Company’s Privacy Commitment Overview
1. About this Policy
1.1 MVM Infotech Private Limited (hereinafter referred to as “We/Our/Company”) is a company incorporated and registered under the Companies Act, 2013 having CIN U72900UR2021PTC013425 and having its registered office at Flat B-214 Tower B, 2nd Floor, Mussoorie the Forest Residency, Dehradun, Uttarakhand, India 248001.
1.2 The Company has developed a proprietary platform namely Partner Management System (“PMS”) through which the User and the Company can connect and communicate with each other.
1.3 For the purposes of this Privacy Policy, “You”, “Your” or “User” shall mean, including but not limited to, the Destination Partner(s)and any interested entity who intends to collaborate with the Company and communicate using PMS.
1.4 The Company is committed in protecting the privacy of its Users. The Company strives to provide a safe, secure User experience through protecting the personally identifiable information (hereinafter referred to as “PII”) that resides with the Company. Keeping Your PII secure and preventing any misuse thereof, is therefore a top priority of the Company. The Company is strongly committed to protecting Your privacy and has taken all necessary and reasonable measures to protect the confidentiality of any information including PII shared by You.
1.5 As used in this Privacy Policy, PII includes any information or set of information, whether alone or in combination with other personal information gathered, processed, used or stored by the Company which is sufficient to identify the User and tracking information such as IP address of Your device and device ID when connected to the Internet. This information may include the URL that You just visited (whether this URL is on PMS or not), which URL You next go to (whether this URL is on PMS or not), Your computer or device browser information, and other information associated with Your interaction with PMS.
1.6 This Privacy Policy explains the Company’s commitment to managing Your personal information and sets out how and when PII is collected, used, shared, and secured as well as Your choices regarding the use, access, and correction of Your personal information.
1.7 This Privacy Policy forms part and parcel of the Terms for the use of PMS.
By using this PMS or accepting the Privacy Policy, You agree to the collection, use and transfer of Your data as described in this Privacy Policy.
2. Scope of this Policy
2.1 This Privacy Policy applies to current and former Users of PMS. By visiting and/or using/downloading PMS, You are accepting and consenting to the practices described in this Privacy Policy. The statements and procedures mentioned under this Privacy Policy must be read in conjunction with Our Terms available on PMS.
2.2 The Privacy Policy is published and shall be construed in accordance with the provisions of Information Technology Act, 2000 and rules made thereunder including the Information Technology (reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended thereof, the Digital Personal Data Protection Act, 2023, the EU General Data Protection Regulation and other applicable law enacted from time to time. There is no requirement for any physical, electronic, or digital signature in this Privacy Policy.
2.3 This Privacy Policy explains the Company’s policy regarding the collection, use, disclosure, and transfer of Your PII by the Company in relation to the use of PMS including but not limited to delivery of information and content.
2.4 You accept this Privacy Policy when You visit PMS or use any services, content, features, technologies, or functions offered on the Company’s PMS.
3. Applicability of Privacy Policy
3.1 This Privacy Policy applies to PII as defined in Clause 1.3 and 1.4 of this Policy and such other information as may be required on need to know basis for the usage of the services offered by the Company.
3.2 This Privacy Policy is intended to govern the use of services by Users unless otherwise agreed.
4. Information We Collect and Retain
4.1 By accessing PMS, You consent to collection storage, and use of PII provided by You (including any changes thereto as provided).
4.2 The Company respects Your privacy and is committed to reasonably protect it in all aspects. In order to use PMS, User needs to provide the following PII.
a) Name of the entity
b) Year of establishment
c) Email Address
d) Address of the entity
e) Website (if any)
f) Skype ID (if any)
g) Mobile/Telephone number (with country code)
h) Country and City
i) Valid government identification/documentation/registration number
j) Specialised services
k) Number of staff/employees
l) Regions/countries where services are offered
m) Third party review links (if any)
n) Commission Rate
o) Details of point of contact person
4.3 The Company may also collect information through Your interaction with and use of PMS. This information includes, but is not limited to the following:
a) You activity on PMS
b) Your internet protocol (IP) address and internet service provider (ISP)
c) Your browser type and device ID
d) Operating system, date/time stamp, and/or clickstream data
e) Data about pages You access
f) Computer IP Address
g) Geo-location information,
h) Computer and connection information,
i) Referral URL,
j) Ad data, and
k) Any other information.
4.4 Upon registration with the Company (as per Clause 4 of the Terms of Use) automatically generates a unique password for each User, which is securely stored in Our database. To maintain the security of Your account, the Company does not share this password with You or any third parties.
4.5 The Company provides a secure link accompanied by a unique browser code for communication purposes. This link allows you to chat with us in a secure environment.
4.6 Upon entering the secure browser code for the first time, it will be saved in Your browser's cookies ( as per Clause 17). This means that if You access the link again from the same device, You will not be required to enter the code once more. However, if You access the link from a different device or computer, You will be prompted to enter the secure browser code again for verification.
4.7 The Company may also collect anonymous information through use of cookies and web beacons. The Company may collect and store any information You may provide to us when You use the services being offered by the Company, including when You add information in a web form, add or update Your account information, or when you otherwise correspond with the Company regarding the services.
4.8 In order to help protect You from fraud and misuse of Your personal information, we may collect information about You and Your interactions with PMS for the services provided.
5. How PII is used
5.1 Your PII may be used to set up and administer Your account, provide necessary technical support, verify Your identity, and send important communication.
5.2 We may use Your PII for internal and external research and development purposes and to improve and test the features and functions of PMS to give the best options and services to You. It is clarified that access of such information may be limited to authorised personnel for a critical reason, such as technical support.
5.3 By registering with PMS and/or by managing Your profile/account on PMS You have consented the Company to to use Your information in the following ways:
5.3.1 To provide You with Our services in accordance with the terms of use of PMS.
5.3.2 To improve PMS functions, features and services therein efficiently.
5.3.3 To provide technical assistance requiring initial setup, support services, or dealing with any suspicious activities from the user accounts.
5.3.4 To detect, investigate, and prevent activities that may violate the Company’s policies or be illegal.
5.4 The Company gathers information about all of its Users visiting PMS collectively, which includes but is not limited to their activity on PMS and what services are accessed by them the most. Such data and/or information is used anonymously and in the aggregated form. Such information is analysed and used to create an overall better experience for the use of PMS and the services offered through PMS.
5.5 You however acknowledge and accept that in case of information that may be asked by any court or government authority, the Company will inform You of such information being given to the court or government authority only if the court or government authority permits the Company to do so.
5.6 The Company does not sell information about its Users to any person or entity whatsoever. However, during the development of its business, the Company may sell or buy companies or assets. In such transactions, Your information may be transferred to such companies or assets.
6. Sharing and Disclosure of the Information
6.1 The Company may share the information provided by You with its affiliates.
6.2 The Company in no way shares or discloses information about Your visits to PMS to any outside parties, except otherwise necessary or appropriate to comply with applicable laws, rules, or regulations or in legal proceedings when such information is relevant.
6.3 The Company will share the information for the enlisted purposes with the Company’s service providers, which are third parties who help the Company in the delivery of services to You and where sharing of information is essential for imparting business obligations of the Company. Examples include hosting the Company’s web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These service providers will have access to Your personal information to perform their functions, however, they shall not be authorized to use the information for any purpose other than prescribed.
6.4 While the Company takes measures to safeguard Your information from unauthorized access or inappropriate use, the Company does not control these third parties and shall not be responsible for their use of the information You provide to the Company.
6.5 The information may be shared with Law enforcement agencies, government officials, or other third parties pursuant to a subpoena/summon, court order, or other legal process or requirement applicable to the Company or any of its affiliates, if required by them, or at Our discretion pursuant to a request from a governmental entity or if We believe in good faith after considering Your privacy interests and other factors that such action is necessary to:
6.5.1 conform to legal requirements or comply with legal process;
6.5.2 protect Our rights or property or Our affiliated companies;
6.5.3 prevent a crime or protect national security;
6.5.4 protect the personal safety of Users or the public.
6.5.5 to legally comply with anti-money laundering and counter-terrorist financing verification requirements
6.6 The Company may also disclose and transfer such information to a third party who acquires any or all of Company's business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of Our assets.
6.7 In the event the Company becomes the subject of bankruptcy proceeding, whether voluntary or involuntary, Company or its liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court. You will be notified of the sale of all or a substantial portion of the Company’s business to a third party by email or through a prominent notice posted on the Site.
7. Express Consent
7.1 You expressly consent to provide details/information/documents to the Company under this Privacy Policy.
7.2 You while providing Your details/documents over PMS, including but not limited to the personal information or other information as mentioned hereinabove, expressly consent to the Company to contact You through e-mail and for follow-up calls concerning the Services provided through PMS, for imparting service knowledge, offering promotional offers running on PMS & various other offers offered by its business partners. The nature and frequency of these messages will vary depending on the information we have about You.
8. Withdrawal of Consent
8.1 The consent provided to the Company by You for collection of PII and such other information on need to know basis may be withdrawn at any time by emailing the consent manager at (privacy@exploringtourism.com).
8.2 If You do not want Your information to be processed as described by this Policy, You may revoke Your consent to Our Privacy Policy. If You wish to do so, please email the consent manager at privacy@exploringtourism.com. However, please note that if You do withdraw Your consent, You may not be able to use the relevant services and Your account will be deleted in 30 days from PMS.
8.3 However, the Company shall retain and store Your information in the database maintained with the Company till such reasonably practical time period post withdrawal of consent by the User as applicable under the prevailing law.
9. Access and Updating Account Information
9.1 When the User uses PMS, the Company makes good faith efforts to provide the User, as and when requested by the User, with access to his/her PII and the User shall further ensure that any PII or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such PII or sensitive personal data or information to be retained by law or for legitimate business purposes.
9.2 The Company asks individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and the Company may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.
9.3 In case You would like to access/modify / delete any details with respect to Your information, or to access Your information in readable format, You can write to:privacy@exploringtourism.com.
9.4 The Company shall process all information access requests within 30 days of receipt. However, in case the Company requires additional time to provide access to Your information, the same shall be acknowledged on the User email id, from which the information access request was sent, within 30 days.
9.5 The Company reserves the right to verify and authenticate Your identity and PII the access to which is requested.
10. Retention and Storage of PII
10.1 The Company will retain Your information for as long as necessary for providing the Services available on PMS, comply with Our legal obligations, resolve disputes, or till Your request to terminate Your account, whichever is later.
10.2 If in case a User is located in the European Union and does not log into the User account or interact/avail any of the Company services for more than five years, the User account of the individual User shall be terminated and from PMS. An email initiating termination shall be sent to the User whose account contains contact information, before termination of User account.
10.3 Post termination of Your account or withdrawal of consent to use certain information/ data, the Company continues to use Your anonymized data aggregated or in combination with anonymized data of other users. We use this aggregated anonymized data for data analysis, profiling, and research purposes. We may keep Your contact information for fraud prevention purposes and for the exercise/ defence of a legal claim or for providing evidence in a legal proceeding(s).
11. Online Security
The Company shall ensure safety and security of online payment on services availed by the Users of PMS. The Company undertakes to ensure that the financial information is duly encrypted using Secure Socket Layer ("SSL") encryption technology before being sent over the Internet. SSL makes it very difficult for Your information to be stolen or intercepted while being transferred. However, the Company does not guarantee encryption or the privacy of Your financial information of Users is maintained through and the payment is processed.
12. Company Database
12.1 The information, including but not limited to PII, provided by the Users of PMS is stored on the Company database. The Company is a legal entity determining the purposes and means of processing the information gathered on PMS and applications and is the data controller of all data Company collects from You.
12.2 PMS contains a section for the Users of PMS to provide feedback. Any feedback that is submitted through this area becomes the property of Company. The Company may use this feedback at any time for any purposes, such as success stories for marketing purposes, or to contact You for further feedback on PMS.
13. Important Information
13.1 The Users are themselves responsible for ensuring that log-in credentials used on PMS i.e. Your username and password are kept confidential at all times;
13.2 The Company has implemented technical and organizational measures designed to secure Your personal information from accidental loss and from unauthorized access, use, alteration or disclosure.
13.3 Notwithstanding to anything contained in Clause 17.2., the Internet is an open system and the Company in no way guarantee that unauthorized third parties will not be able to defeat those measures or use Your personal information for improper purposes.
13.4 The Company also makes use of cookies, web beacons, and Java Script to administer PMS and deliver a personalized experience. For additional detailed information on each of these, kindly refer to the Cookie Policy under Clause 17.
14. Changes to Privacy Statement
The Company may update and change its Privacy Policy from time to time to provide efficient services and to safeguard Your information. The Company may provide such information of change or updation of Privacy Policy through a prominent notice on PMS. However, You shall check the Privacy Policy for periodically for such changes. In case of continued use of the Services of PMS provided by the Company shall mean that the changes in Privacy Policy have been accepted by You.
15. Legal and Contact Information
15.1 If, at any time, You have questions or concerns about this Privacy Statement or believe that we have not adhered to this Privacy Statement, please feel free to contact us online at: privacy@exploringtourism.com
15.2 We will use reasonable efforts to answer promptly Your question or resolve Your problem. Users in the European Economic Area (EEA) and Switzerland have the right to lodge a complaint with the supervisory authority for data protection in their respective country.
16. User Acknowledgements
The User hereby acknowledges and agrees that this Privacy Policy:
16.1 Is clear and easily accessible and provide statements of Company policies and practices with respective to the Information;
16.2 provides for the various types of personal or sensitive personal data of information to be collected;
16.3 provides for the purposes of collection and usage of the Information;
16.4 provides for reasonable security practices and procedures.
16.5 User further acknowledges that the User is at least 18 years of age or above and competent as defined under the provisions of applicable statutes in their respective jurisdiction to understand and agree the terms, conditions, obligation, affirmations, representations and warranties set forth in this Terms.
17. Cookie Policy and Online Advertising
17.1 Cookies
The Company makes use of cookies on PMS to analyze trends, administer websites, track User’s movements around the website, save browser code and to gather demographic information about Our user base as a whole. Cookies help personalize and maximize Your use of PMS. You can control Your cookies at the browser level, but if You choose to disable cookies, it may limit Your use of certain features or functions on PMS or service. We offer certain features that are only available through the use of a "cookie”.
17.2 We use the following types of cookies:
a) Security: These cookies allow the Company to secure access to User account.
b) Preference: These cookies are used to store User preferences
c) Analytics: We track traffic patterns in order to identify User’s usage of PMS
d) Advertising: We use non-identifiable information about you to show you advertising on PMS and third party websites.
17.3 Some cookies will remain on Your computer after You have left Our site such as, Security cookies will remain for 30 days after Your last visit., cookies relating to advertisements and site notices will remain for some days or unless you choose to delete them.
17.4 Advertising Opt Out
Company uses several third parties to help provide analytics and to serve advertisements. Users can opt out of third party cookies by setting Your browser to decline cookies.
17.5 JavaScript
The Company also uses JavaScript.. JavaScript is a script language that enhances the functionality of websites, particularly in respect to pictures. The company does not collect any personal data via JavaScript, however uses it in a way to enhance PMS functions and User experience for Employers, specifically. JavaScript via browser settings and can be activated it the same way. However, JavaScript will restrict the use of some functions of PMS.