Adani Digital Labs Private Limited and its affiliates (collectively, “Adani Digital”, “we” or “us”) are engaged in the business of providing web/application based solutions to facilitate connections between customers that seek specific services. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or otherwise interact with our website available at https://www.adanione.com/ or mobile application ‘Adani One’ or avail products or services that Adani Digital Labs offers you on or through the Platform (collectively, the “Services”).
In this Policy, the services offered to you through the Platform are referred to as “Digital Services”. At Adani Digital Labs, we are committed to protecting your personal data and respecting your privacy. To provide you with services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you. Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://adanione.com/terms (“Terms”).
We do collect your personal information and process your personal data in accordance with the IT Act, 2000 (21 of 2000) and other national and state laws which relate the processing of personal data.
Please read this Policy in consonance with the Terms. By using the Services, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.
1. DEFINITIONS AND KEY CONCEPTS
Personal information, including sensitive personal information and special category personal data (as defined under Data Protection Laws) about you, which we collect, receive, or otherwise process in connection with your use of our website/App and/or the Platform.
A small file placed on your device by our website/App or the Platform when you either visit or use certain features of our website/App or the Platform. A cookie generally allows a website or mobile application to remember your actions or preference for a certain period of time.
Data Protection Laws
Any applicable law for the time being in force relating to the processing of Data.
Select third parties (including Adani Group Entities) with whom we have contracts for the businesses described in this Privacy Notice.
Includes entities which provide services to Adani Digital Labs and to whom we may disclose your Data for a specific purpose pursuant to a written contract.
Adani Digital Labs
Adani Digital Labs, a company incorporated in India whose registered office is at Adani Corporate House, Shantigram, Near Vaishno Devi Circle, SG Highway, Khodiyar, Ahmedabad, GJ 382421, IN.
Adani Group Entity
Adani Enterprises Limited, and its subsidiaries, affiliates, associate companies and joint venture companies.
User or you
The natural person who accesses or use the Services through our website/App or the Platform.
Adani Digital Labs' status as controller or processor
Adani Digital Labs' business involves:
- A state-of-the-art digital point of sale and inventory management system for its users for providing solutions for creating and operating an online storefront enabling booking, purchase, and delivery of goods and services to Users; and creation of a digital ecosystem including single window access for Users, a convenient and secure way to make payments, and loyalty benefits as well as extension of retail benefits and preferential rates.
- Operating loyalty programmes and benefits (either our own or on behalf of Adani Group Entities), in which case we either use your Data for our own purposes (where we are operating the loyalty programme and offering it to you directly) or on behalf of the relevant Adani Group Entities (where we are operating the loyalty program on behalf of Adani Group Entities).
For the purposes of certain applicable Data Protection Laws, we will act as a "controller" when we use your Data for our own purposes and a "processor" when we use your Data for and under the instructions of a Group Entity and other participating entities.
2. WHAT DATA DO WE COLLECT ABOUT YOU
Adani Digital Labs collects Data for various purposes set out in this Privacy Notice.
This Data includes, without limitation, the following categories:
- Personal information : First and last name, email address, postal address, country, phone number, Profile picture and other similar contact data.
- Financial information : Payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data. It is clarified that we do not store any of your card details i.e., credit and debit card in our application or website.
- Technical information : Website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
- Product and service information : Your website/App or Platform account membership number, registration information, and program-specific information, when you request products and/or services directly from us or participate in marketing programs.
- Your reviews, feedback and opinions about our products, programmes, and services.
- Loyalty programme information : Your loyalty membership information, account details, profile or password details and any frequent flyer or travel partner programme affiliation.
- Transaction information : Date of the transaction, transaction amount, transaction history and related details.
- Other information :Age, sex, date of birth, marital status, nationality, occupation or any other personal information provided by you.
3. HOW WE COLLECT DATA
We collect Data in the following ways:
- Information You Give Us : We receive and store any information you enter on our website, app or the Platform or give us in any other way. Please see the section below, titled “Data Shared by You” for more information.
- Automatic Information We Collect : We use “cookies”, pixels and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled “Data That is Collected Automatically” for more information.
- E-mail Communications : We often receive a confirmation (if your device supports such capabilities) when you open e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
- Automatic Information We Collect from Other Websites: We receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement.
- Information from Other Sources : We may obtain information from other sources. An example where we receive your Data from Adani Group Entities in connection with the Platform for the purposes of enrolment, offering you products, services, and benefits on the Platform.
- Information Previously Provided to Adani Group Entities : Where you have shared any information previously with any of the Group Entities and such Group Entity is permitted to further share such information, it will share such information with us. If such information is sensitive personal information or special category personal data, the Group Entity will only share such information with us with your consent. Regardless of the terms on which you had originally provided the information to a Group Entity, you acknowledge that: (a) we will collect such information from such Group Entity for the purposes set out in this Privacy Notice; (b) the Group Entity that provides such information to us is subject to its own compliance obligations under the Data Protection Laws, and (c) we are not responsible for any acts or omissions of such Group Entity in relation to any such compliance obligations under the Data Protection Laws.
- We automatically collect purchase or content use history, which we sometimes aggregate with similar information from other customers to create features such as Best Seller, Top Rated, etc.
- The information about usage of the App, including crash logs and usage statistics.
- Information about the location of your device, including geolocation information for the purpose of proving you service which requires processing of such information.
- By using our App, you are agreeing that We may advertise your feedback on the App/ website and marketing materials.
- We will retain your information as long as we require this to provide you with the goods and services and for such period as mandated by the concerned laws.
You can make choices about our collection and use of your Data. For example, you may want to access, edit, or remove your Data on our website/App or the Platform. When you are asked to provide Data, you may decline. For more information, please see the section below, titled “Your Rights and Choices”.
4. DATA SHARED BY YOU
We may collect your Data in several ways from your use of our website/App or the Platform. For instance:
- when you register with us to receive our products and/or services.
- when you conduct a transaction or attempt a transaction on our website/App or Platform.
- when you complete surveys conducted by or for us.
- when you elect to receive any communications (including promotional offers) from us.
- from the information gathered by your visit to our website or the Adani Digital Platform.
- Do not provide personal data about others unless you are authorised or required to do so by contract or applicable law.
5. DATA WE RECEIVED FORM OTHER SOURCES
We may receive personal data about you from other sources, ADL’s affiliate, a person, or company/organisation authorised by you to submit an application on your behalf, and/or publicly available sources. We’ll contact you to let you know we are processing your personal information.
6. DATA THAT IS COLLECTED AUTOMATICALLY:
- We automatically collect some information when you visit our website/App or the Platform. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
- Our web servers or affiliates who provide analytics and performance enhancement services collect IP addresses, operating system details, browsing details, device details and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. We use this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of our website/App or the Platform.
- We may collect your Data automatically via Cookies, pixels and similar technologies in line with settings on your browser. For more information about Cookies, please see the section below, titled “Cookies, Pixels and Similar Technologies”.
7. OUR USE OF DATA
We use the information collected through this App, as described in this policy and we may use your information to:
- Improve our services, App and how we operate our businesses.
- Understand and enhance your experience using our App, products, and services.
- Personalise our products or services and make recommendations.
- Provide and deliver products and services you request.
- Process, manage, complete, and account for transactions.
- Provide customer support and respond to your requests, comments, and enquiries.
- Create and manage the online accounts you manage on our App.
- Send you related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages.
- We may process your personal information without your knowledge or consent where required by applicable law or regulation for the purposes of verification of identity or for prevention, detection, or investigation, including of cyber incidents, prosecution, and punishment of offences.
- Protect, investigate, and deter against fraudulent, unauthorised, or illegal activity.
- Protecting against, and preventing, fraud, illegal activity, harm, financial loss and other legal or information security risks.
- Providing marketing and promotional campaigns to you based on your profile;
- In connection with loyalty programs owned and operated by us or by other Group Entities; and
- Create a user profile based on data provided by you on using of the application.
Where processing your Data is necessary for us to carry out our obligations arising from any contracts entered into between you and us :If you enter into a contract with us in relation to any of our product or service offerings, including products or service offerings we offer to you directly on the Platform, we may process certain Data about you in order to perform our obligations under this contract, including to enable us to communicate with you about such products and/or services and to process your payment transactions.
Where processing your personal information is within our legitimate interests :We can process certain Data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of yours which require protection of your Data.
Where you give us your opt-in consent to process your personal information :In certain circumstances, where required under relevant Data Protection Laws, we will seek to obtain your consent before we undertake certain processing activities with your Data.
Where required under relevant Data Protection Laws(e.g., under direct marketing legislation), we will obtain your opt-in consent prior to sharing your Data with third parties and carrying out certain marketing activities (unless we are permitted by relevant Data Protection Laws to contact you without your opt-in consent in relation to goods and services which are similar to those which you have already purchased, used or interacted with).
You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in the section below, titled "Your Rights and Choices".
Where processing your personal information is necessary for our compliance with a legal obligation : In certain circumstances, we may disclose your Data for the purposes of compliance with a legal obligation (for example, to comply with a law, regulation or compulsory legal request). We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see the section below, titled "Your Rights and Choices".
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Data.
Further, where required under relevant Data Protection Laws, we will only process special category personal data’ (as defined under Data Protection Laws) if there is a valid legal basis, which might involve obtaining your explicit consent.
Where we use or share or otherwise process your Data as a processor on behalf of a Group Entity or other participating entity (i.e., the controller) for the purposes of offering you access to Third Party Applications on the Platform or as part of any services that we provide to that entity, we do so under the instructions of that entity and that entity is responsible for ensuring that there is a legal basis for us to use or share your Data on its behalf (if such legal basis is required under relevant Data Protection Laws).
8. PERMISSIBLE AGE
a. The Services are not intended for users under the age of 18, unless permitted under applicable local laws (Permissible Age) or under the involvement of a parent or guardian. We do not knowingly collect any personal information from users 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 a user under the Permissible Age, please contact us at email@example.com
b. This Website is not directed at children under the age of 18 and ADL cannot distinguish the age of persons who access and use our website. If a minor (according to applicable laws) has provided ADL with Customer Data without parental or guardian consent, the parent or guardian should contact ADL (see Section 20) to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account.
9. SHARING OF DATA
We may share your Data in the following ways (and for the purposes of relevant Data Protection Laws, we may do so either as a controller in our own right or as a processor on behalf of and under the instructions of another entity in accordance with our obligations under our agreement with that entity):
- We share your data with your consent or to complete any transaction or provide any product or service you have requested or authorised. We also share data with our affiliates and subsidiaries, with vendors working on our behalf.
- We may employ other companies and individuals to perform function(s) on our behalf. The functions include fulfilling orders for products or services, delivering packages, sending e-mail, removing repetitive information from customer lists, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, scoring credit risk, and providing customer service.
- Business Transfers : As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data (including in relation to loyalty programs) may be transferred as part of such transactions.
- Protecting Adani Digital Labs: We may release Data when we believe that disclosure is reasonably necessary (a) to comply with a law, regulation or compulsory legal request; (b) to protect Adani Digital Labs or a Adani Group Entity's intellectual property rights; (c) to protect Adani Digital Labs against harm or financial loss; (d) when we believe disclosure is necessary to protect individuals’ vital interests, or (e) in connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other companies and organizations for fraud protection, risk management and dispute resolution.
- Third Parties :We may also share your Data with other third parties where:
- You request or authorise us to do so;
- We need to comply with applicable law or respond to valid legal process; or
- We need to operate and maintain the security of our website/App or Platform, including to prevent or stop an attack on our computer systems or networks.
10. DATA SECURITY
We will use technical and organisational measures to safeguard your Data. We store your Data on secure servers. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us through e-mail at firstname.lastname@example.org.
The security of your Platform account depends on you keeping your account password(s), PINs and other access information confidential. If you share your Platform account information with a third party, they will have access to your account and your Data.
It is your responsibility to control access to your mobile device and the Platform on your device, including keeping your password(s) and/or PIN confidential and not sharing it with anyone. It is also your responsibility to alert us if you believe that the security of your Data in the Platform has been compromised.
11. ANALYTICS AND TAILORED ADVERTISING
To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics etc. These service providers use the sort of technology described in the "Automatically-Collected Information" Section above. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate our users' use of the Services. We also use Google Analytics as described in the following section. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser add-on.
- Inform, optimise, and serve ads based on past visits to our website and other sites and
When accessing the Services from a mobile application you may also receive tailored in-application advertisements. Each operating system: iOS, Android and Windows Phone provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.
12. RETENTION OF DATA
We retain Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website/App or the Platform, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your Data is necessary for our legitimate interests. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.
Even if we delete your Data, including on account of exercise of your right under Clause 13 below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.
13. WHERE WE STORE DATA
If the GDPR/United Kingdom’s version of the GDPR applies to our processing of your Data, we will only process and/or transfer Data outside of the European Economic Area/United Kingdom where it is compliant with Data Protection Laws and the means of transfer provides adequate safeguards in relation to your Data, including for example:
- By way of a data transfer agreement incorporating the current relevant standard contractual clauses adopted in the European Economic Area/United Kingdom; or
- By transferring your Data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
- Where it is necessary for the conclusion or performance of a contract between us and a third party and the transfer is in your interests for the purposes of that contract; or where derogations are provided as per GDPR and/or UK GDPR.
14. YOUR RIGHTS AND CHOICES
Depending on which country’s laws are applicable to you, you may have various rights in relation to the Data that we hold about you. To get in touch with us about any of your rights under Data Protection Laws, please use the contact details set in the section below, titled “How to Contact Us”. We will seek to deal with your request without undue delay, and in any event, within any time limits provided for in Data Protection Laws (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. Where we are legally permitted to do so, we may refuse your request.
You may be entitled to the following rights in relation to your Data, i.e. Data Subject Rights (DSR):
- Right to Confirmation and Access - You may ask us to confirm what Data we hold about you at any time. You may also request a copy of the Data we hold about you by following the process as provided under clause 20 below. Additionally, data subject can seek other information related to the processing of their data.
- Right to Rectification - You have the right to request that we rectify any inaccurate or incomplete Data that we hold about you and/or right to get the Data updated or corrected, including by means of providing a supplementary statement.
- Right to be Erasure - You have the right to request that we "erase" your Data in certain circumstances.
- Right to Restrict Our Use of your Data - You have the right to request that we restrict our processing of your Data in certain circumstances, for example if you dispute the accuracy of the Data that we hold about you or you object to our processing of your Data (including where we process your Data for our legitimate interests, where permitted under applicable law).
- Right to Object – This right enables you to object to us processing your Data where we do so for certain lawful bases like our legitimate interest.
- Right to Data Portability - You have the right to request that we transfer your Data to another third party and with you in a structured, commonly used and machine-readable format. This right of data portability only applies to certain types of Data.
- Right to Withdraw Consent – Where we have obtained your consent to process your Data for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative and strong compelling legal basis to justify our continued processing of your Data for this purpose.
- Right to File Complaints – You have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.
To get in touch with us about these rights, or for more information about managing your Data and promotional communications, please use the contact details set out in the section below, titled “How to Contact Us”.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.
15. PROCESSING YOUR DATA
We take steps to ensure that your Data is processed according to the provisions of this Privacy Notice and the requirements of applicable law.
17. LINKS TO THIRD PARTY SITE/APPS
- Keeping track of items stored in your shopping basket.
- Conducting research and diagnostics to improve the content, products, and services.
- Preventing fraudulent activity.
- Improving security.
- Our cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you will not be able to add items to your shopping basket, proceed to checkout, or use any products or services that require you to sign in.
- Approved third parties also may set cookies when you interact with Our services.
- Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies.
- You can prevent the storage of cookies by choosing a "disable cookies" option in your device settings. But this can limit the functionality of our services.
19. PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS
When Adani One app is installed on your phone or tablet, a list of permissions appears and are needed for the app to function effectively as and when the services are available and such permissions are required. There is no option to customise the list. The permissions that Adani One requires and the data that shall be accessed and its use is as below:
Device & App history : We need your device permission to get information about your device, like OS (operating system) name, OS version, mobile network, hardware model, unique device identifier, preferred language, etc. Basis these inputs, we intend to optimise your travel booking experience, use OS specific capabilities to drive great in-funnel experiences using components of device’s OS, etc.
Camera : This permission enables you to use your camera from within the application to upload a new profile picture.
Identity : This permission enables us to know about details of your account(s) on your mobile device. We use this info to auto-fill your email IDs and provide a typing free in-funnel experience. It helps us map email IDs to a particular user to give you the benefit of exclusive travel offers, wallet cash-backs, etc.
Location : This permission enables us to give you the benefit of location specific deals and provide you a personalised in-funnel experience. When you launch Adani One app to make a travel booking, we auto-detect your location so that your nearest airport or city is auto-filled. Your options are personalised basis your locations. For international travel, this enables us to determine your time zone and provide information accordingly.
SMS : If you allow us to access your SMS, we read your SMS to auto-fill or prepopulate ‘OTP’ while making a transaction and to validate your mobile number. This provides you a seamless purchase experience while making a booking and you don’t need to move out of the app to read the SMS and then enter it in the app.
Photo/Media/Files : The libraries in the app use these permissions to allow map data to be saved to your phone's external storage, like SD cards. By saving map data locally, your phone doesn't need to re-download the same map data every time you use the app. This provides you a seamless map based selection experience, even on low bandwidth network.
Wi-Fi connection information : When you allow us the permission to detect your Wi-Fi connection, we optimise your experience such as more detailing on maps, better image loading, more service and products options to choose from, etc.
Device ID & Call information : This permission is used to detect your Android ID through which we can uniquely identify users. It also lets us know your contact details using which we pre-populate specific fields to ensure a seamless booking experience.
Calendar : This permission enables us to put your travel plan on your calendar.
Bluetooth : This permission enables us to provide you services of the third parties that make available certain features of their products/services on our application. The permission specifically enables our third-party service providers whose services you book on the application to permit you to lock and unlock your self-driven vehicles seamlessly.
Phone Number : We need the permission of access to phone number to provide a seamless login experience, to optimise your travel booking experience and to enable you to obtain UPI services and to prevent fraud in some cases on our application
IMEI/IMSI : This permission enables us to identifying different users uniquely and helps us to prevent frauds on our application.
iOS Permissions :
Notifications : If you opt in for notifications, it enables us to send across exclusive deals, promotional offers, travel related updates, etc. on your device. If you do not opt for this, updates for your travel like PNR status, booking confirmation, refund (in case of cancellation), etc., will be sent through SMS.
Contacts : If you opt in for contacts permission, it enables us to provide a lot of social features to you such as sharing your travel journey with your friends, inviting your friends to try our app, send across referral links to your friends, etc.
Location : This permission enables us to give you the benefit of location specific deals and provide you a personalised in-funnel experience. When you launch our app to make a travel booking, we auto-detect your location so that your nearest Airport or City is auto-filled. We require this permission to recommend you nearest available cabs in case you are running late and want to make a quick last-minute booking for a cab. Your options are personalised basis your locations. For international travel, this enables us to determine your time zone and provide information accordingly.
20. CHANGES TO THIS POLICY
We may change this policy from time to time. If we make any changes to this policy, we will change the "Last Updated" date above. You agree that your continued use of our services after such changes have been published to our services will constitute your acceptance of such revised policy. we will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.
21. HOW TO CONTACT US
22. GRIEVANCE OFFICER
Please find below the details of the grievance officer:
Name: Aditya Khullar
Email Id : email@example.com
The grievance officer is identified above pursuant to the provisions of applicable laws including but not limited to the information Technology Act, 2000 and the Consumer Protection Act, 2019 and the rules enacted under those laws.
2. If you are an existing customer of ours, further details about how we use your personal data are set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided when we collect personal data from you.
3. Our websites/Platform may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.
- What personal data about you may we collect?
- How may we use your personal data?
- Who may we share your personal data with?
- How we protect your personal data?
- Contacting us and your rights to prevent marketing and to access and update your personal data?
1. Information we may collect about you
- We will collect and process all or some of the following personal data about you:
- Information you provide to us : Personal data that you provide to us, such as when using the contact form on our website or mobile app, including your name, email address, etc.
- Advanced Passenger Information (API) :Including your passport, Visa and travel information, date of birth, gender and nationality.
- Health data : Relating to passengers, in order to meet your requirements in flight (e.g., to respond to particular health risks or to understand allergies, etc.) and also to provide special assistance, for example wheelchair access assistance;
- Payment information : Including payment type, information relating to the manner/method of payment, card information (for your security, we do not retain your CVV number, we simply use this to authenticate your card) and where relevant, the name of your bank);
- Our correspondence : If you contact us, we will typically keep a record of that correspondence;
- Survey information : We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
- Your transactions : If you have purchased any services through our website or platform, details of related transaction details and of the fulfilment of the services we provide.
- Website and communication usage : Details of your visits to the websites and information collected on our website including cookies and other tracking technologies including, but not limited to, your IP address and domain name, geographical location, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
- Certain personal data (particularly details of your travel documentation, payment details and contact information) are required in order for us to supply our products and services and if you fail to supply such personal data as requested for specific services, we may be unable to deliver you the products and services in full.
- We may receive personal data from
- Global Distribution Systems :For example, where you have made a booking using a flight comparison website.
- Online travel agents :Where you have made a booking using a third-party agency; or
- Travel management companies :Where you (or your employer or company on your behalf) have booked corporate travel through a third-party agency.
- The data received from these organisations will be limited to that described at section 2.1 above and we will not use it for any other purpose other than those described.
2. USES MADE OF YOUR PERSONAL DATA
- In this section, we set out the purposes for which we use your personal data and, in compliance with our obligations under European law, identify the lawful bases we rely on in order to process the information.
- These “legal grounds” are set out in the relevant data protection law applicable to the EEA and the UK, which allows companies to process personal data only when the processing is permitted by the specific “legal grounds” set out in law.
- Please note that in addition to the disclosures we have identified below, we may disclose personal data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g., legal, financial, business or other advisors) and affiliates of ADL that perform activities on our behalf, as well as other members of the Adani Group.
- To communicate effectively with you and conduct our business : To conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us; Legal bases : Contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you).
- For research and development purposes : To analyse your personal data in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services; Legal bases : Legitimate interests (to allow us to improve our services).
- To monitor certain activities : To monitor queries and transactions to ensure service quality, compliance with procedures and to combat criminal activity; Legal bases : Legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services
- To inform you of changes : To notify you about changes to our services and products; Legal bases : Legitimate interests (to notify you about changes to our service).
- To ensure website content is relevant : To ensure that content from our websites/Platform is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers; Legal bases : Legitimate interests (to allow us to provide you with the content and services on the websites).
- Strong in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal data to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy; Legal bases : Legitimate interests (in order to allow us to change our business).
- In connection with legal or regulatory obligations : We may process your personal data to comply with our regulatory requirements or discourse with regulators as applicable which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. Legal bases : Legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).
- Understanding your health requirements : To ensure that you are safe on flights and to manage any particular requirements for example, allergies. Legal bases :Explicit consent
3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
- In addition, we may disclose information about you to counterparties, customs and immigration authorities, other government bodies, regulators and law enforcement agencies where required by law, in connection with any legal proceedings or prospective legal proceedings, or to establish, exercise or defend our legal rights including providing information to others for the purposes of crime detection and prevention.
4. STORAGE AND SECURITY OF YOUR PERSONAL DATA
- No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements.
- All information you provide to us is stored on our or our subcontractors’ secure servers in on outside of the EEA or the UK (i.e., India only) and accessed and used subject to our security policies and standards.
- Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
- Protecting Adani Digital Labs: We may share your Data when we believe that disclosure is reasonably necessary (a) To comply with a law, regulation or compulsory legal request; (b) To protect Adani Digital Labs or a Adani Group Entity's intellectual property rights; (c) To protect Adani Digital Labs against harm or financial loss; (d) When we believe disclosure is necessary to protect individuals’ vital interests, or (e) In connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other companies and organisations for fraud protection, risk management and dispute resolution.
5. PROCESSING OUTSIDE THE EEA AND THE UK
- Where your personal data is transferred from an entity inside the European Economic Area (the EEA) or the UK (as the case may be) to outside the EEA or the UK (as the case may be), we may be required to take specific additional measures to safeguard the relevant personal data. Where we transfer your personal data, we will establish legal grounds justifying such transfer, or otherwise to ensure the appropriate security of your personal data.
- Storage limits : Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data.
6. YOUR RIGHTS & CONTACTING US
You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. Where you do not wish to receive marketing from us, you can decline or withdraw your consent at any time, either by choosing not to select the relevant check boxes on our subscription form, by clicking the unsubscribe link in any marketing message received from us, or by contacting us here.
We will use reasonable endeavors to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by contacting us as set out in the “Contacting Us” section below. Please note that it is your responsibility to ensure that your booking information or flight itinerary is accurate.
If you have any questions in relation to our use of your personal data, you should first contact us as per the “Contacting Us” section below. Under certain conditions, you may have the right to require us to:
- Provide you with further details on the use we make of your information;
- Provide you with a copy of information that you have provided to us;
- Update any inaccuracies in the personal data we hold;
- Delete any personal data that we no longer have a lawful ground to use;
- Where processing is based on consent, to withdraw your consent so that we stop that particular processing. Please note that in relation to health information, this will prevent us from reacting to any health condition you may have;
- To ask us to transmit the personal data you have provided to us and we still hold about you to a third party electronically;
- Object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- Restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within 90 days from the date of receipt of any such request.
If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the relevant data protection authority.
If you have any questions in relation to this policy, please contact us at firstname.lastname@example.org