permitted to be received as per your account settings) as a part of your account information.
"Profile Data": including information collected progressively when you visit our site, including your referral website, pages you visit, actions you take, patterns of page visits, and information from forms you fill in;
"Technical Data": includes information collected when you access our website, mobile site, or mobile app—your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you are using;
"Usage Data": information about how you use our Website.
"Any other Personal Data" : If you request Club Travalet to provide visa-related services, then copies of your passport, bank statements, originals of the filled-in application forms, photographs, and any other information which may be required by the respective embassy to process your visa application. If you request Club Travalet to provide foreign exchange (Forex) related services, then passport copies, A2 forms, air tickets, or travel authentication documents to verify confirmed travel or any other documents required to process your Forex transaction.

MODES OF COLLECTING PERSONAL DATA

The only way we will get any kind of personal data is if you choose to give it to us in the following circumstances:

Direct Interactions

When you make an enquiry or quotation request or make a reservation or purchase from our Website or through our customer service team — by emails, letters, fax, on the phone, or in a physical store.
When you register with us, subscribe to our newsletter, enter in lucky draws/competitions/surveys/feedback, send us queries, or register for promotions.
When you engage with us in any online or offline event, promotions, or pages hosted by us on a third-party platform or location.

Cookies & other technologies

We receive technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see the cookie policy for further details of the information collected.

GROUNDS FOR PROCESSING OF DATA

When you use our Website, we will use your personal data in the following circumstances:

Performance of a contract: where we need to perform a contract which we are about to enter into or have entered into with you as a party, or to take steps at your request before entering into such a contract.
Legal or regulatory obligation: where we need to comply with a legal or regulatory obligation that we are subject to.
Legitimate interests: where necessary for our interests, provided that your fundamental rights do not override such interests. This can mean, for instance, that it is in our interest to monitor how you are using our Website or client portals to ensure that the security of our Website, client portals, or systems is maintained. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
Consent: We rely on consent as a legal basis for processing your personal data in relation to sending direct marketing communications to you via email or text message. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

COLLECTION AND USE OF NON-PERSONAL DATA

Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on our various portals. This aggregated information is used in research, analysis, to improve and monitor products, and for various promotional schemes. It may be shared in aggregated, non-personal form with third parties to enhance customer experience, product offerings, or services.

COOKIES AND OTHER TECHNOLOGIES

We use cookies and other technologies to enhance your experience when you use our Website. To that effect, we have developed a cookie policy to familiarize you with our practices. You can access the cookie policy.

LINKS

For your convenience, our Website provides links to other sites. When you click on one of these links, you are leaving our Website and entering another site. We are not responsible for such third-party sites. You should carefully review the privacy statements of any other sites you visit because those privacy statements will apply to your visit to such other sites.

WITH WHOM YOUR PERSONAL DATA IS SHARED

Group Companies (Companies in the same group):

In the interests of improving personalization and service efficiency, we may, under controlled and secure circumstances, share your Personal Information with our affiliate or associate entities. If the assets of Club Travalet are acquired, our customer information may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, as part of business expansion, development, restructuring, or for any other reason whatsoever, if we decide to sell, transfer, or assign our business, any part thereof, any of our subsidiaries, or any business units, then as part of such restructuring exercise, customer information, including the Personal Information collected herein, shall be transferred accordingly.

Service Providers and Suppliers:

Your information shall be shared with the end service providers like airlines, hotels, visa consulates, bus service providers, cab rental, railways, or any other suppliers who are responsible for fulfilling your booking. You may note that while making a booking with Club Travalet, you authorize us and consent to share your information with the said service providers and suppliers. It is pertinent to note that Club Travalet does not authorize the end service provider to use your information for any other purpose(s) except as for fulfilling their part of the service. Club Travalet does not sell or rent individual customer names or other Personal Information of Users to third parties except sharing of such information with our business/alliance partners or vendors who are engaged by us for providing various services and for sharing promotional and other benefits to our customers based on their booking history with us.

Third-Party Vendors and Business Partners:

We may also share certain filtered Personal Information with our corporate affiliates or business partners who may contact the customers to offer certain products or services, which may include free or paid products/services, enabling the customer to have a better travel experience or to avail of certain benefits specially made for Club Travalet customers. Examples of such partners are entities offering savings/EMI on travel, co-branded credit cards, travel insurance, insurance cover against loss of wallet, banking cards, or similar sensitive information. If you choose to avail of any such services offered by our business partners, the services so availed will be governed by the privacy policy of the respective service provider.

Club Travalet may share your Personal Information with third parties engaged to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, and data processing platforms. We may provide non-personal data based on this data to suppliers, advertisers, affiliates, and other current and potential business partners. We may also use such aggregate data to inform these third parties about the number of people who have seen and clicked on links to their websites. Occasionally, Club Travalet will hire a third party for market research, surveys, etc., and will provide information to these third parties specifically for use in connection with these projects. The information (including aggregate cookie and tracking information) we provide to such third parties, alliance partners, or vendors is protected by confidentiality agreements, and such information is to be used solely for completing the specific project in compliance with applicable regulations.

DISCLOSURE OF INFORMATION

Where required, we will (subject to our professional obligations and any terms of business which we may enter into with you) disclose your personal data to:

Any person or entity to whom we are required or requested to make such disclosure by any court of competent jurisdiction or by any governmental, taxation or other regulatory authority, law enforcement agency, or similar body.
Our professional advisers or consultants, including lawyers, bankers, auditors, accountants, and insurers providing consultancy, legal, banking, audit, accounting, or insurance services to us.
Service providers who provide information technology and system administration services to us.

INTERNATIONAL TRANSFER

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PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS

When the Club Travalet app is installed on your phone, a list of permissions will appear and are needed for the smooth functioning of the application. The permissions that Club Travalet requires and the data that shall be accessed and its use are as below.

Android permissions:

Location: This permission enables us to give you the nearest branch details from your location in case you require any physical assistance with regards to any travel query.
SMS: If you allow us to access your SMS, we can send you SMS related to "OTP" and send holiday package details to your mobile number.
Phone: The app requires access to make phone calls so that you can make phone calls to our customer contact centers directly through the app.
Contacts: If you allow us to access your contacts, it enables us to provide a lot of social features to you, such as sharing holiday packages with your friends, etc.
Photo / Media / Files: The libraries in the app use these permissions to save and cache images and document data for your ease and faster use of the app while you browse with us the next time. By saving image and document data locally, your phone doesn’t need to re-download the same every time you use the app.

iOS permissions:

Notifications: If you opt in for notifications, it enables us to send across exclusive deals, promotional offers, travel-related updates, etc., on your device.

INFORMATION PROTECTION AND SECURITY

Taking into account the costs of implementation and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing, including:

The pseudonymisation and encryption of personal data.
The ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services.
The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

We ensure that those who have permanent or regular access to personal data, or that are involved in the processing of personal data, or in the development of tools used to process personal data, are trained and informed of their rights and responsibilities when processing personal data.

To protect your personal data and prevent unauthorized access, we have put in place appropriate security measures and certifications. We have an SSL site, and users should use it to protect information transmission while transacting online. We require any third parties processing your information to implement the same levels of protection with respect to your data.

While no system is foolproof, including ours, we will continue using internet security procedures to ensure your data remains safe with us. By opening, browsing, using this site for transactions, or storing any data/information, you agree to comply with the latest revised privacy notice in effect at such time.

If you use some social networking or other service which maintains your information, it is governed by their terms of use and privacy notice.

YOUR RIGHTS

Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data. These rights include:

Details of your rights under GDPR are set out below:

Right to be informed — about how personal data is used in a clear, transparent, and easily understandable way.
Right to access personal data — you have a right to obtain confirmation that your data is being processed and access to your personal data.
Right to rectification — you have a right to have inaccurate personal data corrected, or completed if it is incomplete.
Right to erasure (right to be forgotten) — you can request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
Right to restrict processing — you can block or suppress processing of your personal data under certain circumstances.
Right to data portability — you have the right to obtain and reuse your personal data for your own purposes across different services.
Right to object — you have the right to object to certain types of processing, including direct marketing.
Rights in relation to automated decision making and profiling — you have rights not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You may exercise any of the above-mentioned rights by sending a request to admin@clubtravalet.com.