Traform Travel Technologies India Private Limited, is a private limited company having its registered office at S114, Chaithanya Smaran Whitefield, Hoskote Road, Kannamangala, Bengaluru, Karnataka, India, 560067 (hereinafter referred to as “We”, “Us”, “Traform” or “Our” which expression shall mean and include its affiliates, successors and permitted assigns).
This Policy has been prepared under the provisions of the Information Technology Act, 2000 (IT Act) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (IT Rules) promulgated thereunder, and sets out the practices and policies for the protection of personal information (including sensitive personal data or information) collected, received, possessed, stored, dealt with or handled by TRAFORM.
BY VOLUNTARILY PROVIDING US WITH INFORMATION, YOU ARE CONSENTING TO OUR USE OF IT IN ACCORDANCE WITH THIS POLICY.
This Policy specifically governs:
The manner of collection and use of personal data, sensitive personal data and other information that We may collect from You from time to time.
The manner of storage, transmission and disclosure of personal data, sensitive personal data and other information that We may collect from You from time to time.
“Confidential Information” shall have the meaning ascribed to it in Clause 8 of this Agreement.
“Personal Information” shall mean any information that relates to a natural person, 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 or is not otherwise publicly available. For avoidance of doubt, examples of personal information include a person’s name, address (including work addresses and work email addresses), date of birth, voice, opinions about people, national insurance number, driving license number, permanent account number, etc.
“Sensitive Personal Information” shall mean personal information, which consists of information relating to any to the following of an individual:
Biometric information (information derived from technologies that measure or analyse physical human characteristics such as fingerprints
Financial information such as Bank account or credit card or debit card or other payment instrument details, etc.
“User Information” shall mean, collectively, Your Personal Information and Sensitive Personal Information or data or any other information collected from You.
“Transaction” shall mean (“Booking of Travel services” and “Claiming travel and non-travel Expenses”)
Nature of Information
During Your association with our Platform, We may collect and process such information from You, including but not limited to the below mentioned:
Information that We may collect from You through filing of questionnaires’ and/or forms on the Platform: This typically constitutes User Information including contact information, name, gender, email address, mailing address, phone number, financial information including bank account details, payment instrument details, details of employment and terms thereof, transaction history, Frequent Flyer Numbers
Company, Employee ID, Designation and travel preferences.
We may record and collect, at Our sole discretion, e-mail and telephonic correspondences and conversations between You and TRAFORM, its agents, employees, directors etc.
TRAFORM will collect Sensitive Personal Information from You only upon providing a written notice to You. The notice shall specifically provide the following details:
The fact that Your Sensitive Personal Information is being collected
The purpose for which the Sensitive Personal Information is being collected
The intended recipients of the Sensitive Personal Information.
Access to User Information
You shall be entitled to upon request to access the User Information provided to Us from time to time, to update or correct such information in our records.
The Information collected by Us shall not be retained for longer than is required for the purpose for which the information may lawfully be used or is otherwise required under any other law for the time being in force.
Use of Information
In accordance with data protection laws, We will only process Your Personal Information and where We have a lawful basis for doing so. In respect of Your Personal Information, these bases are:
(i) Where it is necessary to provide services to You under the performance of Our obligations stipulated in the Terms and Conditions;
(ii) Where We are required to do so in accordance with legal or regulatory obligations;
(iii) Where you have given Your consent; and
(iv) Where it is in Our legitimate interests to process Your Personal Information provided that these interests do not prejudice your own rights, freedoms and interests.
We may process and/or use your Personal Information and/or Sensitive Personal Information data for the following purposes:
To analyse Our performance and make improvements thereon to enhance member experience of Our Platform.
Market research or surveying of Your needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible);
To analyse Your preferences and help Us to let You access Information depending upon Your interests.
To provide travel recommendations, send transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding services and other offers from time to time in connection with the Traform Platform or its parent, subsidiary and affiliated companies (“Platform Entities”) and its joint ventures.
To contact You to ensure user satisfaction with respect to Your use of the platform.
To track Your behaviour and preferences for internal analytics of all Users of the Traform Platform.
To provide You with information that You request from Us, where You have consented to be contacted for such purposes.
To evaluate Your eligibility for certain types of offers, products or services
To carry out Our obligations arising from any contracts entered into between You and Us as well as between Us and third party service providers.
We have legal obligation to regulators and authorities, in relation to which We may at their demand disclose Personal Information that You submit to Us.
We may integrate certain third party software development kits (SDKs) within the Traform Platform to assist in placing advertisements better suited to You and improve the overall user experience. Such third party SDK’s may directly collect certain Personal Information from you on the Platform, such as user behavior, preferences, account activity, IP address, user’s interactions with advertisements and identifiers for advertisers (IDFAs) and Google advertising ID (AAID).
You hereby consent to the collection, storage, use, disclosure, transfer, of the Personal Information or Sensitive Personal Information by Platform for the purposes set out herein.
Disclosure of Information
is necessary for performance of a contract between TRAFORM and You and You have authorized Us to share the Sensitive Personal Information.
is required under applicable laws or through a court order.
We may share Your Personal Information with third parties in the manner described below:
To facilitate the execution of Your Transaction.
We may disclose Your Personal Information to third-party service-providers, solely in the course of their provision of services to Us. We will take reasonable precautions to ensure that these service-providers are obligated to maintain the confidentiality of Your information
We may disclose Your Personal Information, if We are under a duty to do so in order to comply with any legal obligation, or to protect our rights, property, or safety, or those of Our users, or other third parties. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
TRAFORM requires all third parties with whom it shares any User Information to implement the same level of data protection that TRAFORM has adopted, as provided for under the IT Rules.