English (IN)
Introduction
Lulu Holidays Private Limited (hereinafter “Lulu Holidays”) recognizes the importance of privacy of its users and also of maintaining confidentiality of the information provided by its users as a responsible data controller and data processer.
This Privacy Policy provides for the practices for handling and securing user's Personal Information (defined hereunder) by Lulu Holidays and its subsidiaries and affiliates.
This Privacy Policy is applicable to any person (‘User’) who purchase, intend to purchase, or inquire about any product(s) or service(s) made available by Lulu Holidays through any of Lulu Holidays’s customer interface channels including its website, mobile site & offline channels including call centers and offices (collectively referred herein as "Sales Channels").
For the purpose of this Privacy Policy, wherever the context so requires "you" or "your" shall mean User and the term "we", "us", "our" shall mean Lulu Holidays. For the purpose of this Privacy Policy, Website means the website(s) and mobile site(s).
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. If you disagree with this Privacy Policy please do not use or access our Website or other Sales Channels.
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 Lulu Holiday’s business partners, advertisers, sponsors or other sites to which Lulu Holidays 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 with whom they interact.
This Privacy Policy is an integral part of your User Agreement with Lulu Holidays and all capitalized terms used, but not otherwise defined herein, shall have the respective meanings as ascribed to them in the User Agreement.
Users outside the geographical limits of India
Please note that the data shared with Lulu Holidays shall be primarily processed in India and such other jurisdictions where a third party engaged by Lulu Holidays may process the data on Lulu Holidays’s behalf. By agreeing to this policy, you are providing Lulu Holidays with your explicit consent to process your personal information for the purpose(s) defined in this policy. The data protection regulations in India or such other jurisdictions mentioned above may differ from those of your country of residence.
If you have any concerns in the processing your data and wish to withdraw your consent, you may do so by writing to the following email id: support@myluluholidays.com. However, if such processing of data is essential for us to be able to provide service to you, then we may not be able to serve or confirm your bookings after your withdrawal of consent. For instance, if you want to book any international holiday package in fixed departures (group bookings), then certain personal information of yours like contact details, gender, dietary preferences, choice of room with smoking facility, any medical condition which may require specific attention or facility etc. may have to be shared by us with our vendors in each city where you will stay, and they may further process this information for making suitable arrangements for you during the holiday. Such sharing and processing of information may extend to the hotel where you will stay or the tour manager who will be your guide during the travel.
A withdrawal of consent by you for us to process your information may:
Type of information we collect and it's legal basis
The information as detailed below is collected for us to be able to provide the services chosen by you and also to fulfill our legal obligations as well as our obligations towards third parties as per our User Agreement.
"Personal Information" of User shall include the information shared by the User and collected by us for the following purposes:
Registration on the Website: Information which you provide while subscribing to or registering on the Website, including but not limited to information about your personal identity such as name, gender, marital status, religion, age etc., your contact details such as your email address, postal addresses, frequent flyer number, telephone (mobile or otherwise) and/or fax numbers. The information may also include information such as your banking details (including credit/debit card) and any other information relating to your income and/or lifestyle; billing information payment history etc. (as shared by you).
Other information: We many also collect some other information and documents including but not limited to:
How we use personal information
The Personal Information collected maybe used in the following manner:
We may also use your Personal Information for several reasons including but not limited to:
Surveys:
We value opinions and comments from our Users and frequently conduct surveys, both online and offline. Participation in these surveys is entirely optional. Typically, the information received is aggregated, and used to make improvements to Website, other Sales Channels, services and to develop appealing content, features and promotions for members based on the results of the surveys. Identity of the survey participants is anonymous unless otherwise stated in the survey.
Marketing Promotions, Research and Programs:
Marketing promotions, research and programs help us to identify your preferences, develop programs and improve user experience. Lulu Holidays frequently sponsors promotions to give its Users the opportunity to win great travel and travel related prizes. Personal Information collected by us for such activities may include contact information and survey questions. We use such Personal Information to notify contest winners and survey information to develop promotions and product improvements. As a registered User, you will also occasionally receive updates from us about fare sales in your area, special offers, new Lulu Holiday services, other noteworthy items (like savings and benefits on airfares, hotel reservations, holiday packages, car rentals and other travel services) and marketing programs.
In addition, you may look forward to receiving periodic marketing emails, newsletters and exclusive promotions offering special deals.
From time to time we may add or enhance services available on the Website. To the extent these services are provided, and used by you, we will use the Personal Information you provide to facilitate the service(s) requested. For example, if you email us with a question, we will use your email address, name, nature of the question, etc. to respond to your question. We may also store such Personal Information to assist us in making the Website the better and easier to use for our Users.
Lulu Holidays may from time to time launch reward programs by way of which users may stand to win travel related rewards or other rewards. We may use your Personal Information to enroll you in the rewards program and status of the same will be visible each time you log in to the Website. Depending on the reward program, each time you win a reward, Lulu Holidays may share your Personal Information with a third party that will be responsible for fulfilling the reward to you. You may however choose to opt out of such reward programs by writing to us. For various purposes such as fraud detection, offering bookings on credit etc., we at times may verify information of customers on selective basis, including their credit information. Additionally, Lulu Holidays may share your Personal Information, anonymous and/ or aggregated data to a third party that Lulu Holidays may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, data processing and assessing credit worthiness for offering bookings on credit.
How long do we keep your personal information
Lulu Holidays will retain your Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this policy. In some circumstances we may retain your Personal Information for longer periods of time, for instance where we are required to do so in accordance with any legal, regulatory, tax or accounting requirements.
Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
Cookies and Session Data
Cookies
A “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. We use cookie and tracking technology depending on the features offered. No Personal Data will be collected via cookies and other tracking technology; however, if the Customer previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties..
Links to Other Sites
Our Platform links to other websites that may collect personally identifiable information about the Customers. We are not responsible for the privacy practices or the content of those linked websites. The Customers are advised to use their discretion while clicking on any such links.
Consent
By using and/or visiting the Platform, using our Services and/or by providing the Customer’s Personal Data, the Customers consent to the collection and use of the information they disclose on the Platform in accordance with this Privacy Policy, including but not limited to their consent for sharing their information as per this privacy policy
How can customers access their Personal Data
As we are a transparent organization, the Customers will always have a way to access or correct their Personal Data unless there are practical, contractual and legal reasons that would prevent us from doing so. We would just need ample time to provide or correct that information for the Customers, but rest assured it would be completed. The Customers can let us know what they think, and if they are in need of any assistance on their data privacy needs or concerns, they can email us at: support@myluluholidays.com
With whom your personal information is shared
Service Providers and suppliers:
Your information shall be shared with the end service providers like airlines, hotels, bus service providers, cab rental, railways or any other suppliers who are responsible for fulfilling your booking. You may note that while making a booking with Lulu Holidays you authorize us to share your information with the said service providers and suppliers. It is pertinent to note that Lulu Holidays does not authorize the end service provider to use your information for any other purpose(s) except as may be for fulfilling their part of service. However, how the said service providers/suppliers use the information shared with them is beyond the purview and control of Lulu Holidays as they process Personal Information as independent data controllers, and hence we cannot be made accountable for the same. You are therefore advised to review the privacy policies of the respective service provider or supplier whose services you choose to avail.
Lulu Holidays does not sell or rent individual customer names or other Personal Information of Users to third parties except sharing of such information with our business / alliance partners or vendors who are engaged by us for providing various referral services and for sharing promotional and other benefits to our customers from time to time basis their booking history with us.
Companies in the same group
In the interests of improving personalization and service efficiency, we may, under controlled and secure circumstances, share your Personal Information with our affiliate or associate entities. This will enable us to provide you with information about various products and services, both leisure- and travel-related, which might interest you; or help us address your questions and requests in relation to your bookings.
If the assets of Lulu Holidays are acquired, our customer information may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, as part of business expansion/development/restructuring or for any other reason whatsoever, if we decide to sell/transfer/assign our business, any part thereof, any of our subsidiaries or any business units, then as part of such restructuring exercise customer information including the Personal Information collected herein shall be transferred accordingly.
Business partners and third-party vendors
We may also share certain filtered Personal Information to our corporate affiliates or business partners who may contact the customers to offer certain products or services, which may include free or paid products / services, which will enable the customer to have better travel experience or to avail certain benefits specially made for Lulu Holidays customers. Examples of such partners are entities offering co-branded credit cards, travel insurance, insurance cover against loss of wallet, banking cards or similar sensitive information etc. If you choose to avail any such services offered by our business partners, the services so availed will be governed by the privacy policy of the respective service provider.
Lulu Holidays may share your Personal Information to third party that Lulu Holidays may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, and data processing platforms.
We use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher quality, more useful online services by performing statistical analysis of the collective characteristics and behavior of our customers and visitors, and by measuring demographics and interests regarding specific areas of the Website. We may provide anonymous statistical information based on this data to suppliers, advertisers, affiliates and other current and potential business partners. We may also use such aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their websites. Any Personal Information which we collect and which we may use in an aggregated format is our property. We may use it, in our sole discretion and without any compensation to you, for any legitimate purpose including without limitation the commercial sale thereof to third parties.
Occasionally, Lulu Holidays will hire a third party for market research, surveys etc. and will provide information to these third parties specifically for use in connection with these projects. The information (including aggregate cookie and tracking information) we provide to such third parties, alliance partners, or vendors are protected by confidentiality agreements and such information is to be used solely for completing the specific project, and in compliance with the applicable regulations.
Disclosure of information
In addition to the circumstances described above, Lulu Holidays may disclose User's Personal Information if required to do so:
Such disclosure and storage may take place without your knowledge. In that case, we shall not be liable to you or any third party for any damages howsoever arising from such disclosure and storage.
User Generated Content
Lulu Holidays provides an option to its users to post their experiences by way of reviews, ratings and general poll questions. The customers also have an option of posting questions w.r.t a service offered by Lulu Holidays or post answers to questions raised by other users. Lulu Holidays may also hire a third party to contact you and gather feedback about your recent booking with Lulu Holidays. Though the participation in the feedback process is purely optional, you may still receive emails, notifications (app, sms, Whatsapp or any other messaging service) for you to share your review(s), answer questions posted by other users or a. The reviews may be written or in a video format. The reviews written or posted may also be visible on other travel or travel related platforms.
The UGC that Lulu Holidays collects may be of the following kinds:
Each User who posts review or ratings, Q& A, photographs shall have a profile, which other Users will be able to access. Other Users may be able to view the number of trips, reviews written, questions asked and answered and photographs posted.
How can you opt-out for receiving our promotional emails
You will occasionally receive e-mail updates from us about fare sales in your area, special offers, new Lulu Holidays services, and other noteworthy items. We hope you will find these updates interesting and informative. If you wish not to receive them, please send an email to support@myluluholidays.com
Withdrawal of your concent and permission
You may withdraw your consent to submit any or all Personal Information or decline to provide any permissions on its Website as covered above at any time. In case, you choose to do so then your access to the Website may be limited, or we might not be able to provide the services to you. You may withdraw your consent by sending an email to support@myluluholidays.com
Your rights QUA personal information
For any update or deletion of user details registered with us, then you write to support@myluluholidays.com
Eligibility to transact with MMT
You must be atleast 18 years of age to transact directly with Lulu Holidays and also to consent to the processing of your personal data.
Changes to the privacy policy
We reserve the rights to revise the Privacy Policy from time to time to suit various legal, business and customer requirement. We will duly notify the users as may be necessary.
You may always submit concerns regarding this Privacy Policy via email to us at support@myluluholidays.com. Lulu Holidays shall endeavor to respond to all reasonable concerns and inquires.
