Privacy Policy – Vachaa Homes, Upvichar International Pvt. Ltd.

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Introduction:

Vachaa Homes, under Upvichar International Private Limited 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 Vachaa Homes.

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 Vachaa Homes through any of Vachaa Homes’s customer interface channels including its website, mobile site, mobile app & offline channels including call centers 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 Vachaa Homes. 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 Vachaa Homes’s business partners, advertisers, sponsors or other sites to which Vachaa Homes 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 Vachaa Homes 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 Vachaa Homes shall be primarily processed in India and such other jurisdictions where a third party engaged by Vachaa Homes may process the data on Vachaa Homes’s behalf. By agreeing to this policy, you are providing Vachaa Homes 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: upasanademmanuel@upvichar.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, any medical condition which may require specific attention or facility etc. may have to be shared to us.

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.

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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, 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 Vachaa Homes 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).

• 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, Vachaa Homes may not be able to process the booking. Vachaa Homes 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 Resorts, 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 to honor your 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 , 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 us 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. Vachaa Homes 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. Vachaa Homes 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, Vachaa Homes may not be able to process the desired booking request. Vachaa Homes 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.

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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.

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HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Vachaa Homes 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:

Vachaa Homes uses cookies to personalize your experience on the Website and the advertisements that maybe displayed. Vachaa Homes’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. Vachaa Homes supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking Vachaa Homes 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.

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DISCLOSURE OF INFORMATION

In addition to the circumstances described above, Vachaa Homes may disclose User's Personal Information if required to do so:

• by law, required by any enforcement authority for investigation, by court order or in reference to any legal process;

• to conduct our business;

• for regulatory, internal compliance and audit exercise(s)

• to secure our systems; or

• to enforce or protect our rights or properties of Vachaa Homes or any or all of its affiliates, associates, employees, directors or officers or when we have reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Such disclosure and storage may take place without your knowledge. In that case, we shall not be liable to you or any third party for any damages howsoever arising from such disclosure and storage.

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HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?

You will occasionally receive e-mail updates from us about fare sales, special offers, new Vachaa Homes 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.

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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.

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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 upasanademmanuel@upvichar.com

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YOUR RIGHTS QUA PERSONAL INFORMATION

You may access your Personal Information from your user account with Vachaa Homes. 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 upasanademmanuel@upvichar.com

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ELIGIBILITY TO TRANSACT WITH Vachaa Homes

You must atleast 18 years of age to transact directly with Vachaa Homes and also to consent to the processing of your personal data.

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CHANGES TO THE PRIVACY POLICY

We reserve the rights to revise the Privacy Policy from time to time to suit various legal, business and customer requirement. We will duly notify the users as may be necessary.

You may always submit concerns regarding this Privacy Policy via email to us at upasanademmanuel@upvichar.com. Vachaa Homes shall endeavor to respond to all reasonable concerns and inquires.

Privacy Policy (EU, UK and US)

Introduction:

Vachaa Homes is committed to our client’s privacy and security and to taking steps designed to secure your personal and financial information. We believe your private details should be kept just that and when you share personal information with us, we will make all reasonable endeavours to keep your details secure and private. We are committed to ensuring that your personal information is protected.

This document describes how we use and process your personal data, provided in a readable and transparent manner. It also tells you what rights you can exercise in relation to your personal data and how you can contact us.

The processing of personal data when using the Services

Vachaa Homes collects and uses information you provide to us. When you make a reservation, you are (at a minimum) asked for your name and email address.

Depending on the reservation, we may also ask for your home address, telephone number, payment information, date of birth, current location (in the case of on-demand services), the names of the people travelling/staying with you and any preferences you might have for your trip/stay (such as dietary or accessibility requirements). In some cases, you may also be able to check-in online with the Booking agency, for which we will ask you to share passport information or a driving license and signatures.

If you need to contact our customer service team, contact your booking agency through us, or reach out to us in a different way (such as social media or via a chatbot) we’ll collect information from you there, too. This applies whether you are contacting us with feedback or asking for help using our services.

You might also be invited to write reviews to help inform others about the experiences you had on your trip/stay. When you write a review on the Vachaa Homes platform, we’ll collect any information you’ve included, along with your display name.

If you create a user account, we’ll also store your personal settings, uploaded photos, and reviews of previous bookings. This saved data can be used to help you plan and manage future reservations or benefit from other features only available to account holders (such as incentives or other benefits).

Personal data you give us about others

Of course, you might not simply be making a reservation for yourself. You might be taking a trip/stay with other people or making a reservation on someone else’s behalf. In both those scenarios, you will provide their details as part of the reservation.

In some cases, you might use Vachaa Homes to share information with others. This can take the form of sharing a Wishlist, taking part in a travel community or participating in a referral program, as described when you use the relevant feature.

At this point, we have to make it clear that it’s your responsibility to ensure that the person or people you have provided personal data about are aware that you’ve done so, and that they have understood and accepted how Vachaa Homes uses their information (as described in this Privacy Policy).

Personal data we collect automatically.

Whether or not you end up making a reservation, when you visit our websites or apps, we automatically collect certain information. This includes your IP address, the date and time you accessed our services, and information about your computer’s hardware and software (such as the operating system, the internet browser used, software/application version data and your language settings). We also collect information about clicks and which pages have been shown to you.

Why do we collect and use your personal data?

We use the information collected about you for a variety of purposes. Your personal data may be used in the following ways:

• Booking Arrangement: First and foremost, we use your personal data to complete and administer your online booking arrangement– which is essential for us to provide this service for you. This includes sending you communications that relate to your booking arrangement, such as confirmations, modifications, and reminders. In some cases, this may also include processing your personal data to enable online check-in or processing personal data in relation to damage deposits.

• Customer service: We provide international customer service from our local offices in more than twenty languages, and we’re here to help 24 hours a day, 7 days a week. Sharing relevant details, such as reservation information or information about your user account with our global customer service staff allows us to respond when you need us. This includes helping you to contact the right booking agency and responding to any questions you might have about your booking arrangement (or any other queries, for that matter).

• Account facilities: Vachaa Homes users can create an account on our website or apps. We use the information you give us to administer this account, allowing you to do several useful things. You can manage your booking arrangements, take advantage of unique offers, make future booking arrangements easily and manage your personal settings.

 

If you want to, you can share certain information as part of your user account, by creating a public profile under your own first name or a screen name you choose.

Communicating with you: There might be other times when we get in touch, including by email, by chatbot, by post, by phone or by texting you. Which method we choose depends on the contact information you’ve previously shared.

We process the communications you send to us. There could be several reasons for this, including:

Responding to and handling any requests you or your booking agency have made.

Data sharing with third parties

In certain circumstances, we’ll share your personal data with third parties. These third parties include:

The booking agency you booked: To complete your booking arrangement, we transfer relevant reservation details to the booking agency you have booked. This is one of the most essential things we do for you.

Depending on the booking arrangement and the Booking agency, the details we share can include your name, contact and payment details, the names of the people accompanying you and any other information or preferences you specified when you made your booking arrangement.

In certain cases, we also provide some additional historical information about you to the Booking agency. This includes whether you’ve already booked with them in the past, the number of completed bookings you’ve made with Vachaa Homes, a confirmation that no misconduct has been reported about you, the percentage of bookings you’ve cancelled in the past or whether you’ve given reviews about past bookings.

In cases of Booking arrangement-related claims or disputes, we may provide the booking agency with your contact details and other information about the booking process, as needed to resolve the situation. This can include, but might not be limited to, your email address and a copy of your reservation confirmation as proof that a booking arrangement was made or to confirm reasons for cancellation.

For completeness, booking agencies will further process your personal data outside of the control of Vachaa Homes. Booking agencies may also ask for additional personal data, for instance to provide additional services, or to comply with local restrictions. If available, please read the Privacy Statement of the booking agency to understand how they process your personal data.

• Connectivity Providers: Please note that certain booking agencies may need us to share your personal data with a contracted Connectivity Provider to be able to finalise and administer your reservation. Connectivity providers act on behalf of booking agencies and help them to manage their reservations.

• Third-party service providers: We use service providers from outside of the Vachaa Homes group to support us in providing our services. These include:

  • Customer support

  • Market research

  • Fraud detection and prevention (including anti-fraud screening)

  • Insurance claims

  • Payment

We use third parties to process payments, handle chargebacks or provide billing collection services. When a chargeback is requested for your booking arrangement, either by you or by the holder of the credit card used to make your reservation, we need to share certain reservation details with the payment service provider and the relevant financial institution so they can handle the chargeback. This may also include a copy of your reservation confirmation, or the IP address used to make your reservation. We may share information with relevant financial institutions if we consider it strictly necessary for fraud detection and prevention purposes.

The data that we collect from you, as described in this Privacy Statement, could be made accessible from, transferred to, or stored in countries which may not have the same data protection laws as the country in which you initially provided the information. In such cases, we will protect your data as described in this Privacy Statement.

This may also be applicable if you are in the European Economic Area (EEA). Countries your data may be transferred to may not have laws that provide the same level of protection for your personal data as laws within the EEA. Where this is the case, we will put appropriate safeguards in place to make sure that these transfers comply with European privacy law.

When your data is transferred to third-party service providers, we establish and implement appropriate contractual, organisational, and technical measures with them. This is done by putting in place Standard Contractual Clauses as approved by the European Commission, by examining the countries to which the data may be transferred, and by imposing specific technical and organisational security measures.

What security and retention procedures does Vachaa Homes put in place to safeguard your personal data?

We have procedures in place to prevent unauthorised access to, and the misuse of, personal data.

We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorised personnel are permitted to access personal data in the course of their work.

We’ll keep your personal data for as long as is necessary to enable you to use our services or to provide our services to you (including maintaining any Vachaa Homes user accounts you may have), to comply with applicable laws, resolve any disputes and otherwise to allow us to conduct our business, including to detect and prevent fraud and/or other illegal activities. All personal data we keep about you as a Vachaa Homes customer is covered by this Privacy Statement.

Your rights

You have the following rights with respect to your personal data:

General rights

You have the right to information, access, correction, deletion, restriction of processing, objection to processing, and data portability. If processing is based on your consent, you have the right to revoke it at any time.

Rights to object to processing of data based on legitimate interests

Article 21(1) EU General Data Protection Regulation (EU) 2016/679 (“GDPR”) gives you the right to object at any time for reasons arising out of your particular situation against the processing of personal data relating to you when your data is processed under Article 6(1)(e) or Article 6 (1)(f) GDPR. This also applies to profiling. If you object, we will no longer process your personal data unless we can establish compelling and legitimate grounds for processing that outweigh your interests, rights, and freedoms, or if the processing aids the enforcing, exercising, or defending of legal claims.

The Data Rights of the Citizens of California

You may have certain data rights under state privacy laws, such as the ability to request information regarding the manner in which Vachaa Homes collects your personal information, to obtain your personal information in a portable format, and to have your personal information amended or deleted.

If we deny a data request, you to appeal the denial of any of these rights by completing a form that we will furnish you with. Depending on the data options selected, specific services might be restricted or inaccessible. We will typically request that you authenticate your request using the contact information you have already provided in order to safeguard your Vachaa Homes account.

No sale of personal information.

Personal information of consumers, as defined by the California Consumer Privacy Rights Act, has not been sold by MMT as of now.

Sensitive Personal Information Disclosure.

Vachaa Homes gathers and divulges certain types of data for some business purposes which includes "sensitive personal information" but this Sensitive personal information is not utilized or disclosed by Vachaa Homes for any purpose that is not explicitly authorized by the California Consumer Privacy Rights Act.

Retention Disclosure

In order to facilitate your ongoing utilization of Vachaa Homes Services, we shall retain your personal information for the duration necessary to fulfil the objectives outlined in this Privacy Notice, in accordance with legal requirements, as otherwise instructed to you.

Non-discrimination Declaration

Any consumer who exercises their rights under the California Consumer Privacy Rights Act will not be subject to discrimination at Vachaa Homes.

How can you exercise your rights and control the personal data you’ve given to Vachaa Homes?

We want you to be in control of how your personal data is used by us. You can do this in the following ways:

• You can ask us for a copy of the personal data we hold about you,

• You can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you. As explained below, you can make some of these changes yourself, online, when you have a user account,

• In certain situations, you can ask us to erase, block, or restrict the processing of the personal data we hold about you, or object to ways in which we are using your personal data,

• In certain situations, you can also ask us to send the personal data you have given us to a third party,

• Where we are using your personal data based on your consent, you are entitled to withdraw that consent at any time subject to applicable law, and

• Where we process your personal data based on legitimate interest or the public interest, you have the right to object to that use of your personal data at any time, subject to applicable law.

We rely on you to make sure that your personal information is complete, accurate and current. Please do let us know about any changes to, or inaccuracies in, your personal information as soon as possible.

Contact by e-mail

When you contact us by e-mail, we will store the data you provide (your e-mail address, possibly your name and telephone number) so we can answer your questions. As far as we use our contact form to request entries that are not required for contacting you, we have always marked these as optional. This information serves to substantiate your inquiry and improve the handling of your request. Your message may be linked to various actions taken by you on the Vachaa Homes website. Information collected will be solely used to provide you with support relating to your booking and better understand your feedback. A statement of this information is expressly provided on a voluntary basis and with your consent, art. 6 par. 1a GDPR. As far as this concerns information about communication channels (such as your e-mail address or telephone number), you also agree that we may also, where appropriate, contact you via this communication channel to answer your request. You may of course revoke this consent for the future at any time.

We delete the data that arises in this context after saving is no longer required, or limit processing if there are statutory retention requirements.

Use of cookies

Cookies will be stored on your device during the use of our website. Cookies are small text files that are stored on your hard drive assigned to the browser you use, and through which the place where the cookie is set accrues certain information. They serve to make the website more user-friendly and efficient overall. We also use cookies to be able to identify you in subsequent visits.

This website uses the following types of cookies, whose extent and function are explained in the following:

• Persistent / Permanent cookies:Persistent cookies helps us recognise you as an existing user, so it’s easier for you to return to our sales channel without signing in again. After signing in, the persistent cookies stay on your browser and will be read when you return to our sales channel. These remain on your computer/device for a pre-defined period.

• Session cookies:Session cookies only last for as long as the session exists, (they are erased when the user closes the browser).

Data transmission

When we use service providers who process data outside the EU/EEA, we use appropriate safeguards such as standard data protection clauses adopted by the EU, or an EU adequacy decision to transfer and process your personal data outside of the EU.

Data security

We have taken extensive technical and operational security precautions to protect your data from being accidentally or intentionally manipulated, lost, destroyed, or accessed by unauthorized persons. Our security measures are reviewed regularly and updated in keeping with technological advances.

Data Storage

We retain your personal data for as long as it is required for you to use our Services, to provide our Services to you, to comply with laws. We will anonymise and/or aggregate your data if we intend to use it for analytical statistical purposes over longer periods.

Data Retention

We will retain the personal information we collect from you where we have a justifiable business need to do so and/or for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, legal, accounting, or other purposes).

Notice for Individuals Located in Europe

‘If you are in the European Economic Area, United Kingdom and/or Switzerland, the policies in this section are specific to you. They describe how we market to you, our legal bases for processing your information and your rights.’

This section only applies to individuals that access or use our Services while located in the European Economic Area, United Kingdom and/or Switzerland (collectively “Europe”). We may ask you to identify which country you are in when you use some of the Services or we may rely on your IP address to identify in which country you are located. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in Europe.

• Legal Bases for Processing. Our legal bases for the processing activities identified in this Policy are:

  • We rely on our contract with you as our legal basis for processing in relation to the following: to provide and maintain our services, to provide customer support or respond to you, to enforce compliance with our Terms, agreements, or policies, and to share your information with service providers.

  • Depending on the specific circumstances, we rely on your consent or legitimate interest in relation to the following processing activities: to send you marketing and promotional emails, to advise you of other services, and to share your information with business partners, sponsors, or within our corporate organization.

  • We rely on legitimate interest in relation to the following processing activities: to personalize your experience, for research and development, and when we share your information with board members or volunteers or in relation to business transfers or bankruptcy.