Comfortable Holidays, including all legal entities under the Comfortable Holidays(hereafter referred to as "Comfortable Holidays" or "we"), 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 Comfortable Holidays (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 Comfortable Holidays through any of Comfortable Holidays' 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 information.
This Privacy Policy applies to Comfortable Holidays, Comfortable Holidays-branded apps, Comfortable Holidays 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 Comfortable Holidays" 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. However, in the event Comfortable Holidays 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 Comfortable Holidays, then the terms and conditions stipulated in such contractual arrangement shall prevail over this data privacy policy.
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 Comfortable Holidays' 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.
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
· Credit Card details
· 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 Comfortable Holidays and Comfortable Holidays’ 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 and
· Details of how you like to interact with us, and other similar information relevant to our relationship
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
d. 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 · Analytics: Google Analytics, Appsflyer, Facebook Ads conversion tracking, Google Tag Manager, Intent Media, Adara
· Adobe Analytics: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.
· Infrastructure monitoring: 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.
· 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 us 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, 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 Comfortable Holidays’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.
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 reservation and booking the services for you and for individuals whose information has been provided by you.
· Information like Credit Card Details 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.
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 Comfortable Holidays 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 Comfortable Holidays 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, Twitter, Google Login); each such account
· 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: 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:
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/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 that assist us in providing services to you (such as any external data hosting providers we may use)
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 Comfortable Holidays and respective organization/p>
f. Any other person or organization after a restructure, sale or acquisition of any member of the Comfortable Holidays group, as long as they use your personal information for the same purposes we did
g.And other members of Comfortable Holidays 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.
If you would like more information about this practice, and to know your choices about not having this anonymous information used by our third party service provider, please email at customercare.comfortable@gmail.com
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
For EU residents, when we, or our permitted third parties, transfer your personal data outside the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. If we transfer your personal data outside the EEA in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
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.
Please contact us on customercare.comfortable@gmail.com to obtain names and addresses of the specific entities that shall have access to your personal information in a given transaction.
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 Comfortable Holidays account with anyone. If we receive instructions using your username and password, 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.
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 – h.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 Comfortable Holidays 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, in such cases we will ensure that you are notified about the same without undue delay.
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 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 should 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 customercare.comfortable@gmail.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.
This Cookie Notice is part of Comfortable Holidays’s Privacy policy. For more information about Comfortable Holidays, and how it protects your information, please see the Privacy policy.
In order to provide you with a more personalized and responsive service, Comfortable Holidays 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.
Whenever you use this Website, information may be collected through the use of cookies and other technologies. By using this Website you agree to Comfortable Holidays’ use of cookies as described in this Cookie Notice.
What cookies do Comfortable Holidays use and why?
Some of the cookies Comfortable Holidays 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 Comfortable Holidays use the said cookies, you may at your wish stop using the Comfortable Holidays Website.
Comfortable Holidays 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.
Comfortable Holidays or its service providers also use analytic services to understand how effective Comfortable Holidays content is, what interests Comfortable Holidays users have, and to improve how this Website works. In addition, Comfortable Holidays 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 Comfortable Holidays's intention to use such information to personally identify any user. However, if you have registered and signed into this Website, Comfortable Holidays 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 Comfortable Holidays can place cookies on your computer or device as explained above. However, you can control and manage cookies in various ways. 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.
Managing Analytics cookies
Comfortable Holidays use the following service providers and you can learn more about their privacy policies by clicking on following links:
Adobe: https://www.adobe.com/privacy.html
Google Analytics: https://www.google.com/analytics/learn/privacy.html
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. Some parts of this Website use 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.
You may also reach out to customercare.comfortable@gmail.com to get more information on how to opt-out of the above cookies.
External web services
Comfortable Holidays sometimes use 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, Comfortable Holidays cannot prevent these sites or external domains, from collecting information on your use of this embedded content.
Email Communications
Comfortable Holidays may also use tracking technologies to determine whether you have read, clicked on, or forwarded certain email communications which Comfortable Holidays sends to you, to make its communications more helpful and interesting. If you do not wish Comfortable Holidays to confirm whether you have opened, clicked or forwarded its communications, you will need to unsubscribe, as it is not possible for Comfortable Holidays to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by contacting Comfortable Holidays, or can unsubscribe following the instructions in the individual email communications you receive from Comfortable Holidays.
Comfortable Holidays may modify or amend this Cookie Notice from time to time at its discretion. When Comfortable Holidays 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. Comfortable Holidays encourages you to periodically review this Cookie Notice to be informed about how it is using cookies.
