Privacy Policy

Visa2Travel Privacy Policy

A. Introduction:

B. Application of Policy:

C. Objectives of policy:

D. Collection of Information:

Types of information Collected by Vinpay Overseas Pvt. Ltd. (Visa2travel):

Sr. No.

Source of Information

Nature of Information Collected

1)

Users/Customers

  1. Personal Identifying information such as name, address and phone numbers; email Id, Age, personal description, profile photograph etc., & delivery address,

  2. payment information.

  3. location information.

  4. Device information (if you provided).

  5. IP address.

  6. Name, addresses & phone numbers, e-mail IDs of friends and other people listed in Addresses;

  7. Content of reviews and e-mails to us.

  8. voice recordings when you call to us.

  9. credit usage, login detail, device log files etc., while using our platform.

  10. Contacts – address book for app users

2)

Vendors/Sellers or

Suppliers/Travel Agents

or

DMC’s/Near by Agents

  1. Personal Identifying information such as name, address and phone numbers; email Id, Age, personal description, profile photograph ,Marital status etc.,.

  2. payment information.

  3. location information.

  4. Device information (if you provided)

  5. IP address.

  6. Name, addresses & phone numbers, e-mail IDs of friends and other people listed in Addresses.

  7. content of reviews and e-mails to us.

  8. voice recordings when you call to us.

  9. images, videos and other content collected or stored in connection with our Services.

  10. information and officially valid documents (KYC regarding identity and address information, including mobile & landline number, place of business, valid Email id, vendor’s photo, id & address proof (such as Aadhar card, Pan Card, GST Voter Id Card, Passport, Shop and Establishment Certificate, etc.,.

  11. credit usage

  12. corporate and financial information, and

  13. device log files and configurations etc.,.

3)

Automatic Information

  1. IP address of your device connected to our platform.

  2. Login details, e-mail address, and password, device log files etc.,.

  3. location of device/computer.

  4. content interaction information, downloads, streaming of video, network details etc.,.

  5. device metrics, application usage, connectivity data, and any errors or event failures.

  6. our Services metrics, any technical errors, interactions with our service features and content, settings preferences and backup information, location of device, file name, dates, times etc while using our service.

  7. content use history.

  8. URLs including date & time; products & contents viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information etc.,.

  9. phone numbers used to call to us.

  10. Images/videos while visiting our platforms.

  11. device identifiers, cookies, browsing history, usage history, and/or other technical information.

4)

Information from Other Sources

  1. updated delivery and address information from our carriers or other third parties.

  2. account information, purchase or redemption information and page-view information from some merchants/partners for which we provide technical, advertising or other services.

  3. information about interactions with vendors while interacting via V2T channel.

  4. search results and links, including paid/free listings.

  5. internet-connected devices details.

5)

Officials/Employees/Resellers etc…

  1. Personal Identifying information such as name, address and phone numbers; email Id, Age, personal description, profile photograph etc.,.

  2. Educational Information.

  3. information and officially valid documents (KYC) regarding identity and address information.

  4. payment information.

  5. location information.

  6. Device information (if you provided)

  7. IP address.

  8. content of reviews and e-mails to us.

  9. voice recordings when you call to us.

  10. login detail, device log files etc., while using our platforms.

6)

Third Party Information

  1. Corporate & financial information about our co-branded partners, delivery partners, and other third party associated with us.

  2. CIN Number, PAN Number, GSTN Number etc.,.

  3. Location information.

  4. Device information (if you provided)

  5. IP address.

  6. Internet-connected devices details.

  7. Identity and address information etc.,.

E. Visa2travel Doesn’t Collect the Information:

F. Usage of Information:

G. Processing of Personal Information:

H. Disclosure of Information:

I. Transfer of information:

J. Retention of Your Information:

K. Review of Information by You:

  1. Visa2travel shall establish & facilitates a mechanism to enable you to review the data/information you had provided, as per your choice, and shall access, edit, rectify, modify, delete any personal information or sensitive personal information found to be inaccurate or deficient. However Visa2travel shall not be responsible for the authenticity of the personal information or sensitive personal information supplied by you.

  2. You shall be entitled to obtain the details about your personal information upon a request made and set forth in writing. Visa2travel shall provide its response within 72 (seventy two) hours of receipt of written request. You shall have the right to require Visa2travel to correct or supplement erroneous, misleading, outdated, or incomplete personal information. We shall record & document each access request as it is received and the corresponding action taken. Visa2travel shall provide personal information to you in a plain simple format which is understandable.

L. Your Consent (Opt-in & Opt-out):

M. Consent to Push Notification:

N. Third-party Advertisers, Links to Other Sites:

O. Children Information

P. Our Commitment to Information Security:

Q. Transparency & Accountability Measures:

  1. Privacy by Design:

    • Visa2travel shall implement policies and measures to ensure that managerial, organisational, business practices and technical systems are designed in a manner to anticipate, identify and avoid harm to you;

    • Visa2travel shall implement policies and measures to ensure that the technology used in the processing of personal data is in accordance with commercially accepted or certified standards;

    • Visa2travel shall implement policies and measures to ensure that the legitimate interest of businesses including any innovation is achieved without compromising privacy interests;

    • Visa2travel shall implement policies and measures to ensure that privacy is protected throughout processing from the point of collection to deletion of personal data and processing of personal data is carried out in a transparent manner and the interest of the data provider is accounted for at every stage of processing of personal Data.

  2. Transparency: Visa2travel shall take reasonable steps to maintain transparency regarding its general practices related to processing personal data and shall make the following information available in an easily accessible form as may be specified –

    • the categories of personal data generally collected and the manner of such collection;

    • the purposes for which personal data is generally processed;

    • any categories of personal data processed in exceptional situations or any exceptional purposes of processing that create a risk of significant harm;

    • the existence of and procedure for the exercise of data principal rights;

    • the existence of a right to file complaints to the Authority;

    • Information regarding cross-border transfers of personal data, if any.

  3. Security Safeguards: Having regard to the nature, scope and purpose of processing personal data undertaken, the risks associated with such processing, and the likelihood and severity of the harm that may result from such processing, Visa2travel shall implement appropriate security safeguards including (a) use of methods such as de-identification and encryption; (b) steps necessary to protect the integrity of personal data; and (c) steps necessary to prevent misuse, unauthorised access to, modification, disclosure or destruction of personal data. Visa2travel shall undertake a review of its security safeguards periodically as may be specified and may take appropriate measures accordingly.

  4. Personal Data Breach: Visa2travel shall notify the Authority of any personal data breach relating to any personal data processed by Visa2travel where such breach is likely to cause harm to any data principal. The said notification includes, (a) nature of personal data which is the subject matter of the breach; (b) number of data principals affected by the breach; (c) possible consequences of the breach; and (d) measures being taken by the data fiduciary to remedy the breach.

  5. Record-Keeping: Visa2travel shall maintain accurate and up-to-date records of the following: (a) important operations in the data life-cycle including collection, transfers, and erasure of personal data to demonstrate compliance; (b) periodic review of security safeguards; (c) data protection impact assessments;

  6. Data Audits: Visa2travel shall have its policies and the conduct of its processing of personal data audited annually by an independent data auditor. The data auditor will evaluate the compliance of Visa2travel with the provisions of law including (a) clarity and effectiveness of notices, transparency, security safeguards, instances of personal data breach and response thereto.

R. Monitoring and Enforcement:

  1. Dispute Resolution & Recourse: Visa2travel shall define and document a cyber-incident management program which addresses the data protection & privacy related incidents. The incident management program includes a clear escalation path up to the executive management, legal counsel, and the board based on type and/or severity of the data breach. It shall define a process to register all the incidents/complaints and queries related to data breach. Visa2travel shall perform a periodic review of all the complaints related to data breach to ensure that all the complaints are resolved in a timely manner and resolutions are documented and communicated to the data principals. An escalation process for unresolved complaints and disputes which shall be designed and documented and the Communication of privacy incident / breach reporting channels and the escalation matrix shall be provided to all data providers.

  2. Dispute Resolution & Escalation Process for Employees: Employees with enquiries or complaints about the processing of their personal information shall first discuss the matter with their immediate reporting manager. If the employee does not wish to raise an inquiry or complaint with their immediate reporting manager, or if the manager and employee are unable to reach a satisfactory resolution of the issues raised, the employee shall bring the issue to the attention of the Grievance Officer.

  3. Dispute Resolution & Escalation Process for Customer / Third Party: Customers / Third Party with inquiries or complaints about the processing of their personal information shall bring the matter to the attention of the Grievance Officer in writing. Any disputes concerning the processing of the personal information of non-employees shall be resolved through arbitration.

S. Terms of Use, Policy & Revisions:

  1. If you choose to use Visa2travel Services, your use and any dispute over privacy is to this policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the prevailing law in India. If you have any concern about privacy at Visa2travel, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly and our Privacy policy will change also. You should check our websites frequently to see recent changes.

  2. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We assure that will never materially change our policies and practices to make them less protective of your information collected in the past without your consent.

T. Grievance Officer / Nodal Officer:

1. In accordance with Information Technology Act 2000 and rules & regulations made thereunder, the name and contact details of the Grievance Officer / Nodal Officer are provided below:

Name : Mr. Vinay Patel
Address: Vinpay Overseas Pvt. Ltd., Anand, Gujrat–388325.
Contact No: 8905060314
Email: grievanceofficer@visa2travel.com

2. If you have a query, issue, concern, or complaint in relation to collection or usage of your personal information under this Privacy Policy, please contact us at the contact information provided above or write to us at privacy@visa2travel.com /grievanceofficer@visa2travel.com.

DEFINITONS:

“Act”

“Act” means the Information Technology Act, 2000 (21 of 2000);

“Automated means”

“Automated means” means any equipment capable of operating automatically in response to instructions given for the purpose of processing data.

“Biometrics”

“Biometrics” means the technologies that measure and analyse human body characteristics, such as ‘fingerprints’, ‘eye retinas and irises’, ‘voice patterns’, “facial patterns’, ‘hand measurements’ and ‘DNA’ for authentication purposes.

“Body corporate”

“Body corporate” means any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities.

“Child”

“Child” means a data provider below the age of eighteen years

“Cyber incidents”

“Cyber incidents” means any real or suspected adverse event in relation to cyber security that violates an explicitly or implicitly applicable security policy resulting in unauthorised access, denial of service or disruption, unauthorised use of a computer resource for processing or storage of information or changes to data, information without authorisation.

“Cyber security”

“cyber security” means protecting information, equipment, devices, computer, computer resource, communication device and information stored therein from unauthorised access, use, disclosure, disruption, modification or destruction.

“Data”

“Data” means a representation of information, knowledge, facts, concepts or instructions which are being prepared or have been prepared in a formalised manner, and is intended to be processed, is being processed or has been processed in a computer system or computer network, and may be in any form (including computer printouts magnetic or optical storage media, punched cards, punched tapes) or stored internally in the memory of the computer.

“Data provider”

“Data provider” means the natural person to whom the personal data relates to.

“Data protection & Security”

Anyone collecting personal & customer information must fairly & lawfully process it only for limited, specifically stated purposes and use the information accurately and in a way that is adequate, relevant and not excessive, and retain the information/records no longer than absolutely necessary, process the information in accordance with law and keep the information secure and never transfer the information outside the country without adequate protection.

“Password”

“Password” means a secret word or phrase or code or passphrase or secret key, or encryption or decryption keys that one uses to gain admittance or access to information.

“Personal information”

“Personal information” means any information that relates to a natural person (individual), which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person, i.e., Name, Address, mobile Number, email id, Date of birth etc.,.

“Data processor”

“Data processor” means any person, including the State, a company, any juristic entity or any individual who processes personal data on behalf of a data fiduciary, but does not include an employee of the data fiduciary.

“Processing”

“Processing” in relation to personal data, means an operation or set of operations performed on personal data, and may include operations such as collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, use, alignment or combination, indexing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.

“reasonable security practices and procedures”

“reasonable security practices and procedures” means security practices and procedures designed to protect such information from unauthorised access, damage, use, modification, disclosure or impairment, as may be specified in an agreement between the parties or as may be specified in any law for the time being in force and in the absence of such agreement or any law, such reasonable security practices and procedures, as may be prescribed by the Central Government in consultation with such professional bodies or associations as it may deem fit.

“Sensitive personal data or information”

Sensitive personal data or information of a person means such personal information which consists of information relating to; –

  1. password;

  2. financial information such as Bank account or credit card or debit card or other payment instrument details ;

  3. physical, physiological and mental health condition;

  4. sexual orientation;

  5. medical records and history;

  6. Biometric information;

  7. any detail relating to the above clauses as provided to body corporate for

  8. providing service; and

  9. any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise;

Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information.

“Third Party”

All external parties, i.e. contractors, interns, trainees, vendors, users etc., who have accessed to Visa2travel information assets or information systems.

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