- Purchases and/or intend to purchase and/or inquire about any products of the Company (“Products”) and / or any services of the Company (“Services”).
- Purchases any service(s) made available by us through any of our customer interface channels including without limitation Website and through our offline channels such as but not limited to call centers, offices, agents and franchisees (collectively referred hereinafter as “Offline Sales Channels”).
Who We Are, Policy, Updates And Other Important Information
We are IsleWalk, a company incorporated in Andaman & Nicobar Island and have our registered office address at Lamba Line (water Treatment Plant).For the purpose of applicable data protection laws, we are the “Data Controller” of all Personal Data that we collect, use and otherwise process about you, through –
- Online sales channels
- Offline sales channels
- Our social media pages that we control (hereinafter referred as “social media pages”)
- Email messages, SMS, notifications, alerts etc that we send you from time to time.
- Offline interactions
What Information Do We Collect About You
The type of information we collect about you are as following:
- “Personal Data” is that information and / or data which identify you as an individual or relate to a particular individual. Depending on the circumstances, we collect any of the following –
- Details about you such as but not limited to your name, gender, address, contact number, email address, date and place of birth, nationality, religion, PAN card details, Aadhar details, choice of veg / non-veg food, information about your health to the extent that it’s relevant to your fitness to receive our services, your holiday itinerary or to provide you with special assistance.
- Credit and debit card number, Bank Account details, net banking details, cheque details or any other payment related information / data.
- Financial and tax information in limited circumstances.
- Information related to your transactions on the website which including the date and time, the amounts charged and other related transaction details.
- Language preference.
- Identification documents/information such as but not limited to your passport or identity card details (including your passport number, the country in which your passport was issued and the expiry date), visa or other government-issued identification data.
- Important dates, such as birthdays, anniversaries and special occasions of self and family members.
- Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations) Your Employer details.
- Your travel details, tour group or activity data including details of your travel itinerary such as where you are flying from and to, your booking information, any onward travel details if relevant, details of experiences or excursions booked through us, your baggage requirements, any upgrade information, your lounge visits, seat preferences, meal preferences or requirements, details of any special assistance you might need from us and any other information relevant to enable us to provide you with the travel or other services that you’ve arranged with us.
- Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us or when you purchase goods and services, special service and / or make any other amenity requests.
- Information related to your Geographic location and IP address.
- Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts.
- In more limited circumstances, we also collect:
- Data about family members (including children) and companions, such as name(s), age, birthdays, anniversaries etc.
- Biometric data, such as digital images.
- Images and video and audio data via: (a) security cameras located in public areas, such as hallways, lobbies, grounds etc, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel.
- Guest preferences and personalized data (“Personal Preferences”), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit.
- “Other Data” is that information and / or data which does not identify you as an individual or relate to any particular individual such as but not limited to – (i) Browser and device data (ii) Data collected through Cookies, pixel tags and other technologies (iii) Demographic data and other data provided by you (iv) Aggregated data. However, in case any Other Data identify you as an individual or relate to any particular individual, then we will treat such Other Data as Personal Data.
What Are Sensitive Data
- Personal data which concerns your health or which reveals your data related to your social security numbers, any national identification number, racial or ethnic origin, political opinions, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, administrative or criminal proceedings and sanctions, your sexual orientation are Sensitive Data.
- Processing of Sensitive Data requires your explicit consent. Accordingly, information concerning any disability, medical condition or restricted mobility which may affect your travel arrangements (and related requirements) as well as dietary restrictions which may disclose your religious beliefs are Sensitive Data. We will ask for your consent to our processing this Sensitive Data at the time you make your booking or your booking enquiry.
How We Collect Your Information
Depending upon circumstances, we collect Personal Data and Other Data (collectively referred as “Information”) in various ways- Online Sales Channels. We collect Information when you-
- Browse our Online Sales Channels or mobile website
- Book or search for any Product or other services via our Online Sales Channels
- Fill in a portion of the booking form on our Online Sales Channels whether you submit or do not submit the complete or partly complete booking form.
- Communicate with us, or otherwise connect with us or ‘follow’, ‘like’, post to social media accounts/social media pages including without limitation at including Facebook, LinkedIn, Twitter, Pinterest, Instagram and YouTube.
- Sign up for any newsletter, promotional materials or participate in any activity, survey, contest or promotional offer.
Offline Sales Channels. We collect Information through our Offline Sales Channel as following-
- When you fill in the booking form in part or in whole.
- When you make a reservation over the phone, communicate with us by email or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance, training.
- We collect Information from other sources, such as but not limited to suppliers providing public databases, joint marketing partners and other third parties.
- We collect Information from internet-connected devices available in our Office premises, or at the Franchisee stores.
- We collect Information when you choose to participate in any programs. In such situation we collect your device’s precise physical location through satellite, your network tower, WiFi signals etc. We collect this data when you access our Online Sales Channels to enable location-driven capabilities on your mobile device. We will continue to collect location data until you log off or close the Online Sales Channels.
- We collect certain Information from Cookies.
How We Use Your Information
We’ll use your information for various purposes to render services to you as per our contract and hence usage of some Information will depend on the type services for which you have engaged us. Under some circumstance we might require you to share the Information directly with us. In case you fail to provide such Information to us or prohibit us from collecting such information, then we might not be able to render you with your requested Product or services under the contract. We use all such Information for our genuine business purpose to render appropriate services, which includes the following-
- To Render You with Booked Products / Services.We use Information to render any services or Products that you had booked with us. This includes without limitation your flight tickets, rail tickets, cruise, accommodations, arranging a tour, transportation or car hire and providing you with any special assistance with your prior consent such as but not limited to assistance for obtaining visa, insurance etc. We will also use the Information to facilitate your reservations, payments, confirmations or pre-arrival messages, to assist you Other Data about the destination that you are scheduled to visit.
- To optimise our Online Sales Channels. We will use your information to (i) ensure that the content from our Online Sales Channels are made accessible to you in a manner that is effective, convenient and optimal, and (ii) to share with you relevant contents using site analytics and research.
- To protect and safeguard the Company. To protect, safeguard, investigate and prevent any fraudulent, unauthorized or illegal activity, terrorism and other types of unlawful conduct.
- To Comply with our Policies, Procedures and other Business Purposes. We will use your Information so as to enable us complying with various policies, procedures and legal obligations, to enforce our legal rights, and to protect the rights, interests, property and safety of our staffs, customers and us as well. This may include sharing your information with our lawyers, technical advisors, law enforcement and other regulatory bodies where necessary (on the basis of our legitimate interests or to comply with a legal obligation). We also use Information for various data analysis, audits, security and fraud monitoring and prevention, developing new services, improving our existing Services and determining the effectiveness of our promotional campaigns.
With Whom Do We Share/Disclose Your Information:
In order to ensure that you are provided with the best services in furtherance of our contract, we may have to share your Information with the parties set out below
- Affiliate and Group Companies. From time to time we might disclose your Information with our affiliate and group Companies for various reasons such as but not limited to – (i) to ensure proper Services are rendered to you, (ii) communicating with you, (iii) facilitating the loyalty programs if any, (iii) to accomplish our business purposes, (iv)to carry out statistical analysis, (v) market research, business/knowledge process outsourcing (such as call centres) etc.
- Third Party Service Providers, Concerned Bodies and Authorities. You are aware that your tour may comprise of services rendered by several Third Party Service Providers. Hence, we will disclose your Information with these Third Party Service Providers to ensure they provide you with appropriate services.
- Business Partners and other Suppliers. On a need to know basis, we share your information with various vendors and third party suppliers that render us services in connection with our business including without limitation: (i) marketing agencies and/or companies that run our marketing campaigns, (ii) IT developers and other software companies, (iii) business / knowledge process outsourcing companies (such as call centres) etc (iv)third parties that manage promotions or competitions that we may run, (v) third Parties whose services/applications are procured by us on a white label basis, (vi) networks, ground handlers, destination management companies, site analytics providers, medical service providers, financial institutes and banks.
- Regulators and Governmental Bodies. We will share your information with regulators, governmental bodies and other authorities etc for various reasons including without limitation- (a) to comply with any applicable laws; (b) to comply with any legal process including defending our company and/or you from 3rd party claim; (c) to respond to any orders, instructions or requests received from any public and government bodies and authorities (d) to ensure that our terms and conditions are complied with; (e) to protect the rights, interest, privacy, safety of the Company.
How Do We Protect Your Information
- We take appropriate technical and organizational measures to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the Information to be protected, having regard to the state of technological development and the cost of implementing any measures.
- In order to protect your Information against any unauthorised access or any unlawful use, we use various technical and operational security measures such as but not limited to:
- Limiting access to your Information to those employees, agents, franchisees, contractors, Third Party Service Providers and other third parties, who have a business need to know.
- Ensuring the physical security of our offices and Franchisee stores and further ensuring digital and physical security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions.
- Implementing processes (such as password hashing, login auditing, and idle session termination) to protect against unauthorized access to your Information.
- Maintaining internal policies and deliver data protection and confidentiality training to our employees to ensure they understand their responsibilities towards protecting and safeguarding your Information and if required take appropriate measures to enforce these responsibilities.