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PRIVACY POLICY

 

I. Introduction

 

At, Foley Designs Pvt. Ltd. a Company incorporated under the Companies Act, 1956 having its registered office at #14, Second Floor, Yolee Building, Pottery Road, Richards Town, Bengaluru 560 005, India (hereinafter referred to as “Company”, “We”, “Us”, “Our” or similar) we appreciate the trust entrusted upon us by you i.e. Registered Users (hereinafter referred to as “You” or “Yours” or similar) (defined below). We seek to protect the Information which includes Personal Information and Sensitive Personal Information that we collect, or you share while using the Travet Application (defined below) to the best extent possible and only use the Information in a manner provided in this policy (“Privacy Policy”). 

 

This Privacy Policy has been drafted in accordance and compliance with (i) the Indian Contract Act, 1872, (ii) the (Indian) Information Technology Act, 2000, and the rules, regulations, guidelines and clarifications framed there under, including (iii) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”), and (iv) Information Technology (Guidelines for Intermediaries and Digital Media Ethics Code) Rules, 2021. 

 

In this Privacy Policy, we describe the kind of Information that we collect about you when you use and access the Travet application through desktops, mobile phones, smart phones, tablets, plugins and API (hereinafter the “Travet Application”) and how we use and disclose that Information in relation to providing the Services through the Travet Application. By using the Travet Application, you have given us your permission/consent to collect, store, and use the Information you provide for availing any of the Services that the Travet Application offers. You acknowledge that You are providing Your Information out of Your free will. The Company is the owner of the Application.

The Privacy Policy read along with the Terms of Use comes into effect from the date and time a Registered User downloads and starts using the Travet Application and accepts the Terms.  If you have any questions or comments about the Privacy Policy, please contact us at tmichael@foleydesigns.com .  

 

BY ACCESSING OR USING THE TRAVET APPLICATION, AND/OR SERVICES PROVIDED THEREIN, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS. IF YOU DO NOT AGREE TO THE TERMS OR PRIVACY POLICY DO NOT USE THE SERVICES OR ACCESS THE TRAVET APPLICATION.

 

Our Privacy Policy is subject to change at any time without notice. Your continued use of the Travet Application following such changes to the Policy constitutes your acceptance of the changed Policy and to be bound by such changes.

 

II. DEFINITIONS

 

As used in these Terms, the following terms shall have the meaning set forth below:

 

(i) Confidential Information shall mean all information and materials furnished by a party which: (a) if in written format is marked as confidential, or (b) if disclosed verbally is noted as confidential at time of disclosure, or (c) in the absence of either (a) or (b) is information which a reasonable party would deem to be non-public information and confidential.  Confidential Information shall include, but not be limited to information regarding Registered Users, all types of data, Personal Information, Sensitive Personal Information, ideas, schedules, contact information, passwords, business plans,  projections, marketing data and other similar information of the Company, documentation, the existence and contents of this Agreement, whether such is transmitted in writing, orally, visually, (e.g. video terminal display) or on magnetic media, and shall include all proprietary information, customer and prospect lists, trade secrets, or intellectual property rights such as trade names, trademarks, copyright, patents, designs, know-how, concepts, drawings, flow charts, diagrams and other intellectual property relating to the subject matter of this Agreement owned by the Company. 

 

(ii) Services means the services being offered to Registered Users through the Travet Application by providing a platform through which the Registered Users will be able to plan and create daily, weekly, monthly or yearly tasks based on a graphical representation of time. The tasks can include setting up meetings, alarms, reminders, recording notes, scheduling and making calls and such other features and services as the Company may include from time to time. 

 

(iii) Registered User shall mean a person who is competent to contract under applicable laws and who signs up and registers as a user on the Travet Application for using the Services.

 

(iv) Registered User Content shall include all content submitted, posted, published, or distributed on the Travet Application by the Registered User including but not limited to all entries made in pursuance of using the features available on the Travet Application as well as Registered User Information. 

 

(v) Registered User Information means information regarding Registered Users which includes personal information such as first and last name, email address, mobile number, photograph, details of google account, details of the apple id/account, access to Google Calendar, information on personal contacts, log in information of Google accounts, passwords, User Content, and any other information which may be provided by a Registered User through using or which may be collected by the Travet Application when the Registered User uses the Services.

 

(vi) All other capitalized terms shall have the meaning ascribed to them in the Other Terms.

 

III. INFORMATION WE COLLECT

 

(i) Information Provided to Us:

 

We receive and store Personal Information/ Sensitive Personal Information (i.e. includes information that whether on its own or in combination with other information may be used to readily identify or contact the Users and Visitors) and Non-Personal Information. 

 

(ii) Personal Information/Sensitive Personal Information: 

 

You will be required to provide certain Personal/Sensitive Personal Information when creating an Account on the Travet Application which would help determine your eligibility to avail the Services. If you create an Account or log into the Travet Application using your Google Apps /Apple Id credentials via single sign-on, we will have access to certain Personal and Sensitive Personal information such as your your first and last name, email address, photograph as authorized in your Google Apps/Apple profile settings. When you use the Travet Application and syn it with your Google Calendar we will have details of google account, details of the apple id/account, Google Calendar information, mobile number, list of personal contacts when entered manually or when given access to Travet Application, login information of Google accounts, passwords, etc. You always have the option to not provide information by choosing not to use a particular Service or feature. Importantly, we only collect Personal Information/Sensitive Personal Information about you that we consider necessary for achieving the purpose of communicating with you and offering the Services available on the Travet Application. 

 

(iii) Non-Personal Information: 

 

Information Collected Automatically: When you download and use the Travet Application as a Registered User, we receive and record information on our server logs from your browser or mobile, including but not limited to your device hardware model, browser type, IP address, operating system version, unique device identifiers, type of device you use, the mobile network information, geographic location, the URL that you just came from, your device browser information, your ISP, and other technical information. We may also collect information about how your device has interacted with the Travet Application, including the pages accessed and links clicked. We treat this data as Non-Personal Information, except where we are required to do otherwise under applicable law. 

 

Cookies: We use data collection devices such as “cookies” on certain pages of the Travet Application to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. “Cookies” are small files placed on the hard drive of your computer that assist us in providing the Services. We offer certain features that are only available through the use of a “cookie”. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies”, meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Application.

 

IV. USE OF INFORMATION COLLECTED 

 

Use of Personal/Sensitive Personal Information and Non-Personal Information is an integral part of the Travet Application, its purpose and our business. We neither rent nor sell your Personal Information to anyone. We may share your Information only as described in this Privacy Policy and related documents. 

 

(i) Use of Personal/Sensitive Personal Information: 

 

We will use and store Personal/ Sensitive Personal Information to: 

 

a) To enable you to use the Travet Application and our Services; 

b) to maintain, and improve our Services, including, for example, to provide Services you request (and send related information), develop new features, provide customer support to You, send updates and administrative messages, develop safety features, authenticate users and customize your experience; 

c) to improve our marketing and promotional efforts;

d) inform you about online and offline offers, services, and updates; 

e) to analyze Application usage and improve customer experience’

f) market and promote the Service and for the internal operational and administrative purposes of the Service, 

g) respond to your emails or letters, or any other correspondence about your activities or postings on Application; 

h) to provide you with a smooth, efficient, safe and customized experience while using the Application;

i) use the information in order to comply with country laws and regulations; and 

j) to resolve disputes; troubleshoot problems; help promote safe interactions and correspondence and detect and protect us against error, fraud and other criminal activity. 

(ii) Use of Non-Personal Information: 

 

We will use Non-Personal Information (including information from online and offline third party sources) to create aggregated data for analytical and other purposes. We use this information to do internal research on your demographics, interests, and behavior to better understand, protect and serve You. This information is compiled and analyzed on an aggregated basis. Unless otherwise stated in this Privacy Policy, We only use this data in aggregate form. 

 

V. OUR DISCLOSURE OF YOUR INFORMATION 

 

Only the persons authorized by us shall have access to your Personal Information and Sensitive Information. Please find below the following circumstances under which and people to whom we would share your Information from time-to-time:

 

(i) Disclosure of Personal Information:

 

We do not disclose your Personal Information/Sensitive Personal Information to any third party for marketing purposes. Except as otherwise provided under this Privacy Policy, we will disclose your Personal Information to third parties only in the following limited circumstances:

 

a) Affiliates: if you use the Service through the Travet Application, we may disclose your Personal Information/Sensitive Personal Information to our affiliates, agents, employees, consultants or trusted partners who work on behalf of or with us under confidentiality agreements. These entities may use your Personal Information for the purposes stipulated under this Privacy Policy, performing Services, administering promotions, analyzing data and usage of the Service through the Travet Application, processing payments and account actions, operating the Service or providing support and maintenance services for the same, or providing customer service, offering advice. They may use the Personal Information to operate, develop, and improve the features and functionality of the Service, communicate with you as described elsewhere in this Privacy Policy. 

 

b) Collaborate with other Registered Users: Your Content is private unless you decide you want to share it. You may choose to collaborate with Registered Users using the collaboration option through the Travet Application feature that allows you to share or collaborate with Registered Users.

 

c) Other third parties with your consent.

d) We reserve the right to use or disclose Personal Information and any other information we collect in connection with the Service offered through the Travet Application if (i) We believe that there is a significant/ real/ imminent threat or risk to your health, safety or life or to the health, safety or life of any other person or the public; (ii) to any successor to our business, including as a result of any merger, acquisition, asset sale or similar transaction, (iii) to any law enforcement, judicial authority, governmental or regulatory authority, to the extent required by law or legal process, or (iv) if in our reasonable discretion, such use or disclosure is necessary to enforce or protect our legal rights or to protect third parties.

 

(ii) Disclosure of Non-Personally Identifiable Information: We may disclose other Non-Personally Identifiable Information including aggregate information to third party advertisers and advertising agencies, partners, and other parties in order for us and such third parties to analyze (a) the performance of, to operate and improve the Services offered through the Travet Application and (b) the behavior of Users and to target offers and services to other users and depending upon their requirements. We may also disclose, use or publish this information for promoting the Services offered under the Travet Application. These third parties are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced operation, unless you have explicitly agreed or given your prior permission to them for additional uses. 

 

(iii) Network Operators: Use of the Service provided through the Travet Application may involve use of the services of third party telecommunications carriers, internet service providers and service providers (such as the services of the carrier that provides cell phone service to you). Such carriers and service providers are not our contractors, and any information that a carrier collects in connection with your use of the Service provided through the Travet Application is not “Personal Information” and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of telecommunications carriers, internet service providers or service providers.

 

VI. STORING YOUR INFORMATION

 

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) (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements) for which the information was collected, and any other permissible, related purpose. When personal data is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.

 

VII. ACCESS OR CHANGE YOUR PERSONAL INFORMATION 

 

You may review, correct, update, change or delete your information at any time by contacting us at michael@foleydesigns.com . To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Information. 

 

Even after you remove information from the Travet Application, copies of that information may remain viewable elsewhere, to the extent it has been shared with others or it was otherwise distributed pursuant to your privacy settings. Removed and deleted information may remain on backup media for up to one hundred and eighty (180) days prior to being deleted from our servers or for a period as required by law.  

 

VIII. AMENDMENTS TO THE PRIVACY POLICY 

 

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we decide to change our Privacy Policy, we will post those changes on this page. You are bound by any changes to the Privacy Policy when you continue to use the Travet Application after such changes have been first posted. 

 

IX. SECURITY OF PERSONAL INFORMATION

 

We take reasonable security measures and procedures, and as specified by applicable law, to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, or unauthorized access, disclosure or modification of Personal Information. While we take these reasonable efforts to safeguard your Personal Information, you acknowledge and agree that no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. We shall, however, not be liable to any user for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused to the user due to the unauthorized access or misuse of the Personal or Sensitive Information by any third party. You agree and undertake that you shall not hold the Company liable therefore in any way. The use and storage of any information, including without limitation, password, account information, transaction activity and any other information available on your internet access device or computer or mobile phone is at your own risk and responsibility. You furthermore acknowledge and accept that the Company may not encrypt all content or communications shared on the Travet Application.

 

X. WITHDRAWAL OF CONSENT 

 

If you have consented to the collection, use and/or disclosure of your Personal and Sensitive Information as identified in this Policy, you may withdraw the same at any time by communicating to us at the given below address under Clause XI.

 

XI. GRIEVANCE OFFICER 

 

In accordance with Information Technology Act 2000 and rules made there under, in case of any complaints or grievances you can contact:

 

michael@foleydesigns.com 

 

In the event you wish to make a complaint regarding any violation of the provisions of the Privacy Policy, you may send a written complaint to the Grievance Officer, who shall redress the complaint within one (1) month.

 

XII. GOVERNING LAW

 

This Policy shall be governed by and construed in accordance with the laws of the Republic of India. The courts at Bangalore, India shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

 

This Privacy Policy was last updated on Jun 21, 2021.

 

Copyright © 2021 Foley Designs Pvt. Ltd. All Rights Reserved

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