PRIVACY POLICY

By visiting Regal Comfort Travels platforms (“Website, Mobile site and Mobile Apps”), you are accepting and consenting to the practices described in this Privacy Notice (as defined here in after). This document describes the privacy policy (“Privacy Notice”) of Regal Comfort Travels Services (India)Private Limited (“Regal Comfort Travels” or “we” or “us” or “our”)and is designed to explain guest users or registered users of the Website, Mobile site and Mobile Apps, Mobile site and Mobile Apps including(without limitation) buyers of bus tickets, customers who are using our hotel booking facility, bus partners, bus ticket booking agents, intermediaries who sell services on the Website, Mobile site and Mobile Apps, other users/visitors of the Website, Mobile site and Mobile Apps (“you” or “your” or “yourself “or “user”) what data/information we collect, why we collect it, and what we do with it. Your use of and access to the Website, Mobile site and Mobile Apps and the services provided through

(i) the Website, Mobile site and Mobile Apps and

(ii) mobile site, mobile app and other offline channels including call centres and offices (“Other Interfaces”) are inter alia subject to this Privacy Notice and our Terms and Conditions. Any capitalized term used but not defined in this Privacy Notice shall have the meaning attributed to it in our Terms and Conditions. This Privacy Notice is applicable all persons including persons/entities who purchase, intend to purchase or inquire about any product(s) or service(s) made available by Regal Comfort Travels through the Website, Mobile site and Mobile Apps and Other Interfaces (collectively “Services”). If you disagree with any provision contained in this Privacy Notice, then please do not

(iii) use or access the Website, Mobile site and Mobile Apps or Other Interfaces or avail any of the Services. By using or accessing the Website, Mobile site and Mobile Apps or Other Interfaces, the User hereby agrees with the Privacy Policy in its entirety and the contents here in.

A.INFORMATION YOU PROVIDE AND WE COLLECT

  1. GENERAL

Regal Comfort Travels provides a technology platform for online bus ticketing that connects intending travelers with bus partners. Regal Comfort Travels does not own or operate or offer the services of transportation to the user. Regal Comfort Travels also doesn’t act as an agent of any bus partner in the process of providing the above-mentioned technology platform services.

Regal Comfort Travels acts as a marketplace facilitating booking of railways tickets and therefore, neither influences nor controls the booking flow, scheduling/rescheduling, confirmation from Waitlisted or RAC to confirmed, cancellations or other changes to the delivery timelines or other related aspects of the railway tickets on offer, delays, meal and berth preferences or any other lack or deficiency of services. Regal Comfort Travels is merely a platform to search for desired train tickets to be booked through IRCTC. All bookings or train reservations made through Regal Comfort Travels are subject to the applicable Terms & Conditions as set out by Indian Railways.

INFORMATION YOU PROVIDE TO US AND ITS USE AND SHARING

(a) We receive and store any information you enter on our Website, Mobile site and Mobile Apps or give us in any other way. In general, you can browse the Website, Mobile site and Mobile Apps without telling us who you are or revealing any personal information about you. Once you give us your personal information, you are not anonymous to us.

(b) We collect personally identifiable information (email address, other addresses, name, phone number, gender, travel preferences, travel plan, accommodation details, hotel bookings/preferences, telephone (mobile or otherwise) and/or fax numbers.etc.) from you when you register and create an account with us, and that you provide to us from time to time. 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).

(c) Further, we may collect certain other information, including (without limitation) the following information, while you

(i) use the Website, Mobile site and Mobile Apps and/or

(ii) access any service made available by Regal Comfort Travels through the Website, Mobile site and Mobile Apps and Other Interfaces:

(i)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.;

(ii) Transactional history (other than banking details) about your e-commerce activities, buying behavior on the Website, Mobile site and Mobile Apps and Other Interfaces;

(iii) User names, passwords, email addresses and other security-related information used by you in relation to the Services;

(d)Such information collected by us may include information considered to be ‘sensitive personal information’ of the user under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“Spirals”).Such ‘sensitive personal information’ generally includes user’s information relating to password, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, and biometric information. Further, the SPI Rules require your express consent to collect, store and use such personally identifiable information collected by us. You hereby consent to such use, collection, storage and disclosure of ‘sensitive personal information’ by us in accordance with this Privacy Notice as required under applicable law.

(e)Where possible, we indicate the fields which are required and the fields which are optional. You [always] have the option to not provide information by choosing not to use a particular service or feature on the Website, Mobile site and Mobile Apps. You [always] have the option to withdraw your consent, upon which we have the option not to provide services for which the consent was sought.

(f)In case you are booking bus tickets, hotel rooms or any other service on the Website, Mobile site and Mobile Apps and/or through Other Interfaces for and/or on behalf of other persons, you here by confirm and represent that each of such other person(s)/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).

(g)While making a booking, we may use ‘sensitive personal information’ including, payment details which include card holder name, credit/debit card number (in encrypted form) with an 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. Further, we may use your ‘sensitive personal information’ to provide seamless and convenient services and such uses will include (without limitation)

(i) confirmation of your reservations/bookings with you and respective service providers,

(ii) informing of the transaction status,

(iii) communicating booking confirmations either via electronic means or other messaging service,

(iv) communicating any updates or changes to your booking(s),

(v) enabling customer service team to contact you, if necessary,

(vi) customize the content of the Website, Mobile site and Mobile Apps and other Interfaces;

(vii) request for reviews of the Services or any other improvements

(viii) sending verification message(s) or email(s)

(ix)validating/authenticating your account and to prevent any misuse or abuse and

(x)contact you to offer offers. Further to the above, your information will be shared with the end service providers like hotels, bus service providers or other suppliers who are responsible for fulfilling your booking. We may employ other companies and individuals to perform functions on our behalf (including but not limited to payment processing, data hosting, and data processing platforms). We may also share certain 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 (like travel insurance, discount coupons, entertainment services), which will enable the customer to have better travel experience or to avail certain benefits specially made for Regal Comfort Travels customers. We may provide anonymous statistical information based on this data to suppliers, advertisers, affiliates and other current and potential business partners. You may note that while making a booking with Regal Comfort Travels you authorize us to share your information with the said service providers and suppliers. Regal Comfort Travels 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. Nevertheless, the information shared with such service providers/suppliers is beyond the purview and control of Regal Comfort Travels, and hence we are not accountable for any unauthorized use of such information by any service provider/supplier. You are therefore advised to review the privacy policies of the respective service provider or supplier whose services you choose to avail

(h)We may share user information with entities that control, are controlled by or are under the common control with Regal Comfort Travels and that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice. Further, we may share user information with our affiliates or associate entities. If the assets and/or business of Regal Comfort Travels are acquired, our customer information may also be transferred to the acquirer depending up on 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 here in shall be transferred accordingly

(I)We use non-identifiable information in aggregate or anonym zed form to build higher quality, more useful online services by performing statistical analysis of the collective characteristics and behavior of our customers and visitors

(j)We receive and store certain types of information whenever you interact with us. We may also receive/store information about your location and your mobile device, including a unique identifier for your device. We may use this information for internal analysis and provide you with location-based services, such as search results and other personalized content. We may automatically track certain information about you based upon your behavior on our Website, Mobile site and Mobile Apps. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you. This information is compiled and analyzed on an aggregated basis. This information may include your login, e-mail address, password, computer and connection information such as browser type and version, operating system and platform, transaction history, which we sometimes aggregate with similar information from other customers to create customized or additional features, the full uniform resource locators (URL) click stream to, through and from our Website, Mobile site and Mobile Apps (including date and time), cookie number, travel routes, service providers, bus partners or hotel bookings you viewed or searched for, and any phone number used to call our customer service number.

(k)We may also use browser data such as cookies, flash cookies (also known as ‘flash local shared objects’), or similar data on certain parts of our Website, Mobile site and Mobile Apps for fraud prevention and other purposes. During some visits, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

(l)If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

(m)We might receive information about you from other sources and add it to our account information. If other users or third parties send us correspondence about your activities, we may collect such information into a file specific to you.

(n)We release account and other personal information when we believe release is appropriate to comply with the law, enforce or apply our Terms and Conditions and other agreements, or protect the rights, property or safety of Regal Comfort Travels, our users or others. This includes exchanging information with other companies, organizations, government or regulatory authorities for fraud protection and credit risk reduction. However, this does not include selling, renting, sharing or otherwise disclosing personally identifiable information from customers for commercial purposes in a way that is contrary to our commitments under this Privacy Notice.

(o)In addition to the circumstances described above, Regal Comfort Travels may disclose the information if required to do so by law, required by any enforcement authority for investigation, required by court order or in reference to any legal process and regulatory, required for internal compliance and audit exercise or required for protecting the rights and business of Regal Comfort Travels.

(p)Other than as set out above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information. Whenever we transfer personal information to countries outside India in the course of sharing information as set out above, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws including but not limited to Information Technology Act, 2000 and the rules framed there under.

B.PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS

ANDROID PERMISSIONS:

  1. Device and 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.
  2. 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 experience. It also 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.
  3. Location: This permission enables us to give you the benefit of location-specific deals and provide you with a personalized experience. When you launch Regal Comfort Travels app to make a travel booking, we auto-detect your location so that your nearest city is auto-filled. We also require this permission to be able to help you track your bus with respect to your location.
  4. SMS: If you allow us to access your SMS, we read your SMS to auto fill or prepopulate ‘OTP’ while making a transaction and to validate your mobile number. This provides you with 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.
  5. Phone: The app requires access to make phone calls so that you can make phone calls to bus partners, hotels and our customer contact centers directly through the app.
  6. Photo/Media/ Files: The libraries in the app use these permissions to allow users to save and upload multimedia reviews.
  7. Wi-Fi connection information: When you allow us permission to detect your Wi-Fi connection, we optimize your band width usage for multimedia uploads.
  8. Device ID and 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.
  9. Camera: This permission is used to capture pictures of the boarding point or bus before the journey. This image can then upload as part of multimedia reviews.
  10. Calendar: This permission enables us to put your travel plans on your calendar.

IOS PERMISSIONS:

  1. 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 booking confirmation, a refund (in case of cancellation), etc. will be sent through SMS.
  2. Contacts: This permission enables us to know about the 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 experience. It also 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.
  3. Location: This permission enables us to give you the benefit of location-specific deals and provide you with a personalized experience. When you launch Regal Comfort Travels app to make a travel booking, we auto-detect your location so that your nearest city is auto-filled. We also require this permission to be able to help you track your bus with respect to your location.
  4. Photo/Media/ Files: The libraries in the app use these permissions to allow users to save and upload multimedia reviews.
  5. Camera: This permission is used to capture pictures of the boarding point or bus before the journey. This image can then upload as part of multimedia reviews.
  6. Calendar: This permission enables us to put your travel plans on your calendar.

C. COOKIES

  1. A ‘cookie’ is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. We place both permanent and temporary cookies in your computer’s hard drive.
  2. We use data collection devices such as ‘cookies’ on certain pages of the Website, Mobile site and Mobile Apps to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help provide information that is targeted to your interests. Most cookies are “session cookies”, meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case, you may not be able to use certain features on the Website, Mobile site and Mobile Apps and you may be required to re-enter your password more frequently during a session.
  3. Additionally, you may encounter “cookies” or other similar devices on certain pages of the Website, Mobile site and Mobile Apps that are placed by third parties. We do not control the use of cookies by third parties.

D. SECURITY OF YOUR INFORMATION

  1. We strive to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input in addition to maintaining the security of your information as per the International Standard IS/ISO/IEC 27001 on “Information Technology Security Techniques Information Security Management System-Requirements”.
  2. 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, Mobile site and Mobile Apps have 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.
  3. We maintain physical, electronic and procedural safe guards in connection with the collection, storage and dis closure of personal information (including sensitive personal information). Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
  4. It is imperative that you have measures to safeguard against unauthorized access to your password and to your computer. Please ensure that you read and understand the terms and conditions which are set out in the Conditions of Use, in this regard.

E. PERSONS WHO ARE ELIGIBLE TO USE THE WEBSITE, MOBILE SITE AND MOBILE APPS

Use of the Website, Mobile site and Mobile Apps is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are a minor, i.e., under the age of 18 years, or do not have the capacity to enter into a legally binding contract, you may use the Website, Mobile site and Mobile Apps only with the involvement of a parent, guardian or a duly authorized person.

F.MODIFY YOUR PRIVACY PREFERENCES

  1. As mentioned above, you can choose not to provide information, even though it might be needed to make proper use of the Services or to take advantage of some of the features offered through the Website, Mobile site and Mobile Apps.
  2. You can add or update certain information on some of the pages of the Website, Mobile site and Mobile Apps, such as your profile. When you update information, we usually keep a copy of the previous version for our records.
  3. If you do not want to receive e-mail or other mail from us, you will be free to adjust your preferences to reflect the same. However, even in case you do not want to receive Conditions of Use and other legal notices from us, such as this Privacy Notice, all those notices will still govern your use of Website, Mobile site and Mobile Apps and requests placed with us, and it is your responsibility to review them for changes.

G. NOTICES AND REVISIONS

  1. Our business operations and our business are bound to change constantly, and so our Privacy Notice and the Conditions of Use will change also. We may e-mail periodic reminders of our notices and conditions unless you have instructed us not to, but you should check our Website, Mobile site and Mobile Apps frequently to see recent changes.
  2. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account. By using or continuing to use the Website, Mobile site and Mobile Apps you agree to our use of your information (including sensitive personal information) in accordance with this Privacy Notice, as may be amended from time to time by Regal Comfort Travels at its sole discretion. You also agree and consent to us collecting, storing, processing, transferring and sharing information (including sensitive personal information) related to you with third parties or service providers for the purposes as set out in this Privacy Notice.
  3. If you have any concern about privacy or grievances regarding the Website, Mobile site and Mobile Apps, please email us at support Regal Comfort Travels with a detailed description and we will endeavor to resolve the issue for you.

BY VISITING OUR WEBSITE, MOBILE SITE AND MOBILE APPS AND/OR BY USING THE SERVICES OR BY OTHER WISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ,UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY NOTICE AND AGREE TO BE BOUND BY THE PRIVACY NOTICE. YOU HERE BY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY NOTICE, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY NOTICE AT ANY TIME, DO NOT USE ANY OFTHE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOME ONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY NOTICE ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE.

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