Clubside Tours & Travels Private Limited (herein after “Clubside”)recognizes the importance of privacy of its users and also of maintaining confidentiality of the information provided by its users as a responsible data controller and data processer.
USERS OUTSIDE THE GEOGRAPHICAL LIMITS OF INDIA
Please note that the data shared with Clubside shall be primarily processed in India and such other jurisdictions where a third party engaged by Clubside may process the data on Clubside’s behalf. By agreeing to this policy, you are providing Clubside with your explicit consent to process your personal information for the purpose(s) defined in this policy. The data protection regulations in India or such other jurisdictions mentioned above may differ from those of your country of residence.
If you have any concerns in processing your data and wish to withdraw your consent, you may do so by writing to the following email id: email@example.com However, if such processing of data is essential for us to be able to provide service to you, then we may not be able to serve or confirm your bookings after your withdrawal of consent. For instance, if you want to book any holiday package in fixed departures (group bookings), then certain personal information of yours like contact details, gender, dietary preferences, choice of room with smoking facility, any medical condition which may require specific attention or facility etc. may have to be shared by us with our vendors in each city where you will stay, and they may further process this information for making suitable arrangements for you during the holiday. Such sharing and processing of information may extend to the hotel where you will stay or the tour manager who will be your guide during the travel.
A withdrawal of consent by you for us to process your information may:
TYPE OF INFORMATION WE COLLECT AND ITS LEGAL BASIS
The information as detailed below is collected for us to be able to provide the services chosen by you and also to fulfill our legal obligations as well as our obligations towards third parties as per our User Agreement.
"Personal Information" of User shall include the information shared by the User and collected by us for the following purposes:
Registration on the Website : Information which you provide while subscribing to or registering on the Website, including but not limited to information about your personal identity such as name, gender, marital status, religion, age etc., your contact details such as your email address, postal addresses, frequent flyer number, telephone (mobile or otherwise) and/or fax numbers. The information may also include information such as your banking details (including credit/debit card) and any other information relating to your income and/or lifestyle; billing information payment history etc. (as shared by you).
Other information : We may also collect some other information and documents including but not limited to:
HOW WE USE YOUR PERSONAL INFORMATION
The Personal Information collected maybe used in the following manner:
WHILE MAKING A BOOKING
While making a booking, we may use Personal Information including, payment details which include cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details, wallet details etc. as shared and allowed to be stored by you. We may also use the information of travelers list as available in or linked with your account. This information is presented to the User at the time of making a booking to enable you to complete your bookings expeditiously.
WE MAY ALSO USE YOUR PERSONAL INFORMATION FOR SEVERAL REASONS INCLUDING BUT NOT LIMITED TO
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
Clubside will retain your Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this policy. In some circumstances we may retain your Personal Information for longer periods of time, for instance where we are required to do so in accordance with any legal, regulatory, tax or accounting requirements.
Where your personal data is no longer required, we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
COOKIES AND SESSION DATA
Cookies are small pieces of information that are stored by your browser on your device's hard drive. Cookies allow us to serve you better and more efficiently. Cookies also allow ease of access, by logging you in without having to type your login name each time (only your password is needed); we may also use such cookies to display any advertisement(s) to you while you are on the Website or to send you offers (or similar emails – provided you have not opted out of receiving such emails) focusing on destinations which may be of your interest.
A cookie may also be placed by our advertising servers, or third party advertising companies. Such cookies are used for purposes of tracking the effectiveness of advertising served by us on any website, and also to use aggregated statistics about your visits to the Website in order to provide advertisements in the Website or any other website about services that may be of potential interest to you. The third party advertising companies or advertisement providers may also employ technology that is used to measure the effectiveness of the advertisements. All such information is anonymous. This anonymous information is collected through the use of a pixel tag, which is an industry standard technology and is used by all major websites. They may use this anonymous information about your visits to the Website in order to provide advertisements about goods and services of potential interest to you. No Personal Information is collected during this process. The information so collected during this process, is anonymous, and does not link online actions to a User
Most web browsers automatically accept cookies. Of course, by changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. Clubside supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking MMT cookies may disable certain features on the Website, and may hinder an otherwise seamless experience to purchase or use certain services available on the Website. Please note that it is possible to block cookie activity from certain websites while permitting cookies from websites you trust.
AUTOMATIC LOGGING OF SESSION DATA
Each time you access the Website your session data gets logged. Session data may consist of various aspects like the IP address, operating system and type of browser software being used and the activities conducted by the User while on the Website. We collect session data because it helps us analyze User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on. It also helps us diagnose problems with our servers and lets us better administer our systems. The aforesaid information cannot identify any User personally. However, it may be possible to determine a User's Internet Service Provider (ISP), and the approximate geographic location of User's point of connectivity through the above session data.
WITH WHOM YOUR PERSONAL INFORMATION IS SHARED
SERVICE PROVIDES AND SUPPLIERS
Your information shall be shared with the end service providers like airlines, hotels, 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 Clubside you authorize us to share your information with the said service providers and suppliers. It is pertinent to note that Clubside does not authorize the end service provider to use your information for any other purpose(s) except as may be for fulfilling their part of service. However, how the said service providers/suppliers use the information shared with them is beyond the purview and control of Clubside as they process Personal Information as independent data controllers, and hence we cannot be made accountable for the same. You are therefore advised to review the privacy policies of the respective service provider or supplier whose services you choose to avail.
Clubside 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 referral services and for sharing promotional and other benefits to our customers from time to time basis their booking history with us.
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. This will enable us to provide you with information about various products and services, both leisure- and travel-related, which might interest you; or help us address your questions and requests in relation to your bookings.
If the assets of Clubside 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/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.
BUSINESS PARTNERS AND THIRD-PARTY VENDORS
Clubside may share your Personal Information to third party that Clubside may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, and data processing platforms.
We use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher quality, more useful online services by performing statistical analysis of the collective characteristics and behavior of our customers and visitors, and by measuring demographics and interests regarding specific areas of the Website. We may provide anonymous statistical information 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 as to the number of people who have seen and clicked on links to their websites. Any Personal Information which we collect and which we may use in an aggregated format is our property. We may use it, in our sole discretion and without any compensation to you, for any legitimate purpose including without limitation the commercial sale thereof to third parties.
Occasionally, Clubside 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 are protected by confidentiality agreements and such information is to be used solely for completing the specific project, and in compliance with the applicable regulations.
DISCLOSURE OF INFORMATION
In addition to the circumstances described above, Clubside may disclose User's Personal Information if required to do so:
USER GENERATED CONTENT
Clubside provides an option to its users to post their experiences by way of reviews, ratings and general poll questions. The customers also have an option of posting questions w.r.t a service offered by Clubside or post answers to questions raised by other users. Clubside may also hire a third party to contact you and gather feedback about your recent booking with Clubside. Though the participation in the feedback process is purely optional, you may still receive emails, notifications (app, sms, Whatsapp or any other messaging service) for you to share your review(s), answer questions posted by other users or a. The reviews may be written or in a video format. The reviews written or posted may also be visible on other travel or travel related platforms.
The UGC that Clubside collects may be of the following kinds:
HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?
You will occasionally receive e-mail updates from us about fare sales in your area, special offers, new Clubside services, and other noteworthy items. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the "unsubscribe" link or follow the instructions in each e-mail message.
PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS
When the Clubside app is installed on your phone or tablet, a list of permissions appear and are needed for the app to function effectively. There is no option to customize the list. The permissions that Clubside requires and the data that shall be accessed and its use is as below :
Device & App History : We need your device 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.
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.
SMS : If you allow us to access your SMS, we 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.
Phone : The app requires access to make phone calls so that you can make phone calls to hotels, airlines and 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 your hotel/ flight/ holidays with your friends, inviting your friends to try our app, send across referral links to your friends, etc. We may also use this information to make recommendations for hotels where your friends have stayed. This information will be stored on our servers and synced from your phone. 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. This provides you a seamless Map based Hotel selection experience, even on low bandwidth network.
Calendar : This permission enables us to put your travel plan on your calendar.
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.
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. We will also use this information to make recommendations for hotels where your friends have stayed. This information will be stored on our servers and synced from your phone.
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. We require this permission to recommend your nearest hotels in case you are running late and want to make a quick last minute booking for the nearest hotel. Your options are personalized basis your locations. For international travel, this enables us to determine your time zone and provide information accordingly.
HOW WE PROTECT YOUR PERSONAL INFORMATION?
All payments on the Website are secured. This means all Personal Information you provide is transmitted using TLS (Transport Layer Security) encryption. TSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.
WITHDRAWAL OF CONSENT AND PERMISSION
You may withdraw your consent to submit any or all Personal Information or decline to provide any permissions on its Website as covered above at any time. In case, you choose to do so then your access to the Website may be limited, or we might not be able to provide the services to you. You may withdraw your consent by sending an email to firstname.lastname@example.org
YOUR RIGHTS QUA PERSONAL INFORMATION
You may access your Personal Information from your user account with Clubside. You may also correct your personal information or delete such information (except some mandatory fields) from your user account directly. If you don’t have such a user account, then you write to email@example.com
ELIGIBILITY TO TRANSACT WITH MMT
You must atleast 18 years of age to transact directly with and also to consent to the processing of your personal data.