Privacy Policy
This Privacy Policy was last updated on 26th July 2024.
Travel Million Company, including all legal entities under the
Travel Million group (hereafter referred to as "Travel Million" or
"we") with an exception of Travel Million Company(TMC), respects
your (customers - hereafter referred as "you" or "user") privacy and
values our relationship with our business partners, clients, third
parties having contractual relationship with Travel Million
(hereafter referred to as "third party" or "service provider"), and
any party who purchases/intend to purchase/inquire about any
product(s) and/or service(s) made available by Travel Million
through any of Travel Million' s customer interface channels
including Website, mobile site, mobile app & offline channels
including call centers and offices (collectively referred herein as
"Sales Channels"). We are committed to protecting your personally
identifiable information (hereafter referred as "information" or
"personal information" or "personal data" or "special category of
personal data") by handling it responsibly and safeguarding it using
appropriate technical and organizational measures.
We want to assure you that we follow appropriate standards when it
comes to protecting your privacy on our Sales Channel. This policy
outlines the types of personal information collected on our Website,
how this data is used/processed and safeguarded as well as how users
may exercise their rights with respect to personal nginformation.
This Privacy Policy applies to Travel Million.com, Travel Million
company pages, communications and services ("Services"), including
off-site Services, such as our email services, customer care and
support services and the "Contact us"; "Apply with Travel Million"
and "Share on" plugins on our digital properties.
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.
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 the
information and privacy practices of Travel Million's business
partners, advertisers, sponsors or other sites to which we provide
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.
Travel Million for Business (Corporate): In the event Travel Million
is providing services to you as part of our agreement with your
employer, contractor, business partner, affiliate or any other party
who is having a contractual arrangement with Travel Million, then
the terms and conditions stipulated in such contractual arrangement
shall prevail over this data privacy policy. Such agreement may
involve sharing personal data they control as part of that
engagement. Our services may also include processing personal data
under our client's control on our hosted software applications. All
such processing will be governed by Travel Million's client privacy
policy.
In case you book travel services on behalf of your family or a
minor, you agree:
● To inform the individual about the content of this privacy
policy
● To obtain any legally-required consent, for the collection, use,
disclosure, and transfer (including cross-border transfer) of
individual's personal information, from the individual in accordance
with the legal and regulatory requirements
In such a scenario, Travel Million will be acting as data processors
while your respective employer, contractor, business partner,
affiliate shall be acting as the data controller. It will be the
obligation of the data controller to seek consent of the end
customer.
1. What Personal Data shall we collect?
a. We collect the following personal and sensitive information from
you when you transact through us:
● Name, gender, age and date of birth
● Contact information such as address, email, and mobile phone
number
● Country of residence
● Payment Details like Credit Card/ Debit Card details along with
their expiry date (billing address in case of international
debit/credit card).
● Passport Number & frequent flyer number (wherever needed)
● Lifestyle and social circumstances (for example, your hobbies)
● Family details/information (for example, your marital status and
dependents)
● Employment and education details (for example, the organization
you work for, your job title and your education details)
● Financial and tax-related information (like your income,
investments and tax residency)
● Postings or messages on any blogs, forums, platforms, wikis or
social media applications of Travel Million and Travel Million' s
third parties
● IP address, browser type and language, your access times
● Information in any complaints you make
● Details of how you use our products and services
● CCTV footage and other information we collect when you access
our premises
● Recording of telephone calls to our representatives and call
centers
● Details of how you like to interact with us ( through email, SMS
or whatsapp) and other similar information relevant to our
relationship
● Details shared by you over our chatbot - WhatsApp
b. The personal data we collect may also include 'sensitive' or
'special categories' of personal data such as details about your:
● Dietary requirements (for example, while providing your meal
preference during flight/ hotel bookings)
● Health (so that we can make it easy for you to access our
buildings, products and services, and/or any special assistance
required by you)
● Sexual orientation (if you provide us with details of your
spouse or partner)
If you choose not to provide, or object to us processing the
information we collect, we may not be able to process your
instructions or continue to provide some or all of our services to
you (including our clients)Personal information of other
customers/users/travelers
If you provide personal information to us regarding individuals
other than yourself, you agree
● To inform the individual about the content of this privacy
policy
● To obtain any legally-required consent, for the collection, use,
disclosure, and transfer (including cross-border transfer) of
individual's personal information, from the individual in accordance
with the legal and regulatory requirements
c. Personal information of child
The Services are not intended for users under the age of 16
(Permissible Age), unless permitted under applicable local laws. We
do not knowingly collect any personal information from you or the
market to solicit information from anyone under the Permissible Age.
If we become aware that a person submitting personal information is
under the Permissible Age, we will delete the account and any
related information immediately. If you believe we might have any
information from or about you under the Permissible Age, please
contact us at help@travelmillion.com.
d. We use third party services/bots to capture the following
additional information:t
● Analytics
● Infrastructure monitoring Geographic position, unique device
identifiers for advertising
● Location-based interactions: Geographical locations
● Unique device identification: This Application may track Users
by storing a unique identifier of their device, for analytics
purposes or for storing Users' preferences.
2. How do we collect Personal Data?
a.Directly: We obtain personal data directly from individuals in a
variety of ways , including but not limited to obtaining personal
data from individuals who provide their personal information via
registrations or guest account for booking travel services, their
business card, complete our online forms on our website/mobile app,
provide records relating to previous requests or reservations made,
Individuals who subscribe to our newsletters and preference center,
register for webinars, and attend meetings or events we host or
visit our offices. We may also obtain personal data directly when we
are establishing a business relationship, performing professional
service through a contract, or through our hosted software
applications.
b. Indirectly: We obtain personal data indirectly about individuals
from a variety of sources, which includes but is not limited to
travel agents, other travel websites, social media, authorized
representative from whom you seek travel services on behalf of
others and our clients. We may add personal data to our customer
relationship management records to better understand and serve you,
or to satisfy a legal obligation.
● Public sources - Personal data may be obtained from public
sources such as news articles and Internet searches.
● Social and professional networking sites - If you register or
login to our websites using social media (e.g., LinkedIn, Google, or
Twitter) to authenticate your identity and connect your social media
login information with us, we will collect information or content
needed for the registration or login that you permitted your social
media provider to share with us. That information may include your
name and email address and depending on your privacy settings,
additional details about you, so please review the privacy controls
on the applicable service to set how much information you want to be
shared with us.
● Business clients - Our business clients may engage us to provide
products/services offered by us which involves sharing personal data
they control as part of that engagement. Our services may also
include processing personal data under our client's control on our
hosted software applications. All such processing will be governed
by Travel Million's client privacy policy.
3. What lawful reasons do we have for processing Personal Data?
We may rely on the following lawful reasons when we process your
personal data to operate our business and provide our products and
services:
a.Contract - We may process personal information in order to perform
our contractual obligations to which you (data subject) or our
client (data controller) is party. Please refer to the section -
Travel Million for Business (Corporate)
b. Consent - We may rely on your freely given, specific, informed
and unambiguous consent at the time you provided your personal
information to us for one or more specific purposes
c. Legitimate interests - We may rely on legitimate interests based
on our evaluation that the processing is fair, reasonable and
balanced
d. Legal obligations - We may process personal information where
processing is necessary for the purposes of the legitimate interests
pursued by the controller or by a third party, except where such
interests are overridden by the interests or fundamental rights and
freedoms of the data subject, which require protection of personal
data, in particular where the data subject is a child.
4. How will we use/process your personal data
a. We do not sell or trade upon any of the above foregoing
information without your consent. The foregoing information
collected from you is put to the following use:
● For the purpose of fulfillment of services which include travel
reservation and booking for you and for individuals whose
information has been provided by you.
● Information like Credit Card/ Debit Card, Expiry Date and Net
Banking Details that we store, in case a customer opts for it, are
in adherence to the PCI Compliance and are stored in an encrypted
form in a segmented zone. We do not store CVV details. These details
may also be processed with the help of certain third parties only
for the purpose of processing 'Cash Back & Discounts' and Charge
Backs, if applicable.
● Information like Mobile number, e-mail address and postal
address may be used for promotional purposes, unless the
customer/user opts-out of such use.
● To manage and respond to any request you submit through our
website.
● To meet legal and regulatory requirements.
● Promoting our professional services, products and capabilities
to existing and prospective business clients/customers.
● Sending invitations and providing access to guests attending our
events and webinars or our sponsored events.
● Personalizing online landing pages and communications we think
would be of interest based on interactions with us and group
companies.
● To effectively communicate with you like through SMS, emails or
whatsapp
If you choose not to share this information, you can still visit our
website, but you may be unable to avail certain options or our
services.
b. How we use Cookies?
In general, you can visit our website without telling us who you are
or revealing any personal information about yourself. We track the
Internet address of the domains from which people visit us and
analyse this data for trends and statistics, but the individual user
remains anonymous.
Some of our web pages use "cookies" so that we can better serve you
with customized information when you return to our website. Cookies
are identifiers which websites send to the browser on your computer
to facilitate your next visit to our website. You can set your
browser to notify you when you are sent a cookie, giving you the
option to decide whether or not to accept it. The information we
collect and analyse is used to improve our service to you. However,
our mobile phone application "Adopt-A-Heritage", does not use
cookies.
To learn more, please refer Annexure A: Cookie policy.
c. Permissions required to use various features in our Travel
Million app (Android and IOS):
In order to have a better experience and to use all features in the
app, we need below permissions to be used in our app:
● Camera: We will not access your photos or camera without first
getting your permission and we will never scan or import your photo
library or camera roll. If you give us permission to access photos
or your camera, we will only use images that you specifically choose
to share with us.
● Contacts: We will not scan or import your contacts stored on
your phone without first getting your explicit permission. We will
only use the contact information to help you find friends or
contacts who use Travel Million App, if you choose to do so, and we
will not use contact information for any other purpose without first
getting your separate explicit permission.
● Calendar: This permission enables us to put your travel plan on
your calendar.
● Location: We will not gather or use the specific location of
your mobile device (by using, for example, GPS or Bluetooth) without
first getting your explicit permission. And if you choose to share
location information but later change your mind, you will always
have the option to stop sharing. Please note that this does not
include IP address. The permissions will benefit the user location
specific deals and provide you a personalized experience with time
zone.
● Get Accounts: This permission enables us to know about details
of your account(s) on your mobile device. This will help you to get
register on the Platform by logging into online accounts you may
have with Third Party social networking sites (e.g. Facebook, Google
Login)
● Access WiFi State: By using Wi-Fi connection details, we provide
you a seamless experience depending upon your network. We try to use
this information to optimize the app's performance on slow networks.
● Third Party: The User allow us to provide services to third
party service accounts for Displaying content from external
platforms, SPAM protection, Hosting and back-end infrastructure,
Infrastructure monitoring, Content commenting, Interaction with
external social networks and platforms, Location-based interactions,
Social features, Contacting the User, User database management,
Targeted Advertising and Re-marketing and behavioral targeting.
● In addition to these permissions, below mentioned permission is
additionally required by our Android Application:SMS/ Whatsapp: This
application reads, uploads and do syntactic analyses of text
messages from travel providers within the app for any flight and
train PNR booking messages. We use this information to provide
updates on PNR status, flight and train delays. This information is
stored in a secured environment and always transmitted using SSL.
d.Permissions required to use various features in our Adopt A
Heritage (AAH) app - Android and IOS:
● Camera/Storage: We will not access your photos or camera without
first getting your permission and we will never scan or import your
photo library or camera roll. If you give us permission to access
photos or your camera, we will only use images that you specifically
choose to share with us.
● Location: We will not gather or use the specific location of
your mobile device (by using, for example, GPS or Bluetooth) without
first getting your explicit permission. And if you choose to share
location information but later change your mind, you will always
have the ability to stop sharing. Please note that this does not
include IP address. The permissions will benefit the user
location-specific deals and provide you a personalized experience
with the time zone.
● Third-Party: The User allows us to provide services to third
party services' accounts for Displaying content from external
platforms, SPAM protection, Hosting and backend infrastructure,
Infrastructure monitoring, Content commenting, Interaction with
external social networks and platforms, Location-based interactions,
Social features, Contacting the User, User database management,
Targeted Advertising, and Remarketing and behavioral targeting.
5. With whom do we share your Personal Data?
In connection with any of the purposes outlined in the "How will we
use/process the personal data" section above, we may disclose
details about you to:
a. travel service providers such as travel wholesalers, tour
operators, airlines, hotels, car rental companies, transfer handlers
and other related service provides
b. suppliers of IT based solutions and products that assist us in
providing services to you (such as any external data hosting and
monitoring providers we may use, communication service providers)
c. Competent authorities (including auditors, courts and authorities
regulating us for internal compliance and audit(s)) as required or
authorized by applicable law, and to comply with our legal and
regulatory obligations;
d. Credit reference agencies or other third party organizations
(CyberSource, Paypal) that help us make credit decisions or conduct
risk checks to reduce the incidence of fraud
e. Other organizations to whom we may transfer our rights and/or
obligations under the Terms agreed between Travel Million and
respective organization
f. Any other person or organization after a restructure, sale or
acquisition of any member of the Travel Million group, as long as
they use your personal information for the same purposes we did
g.The analytics service providers which with whom the data may be
shared are:
● Google Analytics, Appsflyer, Facebook Ads conversion tracking,
Google Tag Manager, Datadog, Adara
● Crashlytics - Geographic position, unique device identifiers for
advertising (Google Advertiser ID or IDFA, for example) and various
types of Data as specified in the privacy policy of the service
h. We share following data with MoEngage through their SDK which is
used to send any personalized App Notification to the end user
● Account Name
● Account Email Address
● Account Mobile Number
● Account User ID
● User's Location
i. And other members of Travel Million Group/ third parties that may
reasonably require access to personal data relating to you or
providing services to you. With specific reference to third party,
we use third-party service providers to serve ads on our behalf
across the Internet and sometimes on this site. They may collect
anonymous information about your visits to our website, and your
interaction with our products and services. They may also use
information about your visits to this and other websites to target
advertisements for goods and services. This anonymous information is
collected through the use of a 'pixel tag', which is industry
standard technology used by various major websites. No personally
identifiable information is collected or used in this process. Such
third parties do not know your name, phone number, address, email
address, or any personal information which can identify you.
Our website hosts various blogs, forums, wikis and other social
media applications or services that allow you to share content with
other users (collectively "Social Media Applications"). Any personal
data that you contribute to these Social Media Applications can be
read, collected and used by other users of the application. We have
little or no control over these other users, so any information you
contribute to these Social Media Applications might not be handled
in line with this privacy policy.
6. Where do we transfer (cross boarder transfer) your Personal Data?
Information we hold about you may be transferred to countries:
a. where we do business
b. which are linked to your engagement with us
c. from which you regularly receive or transmit information
d. Where our third parties conduct their activities
We may share non-personal, anonymized and aggregated information
with third parties for several purposes, including data analytics,
research, submissions, thought leadership and promotional activity.
7. How we protects your Personal Data?
We have implemented appropriate technical and organizational
measures to safeguard and help prevent unauthorized access to your
information and to maintain data security. These safeguards take
into account the sensitivity of the information that we collect,
process and store and the current state of technology. We follow
generally accepted industry standards to protect the personal
information submitted to us, both during transmission and once we
receive it. The third party with respect to payment gateway and
payment processing are all validated as compliant with the payment
card industry standard (generally referred to as PCI compliant
service providers).
We assume no liability or responsibility for disclosure of your
information due to errors in transmission, unauthorized third-party
access or other causes beyond our control. You play an important
role in keeping your personal information secure. You should not
share your user name, password, or other security information of
your Travel Million account with anyone. If we receive instructions
using your registered email ID or username, we will consider that
you have authorized the instructions.
8. What are your data Protection Rights?
Your data protection rights are highlighted below:
a. Right to Access - You may ask us to verify whether we are
processing personal data about you, and if so, to provide more
specific information.
b. Right to Correction - You may ask us to correct our records if
you believe they contain incorrect or incomplete information about
you.
c. Right to Erasure - You may ask us to erase (delete) your personal
data after you withdraw your consent to process it, or when we no
longer need it for the purpose it was originally collected and we
shall erase your personal data, subject to the data retention
requirements under the applicable rules, regulations, guidelines,
law, by-law, to meet our legal/regulatory obligations. Please note,
even after completion of your request regarding account or data
deletion, we will be retaining transactional data to meet our legal
obligations.
d. Right to Processing restrictions - You may ask us to temporarily
restrict our processing of your personal data if you contest the
accuracy of your personal data, prefer to restrict its use rather
than having us erase it, or need us to preserve it for you to
establish, exercise, or defend a legal claim. A temporary
restriction may apply while verifying whether we have overriding
legitimate grounds to process it. You can ask us to inform you
before we lift that temporary processing restriction.
e. Right to Data portability - You may request portability of your
personal data, which shall be limited to the transfer of information
pertaining to the customer profile and transaction records, to
another data controller.
f. Automated Individual Decision-making - You may ask us to review
any decisions made about you which we made solely based on automated
processing, including profiling, that produced legal effects
concerning you or significantly affecting you.
g. Right to Object to Direct Marketing including Profiling - You may
object to our use of your personal data for direct marketing
purposes, including profiling. We may need to keep some minimal
information to comply with your request to cease marketing to you.
h. Right to Withdraw Consent - You may withdraw your consent that
you have previously given to one or more specified purposes to
process your personal data. This will not affect the lawfulness of
any processing carried out before you withdraw your consent.
However, this may lead to Travel Million not able to provide certain
products or services to you.
We may need to request specific information from you to help us
confirm your identity and ensure your right to access the
information or to exercise any of your other rights. This helps us
to ensure that personal data is not disclosed to any person who has
no right to receive it. No fee is required to make a request unless
your request is clearly unfounded or excessive. Depending on the
circumstances, we may be unable to comply with your request based on
other lawful grounds.
9. How long shall we retain/ dispose your Personal Data?
We seek to ensure that we only keep your personal data for the
longest of:
a. the period necessary for the relevant activity or services
b. any retention period that is required by law
c. the period in which litigation or investigations might arise in
respect of the services
Please note: Even after your account is terminated, we retain your
transactional data for as long as we have a legitimate purpose to do
so (and in accordance with applicable law), including to assist with
legal obligations, resolve disputes, and enforce our agreements. We
may retain and disclose such data pursuant to this Privacy Policy
after your account has been terminated.
10. Changes to this privacy statement:
From time to time we may update this statement. When we do, we will
publish the changes on this Website. If you do not agree with these
changes, you can discontinue your use of our Website.
11. How to contact us, request access to your personal data or
contact us with questions or feedback?
If you have a question, comment, or complaint or wish to access a
copy of your personal data or to correct it if you believe it is
inaccurate, you may contact us at help@travelmillion.com
Please note, we will not be responding to any operational enquiries
and for such support, kindly drop a mail to
support@travelmillion.com
Annexure A: Cookie Notice
This Website uses cookies to improve the user experience and ensure
that it is functioning effectively, and on occasion also to provide
marketing information or advertise online, either directly or
through third party vendors.
In order to provide you with a more personalized and responsive
service, Travel Million needs to remember and store information
about how you use this Website. This is done using small text files
called cookies. Cookies contain small amounts of information and are
downloaded to your computer or other device by a server for this
Website. Your web browser then sends these cookies back to this
Website on each subsequent visit so that it can recognize you and
remember things like your user preferences. You can find below more
detailed information about cookies.
By using this Website, you agree to Travel Million's use of cookies
as described in this Cookie Notice.
What cookies do Travel Million use and why?
Some of the cookies Travel Million uses are mandatory and cannot be
disabled so as to enable you to move around the Website and use its
features such as accessing secure areas that may contain content for
registered users. Should you not wish to allow Travel Million use
the said cookies, you may at your wish stop using the Travel Million
Website.
Travel Million also uses functional cookies to record information
about the choices you have made and to allow it to tailor the site
to its users; for example, to remember your language or region or
that you have already completed a survey. This information is
usually anonymized and is not used for any other purpose.
Travel Million or its service providers also use analytic services
to understand how effective Travel Million content is, what
interests Travel Million users have, and to improve how this Website
works. In addition, Travel Million use web beacons or tracking
pixels to count visitor numbers and performance cookies to track how
many individual users access this Website and how often. This
information is used for statistical purposes only and it is not
Travel Million's intention to use such information to personally
identify any user. However, if you have registered and signed into
this Website, Travel Million may combine this information with
information from its web analytic services and cookies to analyse
how you use this Website in more detail.
How to control cookies?
By using this Website, you agree that Travel Million can place
cookies on your computer or device as explained above. Please bear
in mind that removing or blocking cookies can impact user experience
and parts of this website may no longer be fully accessible.
Browser controls
Most browsers will allow you to see what cookies you have, and
delete them on an individual basis or block cookies from any
particular or all websites. Be aware that any preference you have
set will be lost if you delete all cookies, including your
preference to opt-out from cookies, as this itself requires an
opt-out cookie to have been set. Also, this may also lead to
unavailability of some services.
Managing Analytics cookies
Travel Million use the following service providers and you can learn
more about their privacy policies by clicking on following links:
Google Analytics:
https://www.google.com/analytics/learn/privacy.html
Leadsquared: https://www.leadsquared.com/privacy-policy/
Managing Local Shared Objects
A local shared object is like most other browser cookies except that
it can store additional types of information. These cookies cannot
be controlled using the mechanisms listed above. Our Website uses
these types of cookies to store user preferences for media player
functionality and without them some video content may not play
properly.
Social buttons
The Website contains 'social buttons' to enable users to share or
bookmark web pages. These are buttons for third party social media
sites and these sites may log information about your activities on
the Internet including on this Website. Please review the respective
terms of use and privacy policies of these sites to understand
exactly how they use your information.
External web services
Travel Million sometimes uses external web services on this Website
to display content within the web pages of this Website, for example
to display images, show videos or run polls. As with the social
buttons, Travel Million cannot prevent these sites or external
domains, from collecting information on your use of this embedded
content.
Email Communications
Travel Million may also use tracking technologies to determine
whether you have read, clicked on, or forwarded certain email
communications which Travel Million sends to you, to make its
communications more helpful and interesting. If you do not wish
Travel Million to confirm whether you have opened, clicked or
forwarded its communications, you will need to unsubscribe, as it is
not possible for Travel Million to send these emails without
tracking enabled. Registered subscribers can unsubscribe following
the instructions in the individual email communications you receive
from Travel Million.
Travel Million may modify or amend this Cookie Notice from time to
time at its discretion. When Travel Million makes a change to this
notice, it will amend the revision date at the top of this page, and
such modified or amended Cookie Notice shall be effective to you and
your information as of that revised date. Travel Million encourages
you to periodically review this Cookie Notice to be informed about
how it is using cookies.