Privacy Policy - SPAS
TOURS
Introduction:
SPAS TOURS 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.
This Privacy Policy
provides for the practices for handling and securing user's Personal
Information (defined hereunder) by SPAS TOURS and its subsidiaries and
affiliates.
This Privacy Policy is applicable to any person (‘User’) who purchase,
intend to purchase, or inquire about any product(s) or service(s) made
available by SPAS TOURS through any of SPAS TOURS’s customer interface channels
including its website, mobile site, mobile app & offline channels including
call centres and offices (collectively referred herein as "Sales Channels").
For the purpose of
this Privacy Policy, wherever the context so requires "you" or
"your" shall mean User and the term "we", "us",
"our" shall mean SPAS TOURS. For the purpose of this Privacy Policy,
Website means the website(s), mobile site(s) and mobile app(s).
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. If you disagree with this
Privacy Policy please do not use or access our Website or other Sales Channels.
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 information and privacy practices of SPAS TOURS’s business
partners, advertisers, sponsors or other sites to which SPAS TOURS provides
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 with whom they interact.
This Privacy Policy is an integral
part of your User Agreement with SPAS TOURS and all capitalized terms used, but
not otherwise defined herein, shall have the respective meanings as ascribed to
them in the User Agreement.
USERS OUTSIDE THE GEOGRAPHICAL LIMITS OF INDIA
Please note that
the data shared with SPAS TOURS shall be primarily processed in India and such
other jurisdictions where a third party engaged by SPAS TOURS may process the
data on SPAS TOURS’s behalf. By agreeing to this policy, you are providing SPAS
TOURS 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 the processing your data and wish to withdraw your consent, you may
do so by writing to the following email id: INFO@SPASTOURS.IN. 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 international 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:
·
severely inhibit our ability to serve you properly and in such case, we
may have to refuse the booking altogether, or
·
unreasonably restrict us to service your booking (if a booking is
already made) which may further affect your trip or may compel us to cancel
your booking.
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, profile picture 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 many also collect some other information and documents
including but not limited to:
·
Transactional history (other than banking details) about your e-commerce
activities, buying behavior.
·
Your usernames, passwords, email addresses and other security-related
information used by you in relation to our Services.
·
Data either created by you or by a third party and which you wish to
store on our servers such as image files, documents etc.
·
Data available in 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.
·
Information pertaining any other traveler(s) for who you make a booking
through your registered SPAS TOURS account. In such case, you must confirm and
represent that each of the other traveler(s) 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(s).
·
If you request SPAS TOURS 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.
·
For international bookings, Users, in compliance with the Liberalized
Remittance Scheme(LRS) of RBI or any other law may be required to provide
details such as their PAN information or passport details number or any such
information required by Service Provider. Such information shall be strictly
used as per the aforesaid requirements only. In case a User does not wish to
provide this information, SPAS TOURS may not be able to process the booking. SPAS
TOURS will never share User’s PAN details without their prior consent unless
otherwise such action is required by any law enforcement authority for
investigation, by court order or in reference to any legal process.
·
In case you opt for contactless check-in at Hotels, then copies of your
government identification like aadhar, driving license, election card etc.,
Self-declaration and any other information like date of birth,
destination/origin of travel and place of residence that may be required by the
concerned Hotel to honor your hotel booking.
·
For international bookings, Users, in compliance with the Liberalized
Remittance Scheme(LRS) of RBI or any other law may be required to provide
details such as their PAN information or passport details number or any such
information required by Service Provider.
·
In case you opt for contactless check-in at Hotels, then copies of your
government identification like aadhar, driving license, election card etc.,
Self-declaration and any other information like date of birth,
destination/origin of travel and place of residence that may be required by the
concerned Hotel to honor your hotel booking.
·
Your Covid-19 Vaccination status and certificate in case you wish to
avail any service for provision of which such Covid-19 vaccination related
information is required or want to access your vaccination certificate at a
later stage for travel related or any other purpose. SPAS TOURS will never
process the beneficiary id and other id details contained in the vaccination
certificate.
Such information shall be strictly
used for the aforesaid specified & lawful purpose only. User further
understands that SPAS TOURS may share this information with the end service
provider or any other third party for provision and facilitation of the desired
booking. SPAS TOURS will always redact all/any sensitive & confidential
information contained in the vaccination certificate, passbook, bank statement
or any other identity card submitted for the purpose of availing a service,
promotional offer or booking a product on the Website. In case a User does not
wish to provide this information or opts for deletion of the information
already provided, SPAS TOURS may not be able to process the desired booking
request. SPAS TOURS will never share any of the above information collected
including PAN card details, Vaccination status & certificate , Passport
details , Aadhar Card details without their prior consent unless otherwise such
action is required by any law enforcement authority for investigation, by court
order or in reference to any legal process.
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:
·
confirm your reservations with respective service providers;
·
keep you informed of the transaction status;
·
send booking confirmations either via sms or Whatsapp or any other
messaging service;
·
send any updates or changes to your booking(s);
·
allow our customer service to contact you, if necessary;
·
customize the content of our website, mobile site and mobile app;
·
request for reviews of products or services or any other improvements;
·
send verification message(s) or email(s);
·
validate/authenticate your account and to prevent any misuse or abuse.
·
contact you on your birthday/anniversary to offer a special gift or
offer.
Surveys:
We value opinions
and comments from our Users and frequently conduct surveys, both online and
offline. Participation in these surveys is entirely optional. Typically, the
information received is aggregated, and used to make improvements to Website,
other Sales Channels, services and to develop appealing content, features and
promotions for members based on the results of the surveys. Identity of the
survey participants is anonymous unless otherwise stated in the survey.
Marketing Promotions,
Research and Programs:
Marketing
promotions, research and programs help us to identify your preferences, develop
programs and improve user experience. SPAS TOURS frequently sponsors promotions
to give its Users the opportunity to win great travel and travel related
prizes. Personal Information collected by us for such activities may include
contact information and survey questions. We use such Personal Information to
notify contest winners and survey information to develop promotions and product
improvements. As a registered User, you will also occasionally receive updates
from us about fare sales in your area, special offers, new SPAS TOURS services,
other noteworthy items (like savings and benefits on airfares, hotel
reservations, holiday packages, car rentals and other travel services) and
marketing programs.
In addition, you
may look forward to receiving periodic marketing emails, newsletters and
exclusive promotions offering special deals.
From time to time
we may add or enhance services available on the Website. To the extent these
services are provided, and used by you, we will use the Personal Information
you provide to facilitate the service(s) requested. For example, if you email
us with a question, we will use your email address, name, nature of the question,
etc. to respond to your question. We may also store such Personal Information
to assist us in making the Website the better and easier to use for our Users.
SPAS TOURS may from time to time
launch reward programs by way of which users may stand to win travel related
rewards or other rewards. We may use your Personal Information to enroll you in
the rewards program and status of the same will be visible each time you log in
to the Website. Depending on the reward program, each time you win a reward, SPAS
TOURS may share your Personal Information with a third party that will be
responsible for fulfilling the reward to you. You may however choose to opt out
of such reward programs by writing to us. For various purposes such as fraud
detection, offering bookings on credit etc., we at times may verify information
of customers on selective basis, including their credit information.
Additionally, SPAS TOURS may share your Personal Information, anonymized and/
or aggregated data to a third party that SPAS TOURS may engage to perform
certain tasks on its behalf, including but not limited to payment processing,
data hosting, data processing and assessing credit worthiness for offering
bookings on credit.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
SPAS TOURS 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.
In case user wishes to delete their
account, they can do so using this Link.
COOKIES AND SESSION DATA
Cookies:
SPAS TOURS uses
cookies to personalize your experience on the Website and the advertisements
that maybe displayed. SPAS TOURS’s use of cookies is similar to that of any
other reputable online companies.
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. SPAS TOURS supports your right to
block any unwanted Internet activity, especially that of unscrupulous websites.
However, blocking SPAS TOURS 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 Providers
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 SPAS TOURS you authorize us to share your information with the
said service providers and suppliers. It is pertinent to note that SPAS TOURS
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 SPAS TOURS 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.
SPAS TOURS 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 SPAS
TOURS 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:
We may also share
certain filtered Personal Information to 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, which will enable the
customer to have better travel experience or to avail certain benefits
specially made for SPAS TOURS customers. Examples of such partners are entities
offering co-branded credit cards, travel insurance, insurance cover against
loss of wallet, banking cards or similar sensitive information etc. If you
choose to avail any such services offered by our business partners, the
services so availed will be governed by the privacy policy of the respective
service provider.
SPAS TOURS may
share your Personal Information to third party that SPAS TOURS 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, SPAS
TOURS 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.
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