Privacy Policy
Introduction:
TELLIS TRAVEL EXPERIENCES (OPC) PRIVATE LIMITED (India) Private Limited (hereinafter “TTEPL”) 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 TTEPL 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 TTEPL through any of TTEPL’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 TTEPL. 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 TTEPL’s business partners, advertisers, sponsors or other sites to which TTEPL 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 TTEPL 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 TTEPL shall be primarily processed in India and such other jurisdictions where a third party engaged by TTEPL may process the data on TTEPL’s behalf. By agreeing to this policy, you are providing TTEPL 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: sales@topgoatours.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 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 ammunition 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 fulfil our legal obligations as well as our obligations towards third parties as per our User Agreement.
Personal Informationof 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 behaviour.
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 TTEPL 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 TTEPL 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, TTEPL may not be able to process the booking. TTEPL 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. TTEPL 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 TTEPL may share this information with the end service provider or any other third party for provision and facilitation of the desired booking. TTEPL 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, TTEPL may not be able to process the desired booking request. TTEPL 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 travellers 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. TTEPL 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 TTEPL 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.
TTEPL 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 enrol 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, TTEPL 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, TTEPL may share your Personal Information, anonymized and/ or aggregated data to a third party that TTEPL 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?
TTEPL 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:
TTEPL uses cookies to personalize your experience on the Website and the advertisements that maybe displayed. TTEPL’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. TTEPL supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking TTEPL 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 analyse 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 TTEPL you authorize us to share your information with the said service providers and suppliers. It is pertinent to note that TTEPL 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 TTEPL 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.
TTEPL 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 TTEPL 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 TTEPL 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.
TTEPL may share your Personal Information to third party that TTEPL 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 behaviour 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, TTEPL 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.
DISCLOSURE OF INFORMATION
In addition to the circumstances described above, TTEPL 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 TTEPL 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.
USER GENERATED CONTENT
TTEPL provides an option to its users to post their experiences by way of reviews, ratings and general poll questions. The customers also have an option of posting questions w.r.t a service offered by TTEPL or post answers to questions raised by other users. TTEPL may also hire a third party to contact you and gather feedback about your recent booking with TTEPL. Though the participation in the feedback process is purely optional, you may still receive emails, notifications (app, SMS, WhatsApp or any other messaging service) for you to share your review(s), answer questions posted by other users or a. The reviews may be written or in a video format. The reviews written or posted may also be visible on other travel or travel related platforms.
The UGC that TTEPL collects may be of the following kinds:
Review and Ratings
Question and Answers
Crowd Source Data Collection (poll questions).
Each User who posts review or ratings, Q&A, photographs shall have a profile, which other Users will be able to access. Other Users may be able to view the number of trips, reviews written, questions asked and answered and photographs posted.
HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?
`You will occasionally receive e-mail updates from us about fare sales in your area, special offers, new TTEPL 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.`
PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS
When the TTEPL app is installed on your phone or tablet, a list of permissions appear and are needed for the app to function effectively. There is no option to customize the list. The permissions that TTEPL requires and the data that shall be accessed and its use is as below:
Android permissions:
Device & App history:We need your device permission to get information about your device, like OS (operating system) name, OS version, mobile network, hardware model, unique device identifier, preferred language, etc. Basis these inputs, we intend to optimize your travel booking experience, use OS specific capabilities to drive great in-funnel experiences using components of device’s OS, etc.
Camera:This permission enables you to use your camera from within the application to upload a new profile picture, upload an image for sharing hotel reviews and also allows you to take videos to upload as video reviews on our application. This permission will also enable you to scan QR codes for easy UPI payments.
Identity:This permission enables us to know about details of your account(s) on your mobile device. We use this info to auto-fill your email ID’s and provide a typing free in-funnel experience. It helps us map email ID’s to a particular user to give you the benefit of exclusive travel offers, wallet cash-backs, etc. It also allows facilitating your Facebook and Google+ login.
Location:This permission enables us to give you the benefit of location specific deals and provide you a personalized in-funnel experience. When you launch TELLIS TRAVEL EXPERIENCES (OPC) PRIVATE LIMITED app to make a travel booking, we auto-detect your location so that your nearest airport or city is auto-filled. We also require this permission to recommend you nearest hotels in case you are running late and want to make a quick last-minute booking for the nearest hotel. Your options are personalized basis your locations. For international travel, this enables us to determine your time zone and provide information accordingly
SMS:If you allow us to access your SMS, we read your SMS to autofill or prepopulate ‘OTP’ while making a transaction and to validate your mobile number. This provides you a seamless purchase experience while making a booking and you don’t need to move out of the app to read the SMS and then enter it in the app.
Phone:The app requires access to make phone calls so that you can make phone calls to hotels, airlines and our customer contact centres directly through the app.
Contacts:If you allow us to access your contacts, it enables us to provide a lot of social features to you such as sharing your hotel/ flight/ holidays with your friends, inviting your friends to try our app, send across referral links to your friends, etc. We may also use this information to make recommendations for hotels where your friends have stayed. This information will be stored on our servers and synced from your phone.
Photo/ Media/ Files:The libraries in the app use these permissions to allow map data to be saved to your phone's external storage, like SD cards. By saving map data locally, your phone doesn't need to re-download the same map data every time you use the app. This provides you a seamless Map based Hotel selection experience, even on low bandwidth network.
Wi-Fi connection information:When you allow us the permission to detect your Wi-Fi connection, we optimize your experience such as more detailing on maps, better image loading, more hotel/ flights/ package options to choose from, etc.
Device ID & Call information:This permission is used to detect your Android ID through which we can uniquely identify users. It also lets us know your contact details using which we pre-populate specific fields to ensure a seamless booking experience.
Calendar:This permission enables us to put your travel plan on your calendar.
Bluetooth:This permission enables us to provide you services of the third parties that make available certain features of their products/services on our application. The permission specifically enables our third party service providers whose services you book on the application to permit you to lock and unlock your self-driven vehicles seamlessly.
Video/Audio:This permission enables you to upload videos on our application or to submit video reviews of your hotel/property stays and thereby providing you with new ways of providing reviews of your experience on our application. The audio permission enables us to ensure that the video content that you upload has a clear audio in its background.
Phone Number:We need the permission of access to phone number to provide a seamless login experience, to optimise your travel booking experience and to enable you to obtain UPI services and to prevent fraud in some cases on our application
IMEI/IMSI:This permission enables us to identifying different users uniquely and helps us to prevent frauds on our application.
Subscription Information:Your subscription information enables to provide you a seamless experience depending upon your network and to optimise the application’s performance. In addition, this also enables us in providing to you the train status even in an offline mode and additionally even in a no network area you can get fully aware of the status of the train you want to search for.
SIM Serial Number:This permission enables us to read your sim serial number and helps us in authenticating your mobile number for UPI registration. It helps us to ensure that the mobile number you are using is actually present on your device that you are using to register for UPI.
IOS Permissions:
Notifications:If you opt in for notifications, it enables us to send across exclusive deals, promotional offers, travel related updates, etc. on your device. If you do not opt for this, updates for your travel like PNR status, booking confirmation, refund (in case of cancellation), etc. will be sent through SMS.
Contacts:If you opt in for contacts permission, it enables us to provide a lot of social features to you such as sharing your hotel/ flight/ holidays with your friends, inviting your friends to try our app, send across referral links to your friends, etc. We will also use this information to make recommendations for hotels where your friends have stayed. This information will be stored on our servers and synced from your phone.
Location:This permission enables us to give you the benefit of location specific deals and provide you a personalized in-funnel experience. When you launch our app to make a travel booking, we auto-detect your location so that your nearest Airport or City is auto-filled. We require this permission to recommend your nearest hotels in case you are running late and want to make a quick last-minute booking for the nearest hotel. Your options are personalized basis your locations. For international travel, this enables us to determine your time zone and provide information accordingly.
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.
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
YOUR RIGHTS QUA PERSONAL INFORMATION
You may access your Personal Information from your user account with TTEPL. 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
ELIGIBILITY TO TRANSACT WITH TTEPL
You must atleast 18 years of age to transact directly with TTEPL and also to consent to the processing of your personal data.
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 atsales@topgoatours.com. TTEPL shall endeavour to respond to all reasonable concerns and inquires.
The processing of personal data when using the Services
TTEPL 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 TTEPL 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.
If you have a TTEPL for Business account, you can keep an address book there to make it easier to plan and manage business travel/stay arrangements for others.
In some cases, you might use TTEPL 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 TTEPL 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.
If you’re using a mobile device, we collect data that identifies the device, as well as data about your device-specific settings and characteristics, app crashes and other system activity. When you make a booking arrangement using this kind of device, our system registers how you made your reservation (on which website), and/or which site you came from when you entered the TTEPL website or app.
Personal data we receive from other sources.
It’s not just the things you tell us, though – we may also receive information about you from other sources. These include business partners, such as affiliate partners, subsidiaries of the TTEPL corporate group, other companies in the TELLIS TRAVEL EXPERIENCES (OPC) PRIVATE LIMITED (India) Private Limited. corporate group and other independent third parties.
Anything we receive from these partners may be combined with information provided by you. For example, TTEPL Reservation services are not only made available via TTEPL and the TTEPL apps but are also integrated into services of affiliate partners you can find online. When you use any of these services, you provide the reservation details to our business partners who then forward your details to us.
We also integrate with third party service providers to facilitate payments between you and booking agencies. These service providers share payment information so we can administer and manage your Booking arrangement, making sure everything goes as smoothly as possible for you.
Additionally, we collect information in the regrettable case that we receive a complaint about you from a Booking agency, for example in the case of misconduct.
Another way we might receive data about you, is through the communication services integrated into our platforms. These communication services offer you a way to contact the booking agency you’ve booked with to discuss your stay. In some cases, we receive metadata about these communication activities (such as who you are, where you called from, and the date and length of the call).
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:
Managing personal settings gives you the ability to keep and share lists, share photos, easily see trip/stay Services you’ve searched for and check travel-related information you’ve provided. You can also see any reviews you’ve written.
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.
If you’re a TTEPL for Business account holder, you can also save contact details under that account, manage business reservations and link other account holders to the same TTEPL for Business account.
Online groups: We give account holders the chance to connect and interact with each other through online groups or forums, such as travel communities.
Marketing activities: We use your information for marketing activities. These activities include:
Using your contact information to send you regular news about travel-related products and services. You can unsubscribe from email marketing communications quickly, easily and at any time. All you need to do is click on the ‘Unsubscribe’ link included in each newsletter or other communication.
Based on your information, individualised offers might be shown to you on the TTEPL website, in mobile apps or on third-party websites/apps (including social media sites) and the content of the site displayed to you might be personalised. These could be offers that you can book directly on the TTEPL website, on co-branded sites, or other third-party offers or products we think you might find interesting.
When you participate in other promotional activities (such as sweepstakes, referral programmes or competitions), only relevant information will be used to administer these promotions.
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. TTEPL also offers customers and booking agencies several ways to exchange information, requests, and comments about Booking agencies and existing booking arrangements via TTEPL.
Providing the best price applicable to you, depending on where you are based: When you search our apps or website, for example to find an accommodation, a rental car, or a flight, we process your IP address to confirm whether you are in the European Economic Area (EEA) or in another country. We do this to offer you the best price for the region (EEA) or country (non-EEA) where you are based.
Customer reviews and other destination-related information: During and after your trip/stay, we might invite you to submit a review. We can also make it possible for the people you’re travelling/staying with or whom you’ve booked a reservation for to do this instead. This invite asks for information about the booking agency or the destination.
Call monitoring: When you make calls to our customer service team, TTEPL uses an automated telephone number detection system to match your telephone number to your existing reservations. This can help save time for both you and our customer service staff. However, our customer service staff may still ask for authentication, which helps to keep your reservation details confidential.
During calls with our customer service team, live listening might be carried out or calls might be recorded for quality control and training purposes. This includes the usage of the recordings for the handling of complaints, legal claims and for fraud detection.
We do not record all calls. In the case that a call is recorded, each recording is kept for a limited amount of time before being automatically deleted. This is unless we have determined that it’s necessary to keep the recording for fraud investigation or legal purposes. You can read more about this below.
Promotion of a safe and trustworthy service: To create a trustworthy environment for you, the people you bring with you on your trip/stay, TTEPL’s business partners and our booking agencies, we continuously analyse and use certain personal data to detect and prevent fraud and other illegal or unwanted activities.
Legal purposes: Finally, in certain cases, we may need to use your information to handle and resolve legal claims and disputes, for regulatory investigations and compliance, to enforce the TTEPL online reservation service terms of use or to comply with lawful requests from law enforcement.
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 TTEPL, 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.
If you have a query about your trip/stay, we may contact the booking agency to handle your request. Unless payment is made during the booking process, via the TTEPL website, we will forward your credit card details to the booking agency for further handling (assuming you’ve provided us with those details).
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 TTEPL. 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.
Your local TTEPL office: To support the use of TTEPL services, your details may be shared with subsidiaries of the TTEPL corporate group, including for customer service.
Third-party service providers: We use service providers from outside of the TTEPL corporate 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.
Marketing services: We share personal data with advertising partners, including your email address, as part of marketing TTEPL services via third parties (to ensure that relevant advertisements are shown to the right audience). We use techniques such as hashing to enable the matching of your email address with an existing customer database, so that your email address cannot be used for other purposes. For information on other personalised advertisements and your choices, please read our cookie policy.
Advertising partners: We use advertising partners, such as metasearch providers, to allow you to compare our offers with offers from other Online Travel Agencies (OTAs). When you make a reservation on TTEPL after using an advertising partner, we will send the details of the reservation that you made on TTEPL to that partner.
Advertisers from Third Parties and Links to Other Websites: The TTEPL Services may have ads from third parties and links to other websites and apps. Advertising partners from outside our site may get information about you when you use their services, ads, and content.
Use of Third-Party Advertising Services: We give ad companies information that helps them show you more useful and relevant ads and figure out how well they're doing. When we do this, we never give out your name or any other information that could be used to find you. We instead use an advertising identifier like a cookie, a device identifier, or a code that we get from encrypting other information, like an email address, in a way that can't be reversed. Even though we don't tell ad companies exactly what you searched for, we may give them an advertising identifier and an idea of how much the ads they show you are worth so they can show you more appropriate and effective ads. You may also see ads from other advertisers that are more useful to you from some ad companies.
Competent authorities: We disclose personal data to law enforcement to the extent that it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud, or if we are otherwise legally obliged to do so. We may need to further disclose personal data to competent authorities to protect and defend our rights or properties, or the rights and properties of our business partners.
Business partners: We work with many business partners around the world. These business partners distribute and advertise TTEPL services, including the services and products of our booking agencies. When you make a reservation on one of our business partners’ websites or apps, certain personal data that you give them, such as your name and email address, your address, payment details and other relevant information, will be forwarded to us to finalise and manage your booking arrangement. If customer service is provided by the business partner, TTEPL will share relevant reservation details with them (as and when needed) to provide you with appropriate and efficient support.
When you make a reservation through one of our business partners’ websites, the business partners can receive certain parts of your personal data related to the specific reservation and your interactions on these partner websites. This is for their commercial purposes. When you make a reservation on a business partners’ website, please also take the time to read their privacy notice if you’d like to understand how they process your personal data.
For fraud detection and prevention purposes, we may also exchange information about our users with business partners – but only when strictly necessary If an insurance claim is made, concerning you and a Booking agency, we may provide the necessary data (including personal data) to the insurance company for further processing.
Partner Offer: We may present you with a ‘Partner Offer. When you book a stay marked ‘Partner Offer,’ your reservation will be facilitated by a booking agency who is separate from the accommodation you’re booking. As part of the reservation process, we’ll need to share some relevant personal data with this business partner. If you book a Partner Offer, please review the information provided in the booking process or check your reservation confirmation for more information about the booking agency and how your personal data will be further processed by them.
TTEPL is a global business. 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.
In certain specific cases, we transfer your data outside the EEA because it is in your interest or is necessary to conclude or perform the contract, we have with you. For instance, when you make a reservation on TTEPL or through a business partner, we might need to transfer your data to a booking agency or business partner who is located outside the EEA
How is personal data shared within the TTEPL corporate group?
We may receive personal data about you from other companies in the TELLIS TRAVEL EXPERIENCES (OPC) PRIVATE LIMITED (India) Private Limited.
corporate group, or share your personal data with them, for the following purposes:
To provide services (including to make, administer and manage reservations or handle payments);
To provide customer service;
To detect, prevent and investigate fraudulent, other illegal activities and data breaches;
For analytical and product improvement purposes;
To provide personalised offers or send you marketing with your consent or as otherwise permitted by applicable law;
For hosting, technical support, overall maintenance and maintaining security of such shared data;
To ensure compliance with applicable laws;
As applicable and unless indicated otherwise, for purposes A to F, TTEPL relies on its legitimate interests to share and receive personal data. For purpose G, TTEPL relies, where applicable, on compliance with legal obligations (such as lawful law enforcement requests).
How is your personal data shared and further processed for insurance services?
When offering insurance, TTEPL may have to use and share personal data that is relevant to the insurance product. This data relates to you as a potential or actual policyholder, the beneficiaries under a policy, family members, claimants and other parties involved in a claim:
To provide offers, arrange insurance cover and handle insurance claims, some personal data, provided to us during the booking process, (‘General Order Data’) may have to be shared with TTEPL. You may also be asked to provide additional information, such as names of family members or other beneficiaries or details about a claim (‘Insurance-Specific Data’).
If you make a claim under an insurance policy, this claim may be directly handled by the insurer. This means that you may be asked to provide personal data to submit the claim directly to them. The insurer will inform you accordingly at the point of collection of your information. When your claim is handled by the insurer, TTEPL may receive information about the status of your claim to provide you with customer support services.
How does TTEPL process communications that you and your booked agency may send via TTEPL?
TTEPL can offer you and booking agencies several ways to communicate about the trip/stay Services and existing booking arrangements, directing the communications via TTEPL. This also allows you and your booking agency to contact TTEPL with questions about your booking arrangement through the website, our apps, and the other channels that we make available.
TTEPL accesses communications and may use automated systems to review, scan, and analyse communications for the following reasons:
Security purposes;
Fraud prevention;
Compliance with legal and regulatory requirements;
Investigations of potential misconduct;
Product development and improvement;
Research;
Customer engagement (including to provide you with information and offers that we believe may be of interest to you)
Customer or technical support
We reserve the right to review or block the delivery of communications that we, in our sole discretion, believe might contain malicious content or spam, or pose a risk to you, booking agencies, TTEPL or others.
All communications sent or received using TTEPL communication tools will be received and stored by TTEPL. Booking agencies and Business partners you’ve booked a booking arrangement through might also choose to communicate with you directly by email or through other channels that TTEPL does not control.
How does TTEPL make use of social media?
At TTEPL, we use social media in separate ways. We use it to facilitate the use of online reservation services, but also to promote our booking agencies’ travel-related products and services and to advertise, improve and facilitate our own services.
Note that the use of social media features can result in the exchange of personal data between TTEPL and the social media service provider, as we describe below. You are free not to use any of the social media features available to you.
Sign in with your social media account. We offer you the opportunity to sign in to a TTEPL user account with one of your social media accounts. We do this to reduce the need for you to remember different usernames and passwords for different online services. After you’ve signed in once, you’ll be able to use your social media account to sign into your TTEPL account. You can decouple your TTEPL user account from your chosen social media account any time you want to.
Integration of social media plugins. We have also integrated social media plugins into the TTEPL website and apps. This means that when you click or tap on one of the buttons (such as Facebook’s ‘Like’ button), certain information is shared with these social media providers. If you’re logged into your social media account when you click or tap one of these buttons, your social media provider may relate this information to your social media account. Depending on your settings, they might also display these actions on your social media profile, to be seen by others in your network.
Other social media services and features. We may integrate other social media services (like social media messaging) for you to interact with TTEPL or with your contacts about our services. We may maintain social media accounts and offer apps on several social media sites. Whenever you connect with TTEPL through social media, your social media service provider may allow you to share information with us.
If you choose to share, your social media provider will inform you about which information will be shared. For example, when you sign into a TTEPL user account using your social media account, certain information from that account may be shared with TTEPL. This includes your email address, your age, and the profile pictures you’ve saved – depending on what you authorise in your social media account.
When you register with a TTEPL social media app or connect to a social media messaging service without a TTEPL user account, the information you choose to share with us may include the basic information available in your social media profile (including your email address, status updates and a list of your contacts).
We’ll use this information to help provide you with the service you requested – for example, to forward a message you want to send to your contacts, or to create a personalised user experience in the app or on our websites. It means that if you want us to, we can tailor our services to suit your needs, connecting you and your friends with the best travel destinations and analysing and improving our travel-related services.
Your social media provider will be able to tell you more about how they use and process your data when you connect to TTEPL through them. This can include combining the personal data they collect when you use TTEPL through them with information they collect when you use other online platforms you have also linked to your social media account.
If you decide to connect using your Facebook or Google account, please review the following links for information about how these parties use data they receive: Facebook and Google.
What security and retention procedures does TTEPL 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 TTEPL 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 TTEPL customer is covered by this Privacy Statement.
For added protection, we strongly recommend that you set up two-factor authentication for your TTEPL user account. This adds an extra authentication step, to make sure that anyone who gets hold of your username and password (e.g., through phishing or social engineering) won’t be able to get into your account. You can set this up in the Security section of your account settings.
How does TTEPL treat personal data belonging to children?
Our services aren’t intended for children under 18 years old, and we’ll never collect their data unless it’s provided by (and with the consent of) a parent or guardian. The limited circumstances we might need to collect the personal data of children under 18 years old include: as part of a reservation, the purchase of other travel-related services, or in other exceptional circumstances (such as features addressed to families). Again, this will only be used and collected as provided by a parent or guardian and with their consent.
If we become aware that we’ve processed the information of a child under 18 years old without the valid consent of a parent or guardian, we will delete it.
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.
Rights to object to direct marketing
If we process your personal data for the purpose of direct marketing Article 21(2) GDPR gives you the right to object at any time to the processing of your personal data for the purpose of direct marketing; this also applies to profiling, as far as it is associated with direct marketing.
If you object to processing for the purpose of direct marketing, we will no
How can you exercise your rights and control the personal data you’ve given to TTEPL?
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.
If you have a TTEPL user account, you can access a lot of your personal data through our website or apps. You’ll find the option to add, update or remove information we have about you in your account settings.
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 TTEPL 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:
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).
How to contact us
TTEPL’s Data Protection Officer is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data. Please contact us at sales@topgoatours.com You can contact us for any concerns or questions about your personal information, those we process or store.
Our cookie statement may also be updated from time to time. If these updates are substantial, particularly relevant to you or impact your data protection rights, we’ll contact you about them. However, we recommend that you visit this page regularly to stay up to date with any other (less substantial or relevant) updates.
