PRIVACY POLICY

Ghoomo Tech Services India Private Limited, is a private limited company incorporated under the Companies Act, 2013 having its registered office located at 103, Navyug Industrial Estate, T. J. Road, Sewri West, Mumbai - 400 015. (hereinafter shall be referred to as “Company”, “We”, “Us”, “Our” and terms of similar meaning).

This website is published and maintained by the Company. The Privacy Policy & Disclaimer (as defined hereunder), is applicable to the websites of the Company including www.ghoomo.com, which also comprises of the mobile site, smartphone app platforms such as iOS, android, windows (all together referred to as “Website”). This Privacy Policy does not apply to the websites of our business partners, corporate affiliates or to any other third parties, even if their websites are linked to the site. We recommend you to review the respective privacy statements of the other parties with whom you interact.

This privacy policy and disclaimer, as amended from time to time (“Privacy Policy/ Privacy Policy & Disclaimer”) forms part and parcel of the www.ghoomo.com/terms-and-conditions (“Terms”) and is included therein by this reference. The capitalized terms which have been used herein but are not specifically defined shall have the same meaning as attributed to such term in the Terms. In the event of any inconsistency between the Terms and this Privacy Policy & Disclaimer, the Privacy Policy & Disclaimer will supersede solely in respect of the content contained herein and not in respect of any other clause, term or provision contained in the Terms.

By accessing the Website or otherwise using the Website, you (hereinafter referred to as “You”, “Your”, “User”, “Customer” as applicable) expressly consent to Our collection, storage, use and disclosure of the Information (as defined hereunder) in accordance with the terms of this Privacy Policy & Disclaimer.

As We update, improve and expand the Website, this Privacy Policy & Disclaimer may change at Our sole discretion without notice, so please refer back to it periodically as You will be deemed to be governed by the terms of such modified Privacy Policy & Disclaimer, as it comes into effect from time to time. By using Our Website, you are deemed to have read, acknowledged and accepted all the provisions stated herein this Privacy Policy & Disclaimer, including any changes that we may make from time to time. This online Privacy Policy & Disclaimer applies only to information collected through our Website and not to information collected offline.

1. REGISTERED USERS
a) If You choose to become a registered member of the Website, You must provide Your name, address, telephone number, e-mail address, a unique login name, password, and password validation, and a password hint to help you remember Your password.

b) As a member, You can choose to complete Your online account by providing Us with travel preferences, frequent - traveller or affinity numbers, credit card billing information, paper ticket delivery address, and other personal Information. This information is primarily used to assist You in making reservations quickly without having to type in the same information repeatedly.

c) The Website cannot be held responsible for lapses in security caused by third party accesses to Your Personal Information as a result of Your failure to keep Your Personal Information private. Notwithstanding the foregoing, You must notify Us immediately if there is any unauthorised use of your account by any other internet user or any other breach of security.

d) Minors (as defined under the laws of their jurisdiction or residence) are not eligible to register for, use, or purchase the products or services available on Our Website. We do not knowingly collect Personal Information from any minor, and will not use this information if We discover that it has been provided by a minor.

2. TYPE OF INFORMATION COLLECTED
a) In order for You to access certain services, We collect personal, non-personal and other information and correspondences from You, as detailed below, that We consider necessary for achieving this purpose (such information and correspondences hereinafter collectively referred to as “Information”).

b) Personal Information: Personal Information shall include all information that can be linked to a specific individual or to identify any individual, such as name, address, mailing address, telephone number, email address, credit card number, cardholder name, expiration date, information about the travel, bookings, passengers, frequent traveller / flier numbers, and any and all details that may be necessary from the customer (“Personal Information”).

Note: Any content on the Website shared by You or end users via reviews, blogs, online chat or instant messages, discussion boards, forums, user testimonials etc. are not considered as Personal Information and is not subject to the terms of this Privacy Policy. We will not be responsible for the accuracy or filtration of any of the content posted on Our Website by You or any end user, however, We will be entitled to removed any content posted by any person on Our Website which We, in Our sole discretion, consider offensive, discriminatory, racist, defamatory or inappropriate in nature.

c) Non-Personal Information: When You visit the Website, We may collect certain non- personal information such as domain and host from which You access the internet, Your internet protocol address, operating system, browser type, and internet service provider. This type of information does not identify You personally.

d) Mobile: When You use the Website through Your mobile, We may receive information about Your location and Your mobile device, including a unique identifier number for Your device. We may use this information to provide You with suggestions in respect of services if required.

e) When browsing our Website, you are not required to provide any Personal Information unless and until you choose to make a purchase or sign up for one of our e-mail newsletters or other services as described below. You may, however, visit our site anonymously.

3. USE OF YOUR INFORMATION
a) We do not sell, trade, or otherwise transfer to outside parties Your Information. This does not include trusted third parties who assist Us in operating Our Website, conducting Our business, or servicing You. We may also release Your information when We believe release is appropriate to comply with the law, enforce Our Website policies, or protect Ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

b) We process the Information You provide in any one or more of the following manner:

i. To process and fulfil Your request for Services,

ii. To personalize your experience

iii. For providing Services, We may disclose Your Personal Information to the Company’s and/or other registered business partners (as applicable).

iv. The Company shall be entitled to process the Information in accordance with this Privacy Policy & Disclaimer and as permitted by the applicable law;

v. To improve our Services;

vi. To enforce our Terms;

vii. To contact You and to customise Our communication with You and the marketing material we share with You;

viii. Your information, whether public or private shall be used for the purpose of delivering the purchased product or service requested and additionally analyse and suggest if any other related product / service that shall be suitable for you.

ix. The email address You provide for order processing, may be used to send You information and updates pertaining to Your order, in addition to receiving occasional company news, updates, related product or service information, etc.

x. To avoid fraud and other prohibited or illegal activities;

xi. To protect the security or integrity of the Website, Our business, Services and users;

xii. To publish any testimonials or reviews that You may have provided on the Website;

xiii. We may disclose Information, in good faith, wherein the access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable Terms, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law; and

xiv. Additionally, in the event of a audit, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings), We may share/transfer/assign the Information we have collected to the relevant third party.

4. DATA RETENTION
We shall be entitled to retain Your Information for Our record for a period of two years after the deletion of Your Account with us and such Information shall be used Us only in consonance with this Privacy Policy & Disclaimer.

5. ACCESSING AND UPDATING YOUR INFORMATION
As a User of the Website, You can update or modify the Personal Information you have included in your profile or change your username by logging in and accessing Your account. Though You may delete Your account, You acknowledge that it may be impossible to remove your account without some residual information being retained by the Website.

You may at any time access, delete or change your Personal Information or subscribed services. You can easily access your Personal Information if you login as a member on our Website or you can follow the links that may be provided within our subscription emails to you to manage your subscription preferences.

6. SECURITY
We use reasonable security measures to protect Information from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Information. When the Services are accessed using Internet Explorer, Firefox, Safari, or Chrome or any Secure Socket Layer (“SSL”), or such technology that may protect Information using both server authentication and data encryption. We host Our Website in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. All supplied sensitive/credit information is transmitted via SSL technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, Your sensitive private financial information (such as credit cards) will not be stored on our servers. The foregoing is subject to Your compliance with the following:

i. Account Security: You are responsible for maintaining the security and confidentiality of Your user ids and passwords while accessing the Website as a User (“User Account”). You acknowledge that neither the Company nor any of its directors, shareholders or other representatives shall be liable to You under any circumstances for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of, or a breach or, or compromise of registration of Your User Account with us and/or Your ability or inability to use the User Account or.

ii. Credit Card Security: We use third-party payment processors (“Payment Processors”) for any payments made on this Website. The processing of payments will be subject to the terms, conditions and privacy policies of the Payment Processors in addition to the Terms. You acknowledge that neither the Company nor any of its directors, shareholders or other representatives shall be liable to You under any circumstances for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of Your use of the Payment Processors, Your payment through the Payment Processors or Your ability or inability to complete the payment.

iii. Safeguard Sensitive Information: Sensitive details like Credit/Debit Card and Net Banking information are primarily collected by the Payment Processors and banks and not by Us. However, if this information is stored on our Website, it remains completely unshared and safe. Sometimes, such information is shared with certain third parties to process the applicable cash-back offers & discounts.

7. COOKIES
We use cookies.

8. ANDROID AND IOS PERMISSIONS
When Ghoomo App (“App”) is installed on Your phone, a list of permissions appears. Since there is no option to customize those permissions, below is a description of the permissions that the App requires and the data that the App shall access and use.

c) Android permissions

i. Device & App history: We need Your device’s permission to get information about Your device, like OS (operating system) name, OS version, mobile network, hardware model, unique device identifier, preferred language, etc. Basis these inputs, We intend to optimize Your travel booking experience, use OS specific capabilities to drive great in-funnel experiences using components of device’s OS, etc.

ii. Identity: This permission enables Us to know about details of Your account(s) on Your mobile device. We use this info to auto-fill Your email ID’s and provide a typing free in- funnel experience. It helps Us map email ID’s to a particular User to give You the benefit of exclusive travel offers, wallet cash-backs, etc. It also allows facilitating Your Facebook and Google+ login.

iii. Location: This permission enables Us to give You the benefit of location specific deals and provide You a personalized in-funnel experience. When You start the App to make a travel booking, We auto-detect Your location so that Your nearest airport or city is auto-filled. For international travel, this enables Us to determine Your time zone and provide information accordingly.

iv. SMS: If You allow Us to access Your SMS, We will read Your SMS to autofill or prepopulate ‘OTP’ while making a transaction and to validate Your mobile number. This provides You a seamless purchase experience while making a booking and You don’t need to move out of the app to read the SMS and then enter it in the App.

v. Phone: The App requires access to make phone calls so that You can make phone calls to, airlines and Our customer contact centers directly through the App.

vi. contacts: If You allow Us to access Your contacts, it enables Us to provide a lot of social features to You such as sharing Your hotel/ flight/ holidays with Your friends, inviting Your friends to try Our App, send across referral links to Your friends, etc. This information will be stored on Our servers and synced from Your phone.

vii. Photo/ Media/ Files: The libraries in the App use these permissions to allow map data to be saved to Your phone's external storage, like SD cards. By saving map data locally, Your phone doesn't need to re-download the same map data every time You use the App.

viii. Wi-Fi connection information: When You allow Us the permission to detect your Wi-Fi connection, We optimize Your experience such as more detailing on maps, better image loading, more hotel/ flights/ package options to choose from, etc.

ix. Device ID & Call information: This permission is used to detect Your android ID through which We can uniquely identify users. It also lets Us know your contact details using which We pre-populate specific fields to ensure a seamless booking experience.

x. Calendar: This permission enables Us to put Your travel plan on Your calendar.

d) iOS Permissions:

i. Notifications: If You opt in for notifications, it enables Us to send across exclusive deals, promotional offers, travel related updates, etc. on Your device. If You do not opt for this, updates for Your travel like PNR status, booking confirmation, refund (in case of cancellation), etc. will be sent through SMS.

ii. Contacts: If You opt in for contacts permission, it enables us to provide a lot of social features to You such as sharing your hotel/ flight/ holidays with Your friends, inviting Your friends to try our app, send across referral links to Your friends, etc. This information will be stored on our servers and synced from Your phone.

iii. Location: This permission enables Us to give You the benefit of location specific deals and provide You a personalized in-funnel experience. When You launch Our app to make a travel booking, We auto-detect Your location so that your nearest Airport or City is auto-filled. Your options are personalized basis your locations. For international travel, this enables Us to determine Your time zone and provide information accordingly.

9. LINKS TO THIRD PARTY SITES
The Website may include links to third party applications/websites (“Third Party Sites”). Such Third Party Sites are governed by their respective privacy policies, which are beyond Our control. Once You leave Our Website, use of any information You provide is governed by the privacy policy of the operator of the Third Party Site You are visiting. That policy may differ from Ours. If You can't find the privacy policy of any of these Third Party Sites, You should contact the relevant Third Party Site directly for more information.

We do not provide any Personal Information or personally identifiable information to third party websites/advertisers/ad-servers without Your consent.

10. ADVERTISING
We use third-party service providers to display ads on Our behalf across the internet and sometimes on this Website. They may collect anonymous information about Your visits to Our Website, and Your interaction with Our 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 standard technology used by most major websites in the industry. No personally identifiable information is collected or used in this process.

11. OPTING-OUT
a) As part of the registration process, We give You the ability to receive via e-mail or direct messaging information about Our Products and Services, updates to Our Website, customized advertisements and promotions that are targeted to Your specific interest, such as flight specials, promotions, contests, sweepstakes and other travel opportunities available on Our Website and/or sponsored by Our travel Service Providers and advertisers. We send this information directly ourselves, or via third party service providers.

12. YOUR CONSENT
By using the Website and/ or by providing Your Information, You consent to the collection and use of such Information in accordance with this Privacy Policy & Disclaimer, including but not limited to Your consent for sharing Your Information as per this Privacy Policy & Disclaimer. You specifically agree and consent to us collecting, storing, processing, transferring and sharing Information (including Personal Information) related to You with third parties, service professionals or to registered vendors/users for the purposes as set out in this Privacy Policy & Disclaimer.

13. CONTACTING US
If there are any questions regarding this Privacy Policy, please reach to us at +91 22-2410 2801 or write to us at 103, Navyug Industrial Estate, T. J. Road, Sewri West, Mumbai - 400 015.. If you are not satisfied (after a period of 10 days from the date of writing to 103, Navyug Industrial Estate, T. J. Road, Sewri West, Mumbai - 400 015.), please write to the Grievance Officer.

Any complaints, abuse or concerns with regards to content and or comment or breach of this Privacy Policy & Disclaimer shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email:

Details of the Grievance Officer:

1. Name: Swati Chauhan

2. Email: support@ghoomo.com

Thank you for using the Website!