Last updated on March 18, 2020

This privacy policy is for whatsplan.app by WHATSPLAN OPC PRIVATE LTD, and governs the privacy of its users who choose to use it.

WHATSPLAN, (hereafter referred as "Whatsplan" or "we"), respects its Customer's (hereafter referred as "you" or "user") privacy and values our relationship with our business partners, clients, third party (hereafter referred as "third party" or "service provider"), who have contractual relationship with Whatsplan and any party who purchase / intend to purchase / inquire about any product(s) and / or service(s) made available by Whatsplan through any of Whatsplan' 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 by which you can be identified (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 would like to assure you that we follow appropriate standards when it comes to protecting your privacy on our Sales Channels. 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.

By using or accessing the Website or other Sales Channels, the user hereby agrees with the terms of this Privacy Policy and the contents here in.

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 Whatsplan's business partners, advertisers, sponsors or other sites to which we 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.

1. What Personal Data We Collect?

a. We collect the following personal and sensitive information from you while transacting through us:

• Name, gender age and date of birth
• Contact information, such as address, email, and mobile phone number
• Country/State/City of residence
• Credit Card/Debit Card/Bank Account details
• Passport Number & frequent flyer number (wherever needed)
• Family details/information (for example, your marital status and dependents)
• Postings or messages on any blogs, forums, platforms, wikis or social media applications of Whatsplan and Whatsplan'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 (for example, so that we can make it easy for you to access our buildings, products and services, and/or for any special assistance required by you)
• Sexual orientation (for example, 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 or our client.

c. 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

Our Services are not intended for users under the age of 16 (Permissible age), unless permitted under applicable local laws or if submitted by the guardian. We do not knowingly collect any personal information from you or market to or 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 as soon as possible. If you believe we might have any information from or about you under the Permissible Age, please contact us at .

e. The other information that we collect

• Analytics: Google Analytics, Appsflyer, Facebook Ads conversion tracking, Google Tag Manager, Intent Media
• 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, subscribe to our newsletters and preference center, register for webinars, attend meetings or events we host, visit our offices. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.

b. Indirectly: We obtain personal data indirectly about individuals from a variety of sources, including but not limited to travel agents, other travel websites, social media, authorized representative when such person is seeking travel services information on others behalf and our clients. We may attach personal data to our customer relationship management records to better understand and serve you, 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, Facebook, Instagram, 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, email address and depending on your privacy settings, additional details about you. Hence, we recommend that, you review the privacy settings on the applicable service to set restrictions on what and how much information you wish 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 Whatsplan's client's 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 data subject or 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 We Use/Process Your Personal Data

We assure to you that we do not sell or trade upon any of the above foregoing information without your consent.

a. 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 are usually collected directly by the payment gateways and banks and not by Whatsplan, but if ever stored or retained by us, remain internal
• 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 no., 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 site. Cookies are identifiers which web sites send to the browser on your computer to facilitate your next visit to our site. 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. To learn more, please refer Annexure A: Cookie policy.

c. Android App Permissions required to use various features in our app:

In order to have a better experience and to use all features in the app, we need the following permissions to be used in our android 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 express permission. We will only use the contact information to help you find friends or contacts that use Whatsplan 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 express permission. 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
• SMS: This application reads, uploads and syntactic analyses 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
• GET ACCOUNTS: This permission enables us to know about details of your account(s) on your mobile device. This will help you to register on the Platform by logging into online accounts you may have with Third Party social networking sites (e.g. Facebook, Twitter, Instagram, Google Login)
• ACCESS_WIFI_STATE: By using Wi-Fi connection details, we provide you a seamless experience depending upon your network such as image loading process. 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 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 we use/process the personal data" section above, we may disclose details about you to:

a. Third parties that provide services

b. Competent authorities (including courts and authorities regulating us for internal compliance and audit(s))

c. Other organizations to whom we may transfer our rights and/or obligations under the Terms agreed between Whatsplan and the respective organization

d. Any other person or organization after a restructure, sale or acquisition of Whatsplan, as long as they use your personal information for the same purposes we did

e. Credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud

f. Other third parties that reasonably require access to personal data relating 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 most 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 .

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. Whatsplan shall not be liable for any information you contribute to these Social Media Applications that 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/States/Cities:

• Where we do business
• Which are linked to your engagement with us
• From which you regularly receive or transmit information
• 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 to obtain names and addresses of the specific entities that shall have access to your personal information in a given transaction.

7. How we protect 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 for your Whatsplan account with anyone. If we receive instructions using your user name and password, we will consider that you have authorized the instructions.

8. What Are Your Data Protection Rights?

Your data protection rights are highlighted here.

• Right to Access - You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
• Right to Correction - You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
• Right to Erasure - You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
• Right to Processing restrictions - You can 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.
• Right to Data portability - In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if it is technically feasible.
• Right to Automated Individual Decision-making - You can 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 similarly significantly affected you.
• Right to Object to Direct Marketing including Profiling - You can 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.
• Right to Withdraw Consent - You can 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 Whatsplan to not be able to provide certain products or services to you.

Check your User Profile Information available and stored with us under the section "My Profile". To get user profile deleted please send an email to - .

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/ when do we Dispose Your Personal Data?

We seek to ensure that we only keep your personal data for the longest of:

• the period necessary for the relevant activity or services
• any retention period that is required by law
• 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 assisting legal obligations, to 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. Any such changes made shall be published our 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 .

Annexure A: Cookie Notice

Our 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 Whatsplan's Privacy policy. For more information about Whatsplan, and how it protects your information, please see the Privacy policy.

In order to provide you with a more personalized and responsive service, Whatsplan needs to remember and store information about how you use our 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 our Website. Your web browser then sends these cookies back to the 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 our Website, information may be collected through the use of cookies and other technologies. By using our Website you agree to Whatsplan's use of cookies as described in this Cookie Notice.

What Cookies Do Whatsplan Use And Why?

Some of the cookies Whatsplan uses are necessary to enable you to move around the Website and use its features such as accessing secure areas that may contain content for registered users.

Whatsplan 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 anonymous and is not used for any other purpose.

Whatsplan or its service providers also use analytic services to understand how effective Whatsplan's content is, what interests Whatsplan's users have, and to improve how our Website works. In addition, Whatsplan uses web beacons or tracking pixels to count visitor numbers and performance cookies to track how many individual users access the Website and how often. This information is used for statistical purposes only and it is not Whatsplan's intention to use such information to personally identify any user. However, if you have registered and signed into our Website Whatsplan may combine this information with information from its web analytic services and cookies to analyses how you use this Website in more detail.

How To Control Cookies?

By using this Website you agree that Whatsplan 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 our 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 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

Whatsplan uses 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: 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 that may log information about your activities on the Internet including your activities on our 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 to get more information on how to opt-out of the above cookies.

External Web Services

Whatsplan sometimes uses external web services on its 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, Whatsplan cannot prevent these sites, or external domains, from collecting information on your use of this embedded content.

Email Communications

Whatsplan may also use tracking technologies to determine whether you have read, clicked on, or forwarded certain email communications which Whatsplan sends to you, to make its communications more helpful and interesting. If you do not wish Whatsplan to confirm whether you have opened, clicked on or forwarded its communications, you will need to unsubscribe, as it is not possible for Whatsplan to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by contacting Whatsplan, or can unsubscribe following the instructions in the individual email communications you receive from Whatsplan.

Whatsplan may modify or amend this Cookie Notice from time to time at its discretion. When Whatsplan makes 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 revision date. Whatsplan encourages you to periodically review this Cookie Notice to be informed about how it is using cookies.

Please contact Whatsplan through email: , if you would like more detailed information on the cookies that we use.

Data Privacy Representative for Whatsplan is: