Agiwal Technologies Private Limited, including all legal entities under the Agiwal Group (hereafter referred to as "Agiwal" or "we") respects your (customers - hereafter referred as "you" or "user") privacy and values our relationship with our business partners, clients, third parties having contractual relationship with Agiwal Technologies (hereafter referred to as "third party" or "service provider"), and any party who purchases/intend to purchase/inquire about any product(s) and/or service(s) made available by Agiwal Technologies through any of Agiwal Technologies' s customer interface channels including Website, mobile site, mobile app & ofline channels including call centers and offices (collectively referred herein as "Sales Channels"). We are committed to protecting your personally identifiable information (hereafter referred as "information" or "personal information" or "personal data" or "special category of personal data") by handling it responsibly and safeguarding it using appropriate technical and organizational measures. We want to assure you that we follow appropriate standards when it comes to protecting your privacy on our Sales Channel. This policy outlines the types of personal information collected on our Website, how this data is used/processed and safeguarded as well as how users may exercise their rights with respect to personal information. This Privacy Policy applies to Agiwal Technologies.com, company pages, communications and services ("Services"), including off-site Services, such as our email services, customer care and support services. By using or accessing the Website or other Sales Channels, the user hereby agrees with the terms of this Privacy Policy and the contents herein. This Privacy Policy does not apply to any website(s), mobile sites and mobile apps of third parties, even if their websites/products are linked to our Website. User should take note that the information and privacy practices of Agiwal Technologies’ business partners, advertisers, sponsors or other sites to which we provide hyperlink(s), may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties. Agiwal Technologies for Business (Corporate): In the event Agiwal Technologies is providing services to you as part of our agreement with your employer, contractor, business partner, affiliate or any other party who is having a contractual arrangement with Agiwal Technologies, then the terms and conditions stipulated in such contractual arrangement shall prevail over this data privacy policy. Such agreement may involve sharing personal data they control as part of that engagement. Our services may also include processing personal data under our client's control on our hosted software applications. All such processing will be governed by Agiwal Technologies's client privacy policy. In case you book travel services on behalf of your family or a minor, you agree: • To inform the individual about the content of this privacy policy • To obtain any legally-required consent, for the collection, use, disclosure, and transfer (including cross-border transfer) of individual's personal information, from the individual in accordance with the legal and regulatory requirements In such a scenario, Agiwal Technologies will be acting as data processors while your respective employer, contractor, business partner, affiliate shall be acting as the data controller. It will be the obligation of the data controller to seek consent of the end customer. 1. What Personal Data shall we collect? a. We collect the following personal and sensitive information from you when you transact through us: • Name, gender, age and date of birth • Contact information such as address, email, and mobile phone number • Country of residence • Payment Details like Credit Card/ Debit Card details along with their expiry date (billing address in case of international debit/credit card). • Passport Number & frequent flyer number (wherever needed) • Lifestyle and social circumstances (for example, your hobbies) • Family details/information (for example, your marital status and dependents) • Employment and education details (for example, the organization you work for, your job title and your education details) • Financial and tax-related information (like your income, investments and tax residency) • Postings or messages on any blogs, forums, platforms, wikis or social media applications of Agiwal Technologies and Agiwal Technologies' s third parties • IP address, browser type and language, your access times • Information in any complaints you make • Details of how you use our products and services • CCTV footage and other information we collect when you access our premises • Recording of telephone calls to our representatives and call centers • Details of how you like to interact with us ( through email, SMS or whatsapp) and other similar information relevant to our relationship b. The personal data we collect may also include 'sensitive' or 'special categories' of personal data such as details about your: • Dietary requirements (for example, while providing your meal preference during flight/ hotel bookings) • Health (so that we can make it easy for you to access our buildings, products and services, and/or any special assistance required by you) • Sexual orientation (if you provide us with details of your spouse or partner) If you choose not to provide, or object to us processing the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you (including our clients)Personal information of other customers/users/travelers If you provide personal information to us regarding individuals other than yourself, you agree • To inform the individual about the content of this privacy policy • To obtain any legally-required consent, for the collection, use, disclosure, and transfer (including cross-border transfer) of individual's personal information, from the individual in accordance with the legal and regulatory requirements c. Personal information of child The Services are not intended for users under the age of 16 (Permissible Age), unless permitted under applicable local laws. We do not knowingly collect any personal information from you or the market to solicit information from anyone under the Permissible Age. If we become aware that a person submitting personal information is under the Permissible Age, we will delete the account and any related information immediately. d. We use third party services/bots to capture the following additional information: • Analytics • Infrastructure monitoring Geographic position, unique device identifiers for advertising • Location-based interactions: Geographical locations • Unique device identification: This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences. 2. How do we collect Personal Data? a. Directly: We obtain personal data directly from individuals in a variety of ways , including but not limited to obtaining personal data from individuals who provide their personal information via registrations or guest account for booking travel services, their business card, complete our online forms on our website/mobile app, provide records relating to previous requests or reservations made, Individuals who subscribe to our newsletters and preference center, register for webinars, and attend meetings or events we host or visit our offices. We may also obtain personal data directly when we are establishing a business relationship, performing professional service through a contract, or through our hosted software applications. b. Indirectly: We obtain personal data indirectly about individuals from a variety of sources, which includes but is not limited to travel agents, other travel websites, social media, authorized representative from whom you seek travel services on behalf of others and our clients. We may add personal data to our customer relationship management records to better understand and serve you, or to satisfy a legal obligation. • Public sources - Personal data may be obtained from public sources such as news articles and Internet searches. • Social and professional networking sites - If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want to be shared with us. • Business clients - Our business clients may engage us to provide products/services offered by us which involves sharing personal data they control as part of that engagement. Our services may also include processing personal data under our client's control. 3. What lawful reasons do we have for processing Personal Data? We may rely on the following lawful reasons when we process your personal data to operate our business and provide our products and services: a. Contract - We may process personal information in order to perform our contractual obligations to which you (data subject) or our client (data controller) is party. Please refer to the section - Agiwal Technologies for Business (Corporate) b. Consent - We may rely on your freely given, specific, informed and unambiguous consent at the time you provided your personal information to us for one or more specific purposes c. Legitimate interests - We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced d. Legal obligations - We may process personal information where processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, in particular where the data subject is a child. 4. How will we use/process your personal data a. We do not sell or trade upon any of the above foregoing information without your consent. The foregoing information collected from you is put to the following use: • For the purpose of fulfillment of services which include travel reservation and booking for you and for individuals whose information has been provided by you. • Information like Credit Card/ Debit Card, Expiry Date and Net Banking Details that we store, in case a customer opts for it, are in adherence to the PCI Compliance and are stored in an encrypted form in a segmented zone. We do not store CVV details. These details may also be processed with the help of certain third parties only for the purpose of processing 'Cash Back & Discounts' and Charge Backs, if applicable. • Information like Mobile number, e-mail address and postal address may be used for promotional purposes, unless the customer/user opts-out of such use. • To manage and respond to any request you submit through our website. • To meet legal and regulatory requirements. • Promoting our professional services, products and capabilities to existing and prospective business clients/customers. • Sending invitations and providing access to guests attending our events and webinars or our sponsored events. • Personalizing online landing pages and communications we think would be of interest based on interactions with us and group companies. • To effectively communicate with you like through SMS, emails or whatsapp If you choose not to share this information, you can still visit our website, but you may be unable to avail certain options or our services. b. How we use Cookies? In general, you can visit our website without telling us who you are or revealing any personal information about yourself. We track the Internet address of the domains from which people visit us and analyse this data for trends and statistics, but the individual user remains anonymous. Some of our web pages use "cookies" so that we can better serve you with customized information when you return to our website. Cookies are identifiers which websites send to the browser on your computer to facilitate your next visit to our website. You can set your browser to notify you when you are sent a cookie, giving you the option to decide whether or not to accept it. The information we collect and analyse is used to improve our service to you. 5. With whom do we share your Personal Data? In connection with any of the purposes outlined in the "How will we use/process the personal data" section above, we may disclose details about you to: a. travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service provides b. suppliers of IT based solutions and products that assist us in providing services to you (such as any external data hosting and monitoring providers we may use, communication service providers) c. Competent authorities (including auditors, courts and authorities regulating us for internal compliance and audit(s)) as required or authorized by applicable law, and to comply with our legal and regulatory obligations; d. Credit reference agencies or other third party organizations that help us make credit decisions or conduct risk checks to reduce the incidence of fraud e. Other organizations to whom we may transfer our rights and/or obligations under the Terms agreed between Agiwal Technologies and respective organization f. Any other person or organization after a restructure, sale or acquisition of any member of the Agiwal group, as long as they use your personal information for the same purposes we did g. The analytics service providers which with whom the data may be shared are: • Google Analytics, Appsflyer, Facebook Ads conversion tracking, Google Tag Manager, Datadog, Adara • Crashlytics - Geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service h. We share following data with MoEngage through their SDK which is used to send any personalized App Notification to the end user • Account Name • Account Email Address • Account Mobile Number • Account User ID • User's Location i. And other members of Agiwal Technologies Group/ third parties that may reasonably require access to personal data relating to you or providing services to you. With specific reference to third party, we use third-party service providers to serve ads on our behalf across the Internet and sometimes on this site. They may collect anonymous information about your visits to our website, and your interaction with our products and services. They may also use information about your visits to this and other websites to target advertisements for goods and services. This anonymous information is collected through the use of a 'pixel tag', which is industry standard technology used by various major websites. No personally identifiable information is collected or used in this process. Such third parties do not know your name, phone number, address, email address, or any personal information which can identify you. Our website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively "Social Media Applications"). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy policy. 6. Where do we transfer your Personal Data? Information we hold about you may be transferred to countries: a. where we do business b. which are linked to your engagement with us c. from which you regularly receive or transmit information d. Where our third parties conduct their activities We may share non-personal, anonymized and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity. 7. How we protects your Personal Data? We have implemented appropriate technical and organizational measures to safeguard and help prevent unauthorized access to your information and to maintain data security. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. The third party with respect to payment gateway and payment processing are all validated as compliant with the payment card industry standard (generally referred to as PCI compliant service providers). We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access or other causes beyond our control. You play an important role in keeping your personal information secure. You should not share your user name, password, or other security information of your Agiwal Technologies account with anyone. If we receive instructions using your registered email ID or username, we will consider that you have authorized the instructions. 8. What are your data Protection Rights? Your data protection rights are highlighted below: a. Right to Access - You may ask us to verify whether we are processing personal data about you, and if so, to provide more specific information. b. Right to Correction - You may ask us to correct our records if you believe they contain incorrect or incomplete information about you. c. Right to Erasure - You may ask us to erase (delete) your personal data after you withdraw your consent to process it, or when we no longer need it for the purpose it was originally collected and we shall erase your personal data, subject to the data retention requirements under the applicable rules, regulations, guidelines, law, by-law, to meet our legal/regulatory obligations. Please note, even after completion of your request regarding account or data deletion, we will be retaining transactional data to meet our legal obligations. d. Right to Processing restrictions - You may ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction. e. Right to Data portability - You may request portability of your personal data, which shall be limited to the transfer of information pertaining to the customer profile and transaction records, to another data controller. f. Automated Individual Decision-making - You may ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or significantly affecting you. g. Right to Object to Direct Marketing including Profiling - You may object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you. h. Right to Withdraw Consent - You may withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. However, this may lead to Agiwal Technologies not able to provide certain products or services to you. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds. 9. How long shall we retain/ dispose your Personal Data? We seek to ensure that we only keep your personal data for the longest of: a. the period necessary for the relevant activity or services b. any retention period that is required by law c. the period in which litigation or investigations might arise in respect of the services Please note: Even after your account is terminated, we retain your transactional data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated. 10. Changes to this privacy statement: From time to time we may update this statement. When we do, we will publish the changes on this Website. If you do not agree with these changes, you can discontinue your use of our Website. 11. How to contact us, request access to your personal data or contact us with questions or feedback? If you have a question, comment, or complaint or wish to access a copy of your personal data or to correct it, you may contact us at sharad@agiwalconsulting.com
