Privacy Policy
This Privacy (“Policy”) applies to securing and processing of personal data by
Turban Adventures in connection with personal data provided by any person (“User”)
who has purchased
or intends to purchase or inquiries about any product(s) or service(s) made by
Turban Adventures
through any of Turban Adventures interface channels including website, mobile site
and mobile app
(collectively referred herein as“ Sales Channels”).
- References in this policy to “you” or “your” are
references to ‘User’.
- References to “we”, “us” or “our” are references to
‘Turban Adventures’.
- References to “website” mean a reference to
‘website(s)’, ‘mobile
site(s)’ and mobile app(s).
- By accessing or using the website or any other sales
channel, the User
agrees with the term 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.
- Your privacy is important to us and we recognise
that the use and disclosure
of personal data has important implications for us and for the users whose
personal data we process.
- By using or accessing the Website or other Sales
Channels, the user hereby
agrees with the terms of this Privacy Policy and the contents here in.
Purpose of the 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/guidelines. We are committed to
protecting your personally identifiable information by which you can be identified
(hereafter referred as “information” or “personal information” or “personal data” or
“special category of personal data”) by handling it responsibly and safeguarding it by
using appropriate technical and organizational measures.
What Personal Data we collect?
- We may collect the following personal and sensitive
information from you while
transacting
through us:
- Name, gender, age and date of birth
- Contact information, such as address, email, and
mobile phone number
- Country of residence
- Credit Card details
- 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 (for
example your income,
investments and
tax
residency)
- Postings or messages on any blogs, forums,
platforms, wikis or social
media
applications of
Turban Advenures and Turban Adventures 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 or call centres
- Details of how you like to interact with us, and
other similar
information
relevant to our
relationship
-
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 (for example, so that we can make it easy
for you to access our
buildings, products
and services, and/or for any special assistance required by you)
-
Personal information of other customers/users/travellers, 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
-
The other information that we collect
- Analytics: Google Analytics,
Appsflyer, Facebook Ads
conversion
tracking, Google
Tag
Manager, Intent Media.
- Adobe Analytics: Cookies, Usage
Data and various types
of Data
as specified in
the privacy
policy of the service.
- Infrastructure monitoring:
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.
- 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.
How do we collect Personal Data?
- Directly: We obtain personal data directly
from individuals in a variety of ways, including but not limited to obtaining
personal data from individuals who provides us their business card, complete our
online forms on our website/mobile app, provides records relating to previous
requests or reservations made, subscribes to our newsletters and preference centre,
registers for webinars, attends meetings or events we host, visits our offices. We
may also obtain personal data directly when, for example, we are establishing a
business relationship, performing professional services through a contract, or
through our hosted software applications.
- Indirectly: We obtain personal data
indirectly about individuals from a variety of sources, including but not limited to
from the travel agents, other travel websites, social media, authorized
representative when such person is seeking travel services information on others
behalf and our clients. We may attach personal data to our customer relationship
management records to better understand and serve you, satisfy a legal obligation.
- Public source: 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 clients’ control on our hosted software
applications. All such processing will be governed by Turban Adventures client’s
privacy policy.
How will we use/process your personal data?
-
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 reservation and booking the
services for you and for individuals whose information has been provided by
you.
- Information like Credit Card Details and Net Banking
Details are usually collected directly by the payment gateways and banks and
not by Turban Adventures, but if ever stored or retained by us, remain
internal.
- 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 no,
e-mail address and postal address may be used for promotional purposes.
- 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.
- 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.
-
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 site.
Cookies are identifiers which web sites send to the browser on your computer
to facilitate your next visit to our site. 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
With whom do we share your Personal Data
- Other members of the Turban Adventures group companies or
third parties that provide services.
- Competent authorities (including appropriate legal authority
and authorities regulating us for internal compliance and audit(s)).
- Other organization to whom we may transfer our rights and/or
obligations under the Terms agreed between Turban Adventures and respective
organization.
- Any other person or organization after a restructure, sale
or acquisition of any member of the Turban Adventures, as long as they use your
personal information for the same purposes we did.
- Credit reference agencies or other organizations that help
us make credit decisions and reduce the incidence of fraud.
- Other third parties that reasonably require access to
personal data relating 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 most 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.
Information Protection & 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 organisational measures to ensure a level of security
appropriate to the risk of processing, including:
- The encryption of personal data
- The ability to ensure the on going 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;
and
- A process for regularly testing, assessing and evaluating
the effectiveness of technical and organisational 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 in when processing personal data.
To protect your personal data and prevent unauthorized access,
we have put in place appropriate security measures and certifications. We require any
third parties processing your information to do the implement the same levels of
protection with respect to your data.
While no system is full-proof, 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.
Data Retention
We will only retain your personal data for as long as
necessary to fulfil the purposes we collected it for. This includes, for example, the
purposes of satisfying any legal, regulatory, accounting, reporting requirements, to
carry out legal work, for the establishment or defence of legal claims.
We will retain your personal data in our databases in
accordance with our document management, retention and destruction policy and applicable
laws. This period may extend beyond the end of your relationship with us, but it will be
only as long as it is necessary for us to have sufficient information to respond to any
issues that may arise later. For example, we may need or be required to retain
information to allow you to obtain credit for trip you purchased but had to cancel. We
may also need the retain certain information to prevent fraudulent activity; to protect
ourselves against liability, permit us to pursue available remedies or limit any damages
that we may sustain; or if we believe in good faith that a law, regulation, rule or
guideline requires it.
In some circumstances we may anonymise your personal data (so
that it can no longer be associated with you) for research or statistical purposes in
which case we may use this information indefinitely without further notice to
you.
Changes to The Policy
This notice is effective as of 1st January 2020. We reserve
the right to update or change this Policy at any time, and we will provide you with the
updated policy when we make any substantial updates at the earliest either through email
or by providing a prominent notice of change on our Website. You should check the policy
periodically. Your continued use of our Website after we post any modifications to the
policy on this page will constitute your acknowledgment of the modifications and your
consent to abide and be bound by the modified notice.
Your Rights
Under certain circumstances, you have rights under applicable
data protection laws in relation to your personal data. It is our policy to respect your
rights and we will act promptly and in accordance with any applicable law, rule or
regulation relating to the processing of your personal data. We may need to request
specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to
your request to speed up our response.We try to respond to all legitimate requests
within one calendar month. Occasionally it may take us longer than one calendar month if
your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
