ARNA Global Enterprises Private Limited (hereinafter “ARNA GEPL”) understands its valuable customer’s concerns for privacy and undertakes several measures of protecting and maintaining their personal information that is being shared with us. The applicability of this Privacy Policy extends to the User who inquires or means to purchase or purchases the product(s) or service(s) offered by ARNA GEPL through any of its online channels including its website (“thearna.com”), mobile site, mobile app & offline channels including call centers and offices (collectively referred herein as “Sales Channels”). For the purpose of this Privacy Policy, Website means the website(s), mobile site(s) and mobile app(s) being operated by thearna.com 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 ARNA GEPL’s business partners, advertisers, sponsors or other sites to which ARNA GEPL provides hyperlink(s), may be significantly different from this Privacy Policy. Accordingly, it is recommended that the User reviews the privacy statements and policies of any such third parties with whom they interact.

A cookie may also be placed by ARNA GEPL’s advertising servers or third party advertising companies. Such cookies are used for the purpose of tracking the effectiveness of the advertisement advertising by ARNA GEPL on any website, and also to use aggregated statistics about the User’s visits to the Website in order to provide advertisements in the Website or any other website about services that may be of potential interest to the User. The third party advertising companies or advertisement providers may also employ technology that is used to measure the effectiveness of the advertisements. All such information is anonymous. This anonymous information is collected through the use of a pixel tag, which is an industry standard technology and is used by all major websites. They may use this anonymous information about the User’s visits to the Website in order to provide advertisements about goods and services of potential interest to the User. No Personal Information is collected during this process. The information so collected during this process, is anonymous, and does not link online actions to a User.

ARNA GEPL records session data of the Users, which includes IP address, Operating System, browser software and the activities of the User on his device. We collect session data to evaluate the User’s behavior. Such session data helps ARNA GEPL in identifying the problems with its servers and improving its systems. This information does not identify any visitor personally and only examines the User’s geographic location.

ARNA GEPL provides an option to its Users to post their experiences by way of reviews, ratings and general poll questions. The User also has an option of posting questions with regard to a service offered by ARNA GEPL or post answers to questions raised by other Users. Though the participation in the feedback process is purely optional, a User may still receive emails, notifications (through the App/SMS/Whatsapp or any other messaging service) to share the User’s review(s) or respond to questions posted by other Users. The reviews written or posted by a User may also be visible on other travel or travel related platforms.

Each User who posts a review or ratings or 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 about ARNA GEPL.

The User’s information will 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 the User’s booking. The User may note that while making a booking with ARNA GEPL, the User authorizes ARNA GEPL to share the User’s information with the said service providers and suppliers. It is pertinent to note that ARNA GEPL does not authorize the end service provider to use the concerned User’s information for any other purpose(s) save and except as may be requiring for fulfilling their part of service. However, the use of information as shared with the said service providers/suppliers for any other purpose is beyond the purview and control of ARNA GEPL as they process Personal Information as independent data controllers, and hence ARNA GEPL shall not be held liable for the same. The User is therefore advised to review the privacy policies of the respective service provider or supplier whose services, the User chooses to avail.

ARNA GEPL does not sell or rent individual customer names or other Personal Information of Users to third parties except sharing of such information with ARNA GEPL’s business / alliance partners or vendors who are engaged by ARNA GEPL for providing various referral services and for sharing promotional and other benefits to ARNA GEPL’s customers from time-to-time basis their booking history with ARNA GEPL.

In the interests of improving personalization and service efficiency, ARNA GEPL may, under controlled and secure circumstances, share the User’s Personal Information with its affiliate or associate entities. This will enable ARNA GEPL to provide the User with information about various products and services, both leisure and travel related, which might interest the User; or help ARNA GEPL address the User’s questions and requests in relation to their bookings.

ARNA GEPL may also share certain filtered Personal Information with its corporate affiliates or business partners, including banks, who may contact the Users, either directly or through ARNA GEPL, to offer certain products or services based upon independent or Credit Bureau assessment of eligibility of the Users basis the filtered Personal Information shared, and which may include free or paid products / services, which will enable the User to have better travel experience or to avail certain benefits specially made for ARNA GEPL’s 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 the User chooses to avail any such services offered by ARNA GEPL ’s business partners, the services so availed will be governed by the privacy policy of the respective service provider.

ARNA GEPL may share the User’s Personal Information with any third party whom ARNA GEPL may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, and data processing platforms.

ARNA GEPL uses 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 its customers and visitors, and by measuring demographics and interests regarding specific areas of the Website. ARNA GEPL may provide anonymous statistical information based on this data to suppliers, advertisers, affiliates and other current and potential business partners.

ARNA GEPL 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 ARNA GEPL collects and which it may use in an aggregated format shall be ARNA GEPL’s property. ARNA GEPL may use it, in its sole discretion and without any compensation to the User, for any legitimate purpose including without limitation the commercial sale thereof to third parties.

Occasionally, ARNA GEPL 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) ARNA GEPL provides to such third parties, alliance partners, or vendors are protected by confidentiality agreements and such information shall be used solely for completing the specific project, and in compliance with the applicable regulations.

In addition to the circumstances described above, ARNA GEPL may disclose User’s Personal Information if required to do so:

• by law, required by any enforcement authority for investigation, by court order or in reference to any legal process
• to conduct its business
• for regulatory, internal compliance and audit exercise(s)
• to secure its systems
• to enforce or protect rights or properties of ARNA GEPL or any or all of its affiliates, associates, employees, directors or officers
• When there is reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with its rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Such disclosure and storage may take place without the User’s knowledge. In such an event, ARNA GEPL shall not be liable to the User or any third party for any damages howsoever arising from such disclosure and storage.

When ARNA GEPL App (“App”) is installed on the User’s phone, a list of permissions appears. Permissions that ARNA GEPL requires are:

ARNA GEPL needs the User’s device permission to collect details like Operating System name & version, mobile network, preferred language, and few others. On the basis of these inputs, ARNA GEPL optimizes the User’s travel booking experience.

Through this permission, the User allows ARNA GEPL to get the info of one’s account(s) on the User’s mobile device. This information is used to fill the User’s email IDs automatically. This action allows ARNA GEPL to map e-mail ID’s of its Users to give them the benefits of exclusive travel discounts and cashback etc.

This permission allows ARNA GEPL to let the User know the benefits of ongoing specific offers at the User’s location. When the User launches the App for travel booking, ARNA GEPL detects the User’s location automatically and the User’s nearest airport or city is auto-filled. For international journeys, this action allows ARNA GEPL to ascertain the User’s time zone and provide information accordingly.

The libraries in the App use these permissions to allow map data to be saved to User’s phone’s external storage, like SD cards. By saving map data locally, User’s smart phone is not required to re-download the same map data every time the User uses the App. This provides User a seamless Map based Hotel selection experience, even on low bandwidth network.

When User allows ARNA GEPL the permission to detect User’s Wi-Fi connection, ARNA GEPL optimizes User’s experience such as more detailing on maps, better image loading, more hotel/ flights/ package options to choose from, etc.

If the User allows ARNA GEPL to access its SMS, ARNA GEPL reads SMS and fills the One Time Password (“OTP”) automatically while making transactions. This allows the User to continue to remain on the App and not requiring the OTP to be filled in manually thereby offering the User, a hassle-free booking experience.

If the User allows ARNA GEPL to access its contacts, ARNA GEPL can invite User’s friends to try its App and also give them recommendations for various travel related services. These details will be stored on ARNA GEPL’s servers and synchronized from the User’s phone.

This permission helps ARNA GEPL in identifying the Android ID through which ARNA GEPL can exclusively recognize its Users. It also enables ARNA GEPL to know the contact details through which ARNA GEPL auto-fills specific details, resultantly guarantying a seamless booking experience.

This permission allows ARNA GEPL in putting a travel plan on the User’s calendar.

ARNA GEPL takes all reasonable measures to protect the information that a User shares. ARNA GEPL has undertaken advanced technology and security measures along with strict policy guidelines to secure the privacy of its customers and save their information from any unwanted access. ARNA GEPL is constantly enhancing its security measures by using more advanced technology.

ARNA GEPL’s Privacy Policy may change due to any unforeseen circumstances and enhancement of technologies. We will duly notify the Users as and when necessary.

If a User allows notifications for ARNA GEPL App, it enables ARNA GEPL to send across exclusive deals, promotional offers, travel related updates, etc. on the User’s device. If the User permits this, updates for your travel like PNR status, booking confirmation, refund (in case of cancellation), etc. will be sent through SMS. However, ARNA GEPL will not be liable for non-receipt of such updates by the User for any reason whatsoever.

If the User grants permission to access the User’s contact list, it enables ARNA GEPL to provide a lot of social features to the User such as sharing your hotel/ flight/ holidays with your friends, inviting your friends to try ARNA GEPL’ App, send across referral links to User’s friends, etc. ARNA GEPL will also use this information to make recommendations for hotels where User’s friends have stayed. This information will be stored on ARNA GEPL’s servers and synced from the User’s phone.

This permission enables ARNA GEPL to give the User the benefit of location specific deals and provide the User, a personalized in-funnel experience. When the User launch the App to make a travel booking, ARNA GEPL auto-detects the User’s location so that the User’s nearest Airport or City is auto-filled. ARNA GEPL require this permission to recommend the User nearby hotels in case the User is running late and wants to make a quick last minute booking for the nearest hotel. The User’s options are personalized basis the User’s locations. For international travel, this enables ARNA GEPL to determine the User’s time zone and provide information accordingly.

All payments on the Website are secured. The Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under ARNA GEPL’s control. Once the User’s information is in ARNA GEPL’s possession, we adhere to strict security guidelines, protecting it against unauthorized access.

The User may withdraw its consent to submit any or all Personal Information or decline to provide any permission on the Website as covered above at any time. In such a circumstance, the User may face limited access to the Product(s) and Services (s) being offered by ARNA GEPL.

The User may access its Personal Information from its user account with ARNA GEPL. The User may choose to correct or delete such personal information directly by accessing such User Account, except for such mandatory fields.

The User must atleast be 18 years of age to transact directly with ARNA GEPL and also to consent to the processing of their personal data.

The data shared with ARNA GEPL shall be primarily processed in India and such other jurisdictions where a third party engaged by ARNA GEPL may process the data on ARNA GEPL’s behalf. By agreeing to this policy, you are providing ARNA GEPL 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: info@thearna.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:

• severely inhibit our ability to serve you properly and in such case, we may have to refuse the booking altogether
• unreasonably restrict us to service your booking (if a booking is already made) which may further affect your trip or may compel us to cancel your booking.

ARNA GEPL will retain User’s Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this policy. In some circumstances ARNA GEPL may retain User’s Personal Information for longer periods of time, for instance where ARNA GEPL is required to do so in accordance with any legal, regulatory, tax or accounting requirements.

Where User’s personal data is no longer required, ARNA GEPL will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.