Privacy Policy
1. Privacy Policy Overview
1.1 By browsing and/ or using this website, you agree to have read and understood the terms and conditions recorded in this Privacy Policy. Further, when utilising the services offered by this website, you will be asked to explicitly give your consent by clicking on the “I accept/ I agree/ I authorize” tab. On your acceptance, the terms and conditions of this Privacy Policy will manage and regulate your information and/ or other related data shared with us for the transaction. The terms and conditions stipulated herein shall be binding between you and Suite Guru Pvt Ltd(hereinafter referred to as “SGPL”)
1.2 This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 (“IT Act”) and the rules made thereunder and other applicable laws prevailing in India. This Privacy Policy does not require any physical, electronic or digital signature.
1.3 This Privacy policy is being published in compliance of Section 43A of the Information Technology Act, 2000 (“IT Act”); Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”); and Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
1.4 This Privacy Policy shall apply to all current and former users accessing or using Our Platform, or otherwise engaging with us through email or other means.
1.5 By providing us your information or by making use of the facilities provided by this website, you hereby unconditionally consent to the collection, storage, processing, and transfer of any or all of your personal information and non-personal information by SGPL, as specified under this Privacy Policy. Further, you hereby undertake that such collection, use, storage, and transfer of your information shall not cause any loss to SGPL or wrongful gain to you or any other person.
1.6 That the SGPL is concerned about the privacy of the data and information of users (including buyers/customers whether registered or non-registered) accessing or availing services on SGPL website i.e. http://www.wanderlustamerica.com mobile sites or mobile applications on this website and otherwise doing business with SGPL.
1.7 If You are accessing or using the Platform from any location outside India, You do so at Your own risk, and will be solely liable for compliance with any local laws, as may be applicable.
2. Information and Storage
2.1 SGPL websites/applications/microsites and any other related links, do not automatically capture any specific personal information from you, (like name, phone number or e-mail address), that allows us to identify you individually. If the Portal requests you to provide personal information, you will be informed for the particular purposes for which the information is gathered and adequate security measures will be taken to protect your personal information. We receive information that a) You directly provide to Us such as personal information You provide when You visit the Website/mobile application, b) information/files/documents/data that you share with other users on the Website/mobile application, and c) information that is passively or automatically collected from You, such as information collected from the browser or device You used to access Our Website or Services. In this Privacy Policy, we refer to all this as the ‘User Information’.
2.2 SGPL do not automatically capture any specific personal information from you, (like name, phone number or e-mail address), that allows us to identify you individually. If the Portal requests you to provide personal information, you will be informed for the particular purposes for which the information is gathered and adequate security measures will be taken to protect your personal information.
2.3 Information You Provide To Us. There are portions of this Website/ Application where We may need to collect personal information from You for a specific purpose. In the course of these various offerings, We often seek to collect from You various forms of information, such as: name, address, e-mail address, telephone number, fax number and business details.
2.4 Information That is Automatically Collected. In general, You can visit this Website without telling Us who You are or revealing any information about Yourself. We, and Our third party service providers or other partners (collectively ‘Partners’) may use automated means to collect various types of Information about You, Your computer or other device used to access Our Website. A representative, non-exhaustive list of the types of automatically collected information may include: network or Internet protocol address and type of browser You are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system You are using, (e.g., Microsoft Windows or Mac OS), mobile network, device identifiers, device settings, browser settings, the web pages of the Website You have visited, Website visited before and after You visited our Website, the type of handheld or mobile device used to view the Website (e.g., iOS, Android), location information, and the content and advertisements.
2.5 The SGPL may gather certain information about the User, such as Internet protocol (IP) addresses, domain name, browser type, operating system, the date and time of the visit and the pages visited. We make no attempt to link these addresses with the identity of individuals visiting our site unless an attempt to damage the site has been detected.
2.6 The SGPL is not responsible for any information/data, personal information shared by you with any other user or third-party on the Website/Mobile Application.
2.7 Non-personal information may be collected through the use of cookies. SGPL may store temporary or permanent cookies on your computer. “Cookies” are small files placed on your hard drive that would assist SGPL in providing our services. SGPL offers certain features that are only available through the use of a “cookie”. SGPL also uses cookies to allow you to enter your password, less frequently during a session. Cookies would help SGPL to 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 this website and you may be required to re-enter your password more frequently during a session. You can erase or choose to block these cookies from your computer. You can configure your computer’s browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie. If you have turned cookies off, you may be prevented from using certain features of this website. Additionally, you may encounter “cookies” or other similar devices on certain pages of this website that are placed by third parties. We do not control the use of cookies by third parties.
2.8 You hereby represent to SGPL that:
i. the information provided by you to SGPL from time to time is, and shall be authentic, correct, current, and updated and you have all the rights, permissions, and consents as may be required to provide such information to SGPL.
ii. The information provided by you to SGPL, and SGPL consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third party agreement, laws, charter documents, judgments, orders and decrees.
2.9 SGPL does not intend to collect or otherwise process any sensitive personal information for legitimate purpose and in the event same is used, SGPL undertakes to use the information in accordance with applicable law.
3. Purpose of Collecting Information
3.1 SGPL collects, uses, stores, and processes your information for any purpose as may be permissible under applicable laws (including where the applicable law provides for such collection, usage, storage or processes in accordance with the consent of the user) connected with a function or activity of SGPL and shall include the following:
i. To facilitate your use of this website or other services of SGPL;
ii. To respond to your inquiries or fulfil your requests for information about the various services offered on this website;
iii. To provide you with information about services available on this website and to send you information, materials, and promotional offers from SGPL;
iv. To send you important information regarding this website, changes in terms and conditions, user agreements, and policies and/or other administrative information;
v. To send you surveys and marketing communications that SGPL believes may be of interest to you;
vi. To personalize your experience on this Website by presenting advertisements, products and offers tailored to your preferences;
vii. To help you address your problems faced on this Website including addressing any technical problems;
viii. If you avail of any service from this Website, to complete and fulfil your purchase, for example, to have your payments processed, communicate with you regarding your purchase and provide you with related customer service;
ix. For proper administering of this Website;
x. To conduct internal reviews and data analysis for this website (e.g., to determine the number of visitors to specific pages within this website);
xi. To improve the services, content and advertising on this website;
xii. To provide value added services;
xiii. To facilitate various programmes and initiatives launched by SGPL or third party service providers and business associates;
xiv. To analyze how our services are used, to measure the effectiveness of advertisements, to facilitating payments;
xv. To conducting academic research and surveys;
xvi. To protect the integrity of this website;
xvii. To respond to legal, judicial, quasi-judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law;
xviii. To conduct analytical studies on various aspects including user behaviour, user preferences etc.;
xix. To permit third parties who may need to contact users who have transacted through this website to facilitate installation, service and any other product related support;
xx. To implement information security measures;
xxi. To determine any security breaches, computer contaminant or computer virus;
xxii. To investigate, prevent, or take action regarding illegal activities and suspected fraud;
xxiii. To undertake forensics of the concerned computer resource as a part of investigation or internal audit;
xxiv. To trace computer resources or any person who may have contravened, or is suspected of having or being likely to contravene, any provision of law/guidelines including the IT Act.
xxv. To enable a potential buyer or investor to evaluate the business of SGPL. The above are collectively referred to as “Purposes”.
3.2 You hereby agree and acknowledge that the information so collected is for lawful purpose connected with a function or activity of SGPL or any person on their respective behalf, and the collection of information is necessary for the Purposes.
4. Security
4.1 The security of your information is important to us. SGPL strives to ensure the security of personal information and to protect your personal information against unauthorized access or unauthorized alteration, disclosure or destruction. For this purpose, SGPL adopts internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where SGPL stores your personal information. SGPL shall adopt reasonable security practices and procedures as mandated under applicable laws for the protection of your information. Provided that your right to claim damages shall be limited to the right to claim only statutory damages under IT Act and you hereby waive and release SGPL from any claim of damages under contract or under tort.
4.2 We may share your information with third parties under a confidentiality arrangement which inter alia provides for that such third parties not disclosing the information further unless such disclosure is for the Purposes. However, SGPL is not responsible for any breach of security or for any actions of any third parties that receive your personal information. SGPL is not liable for any loss or injury caused to you as a result of you providing your personal information to third party (including any third party websites, even if links to such third party websites are provided on this Website).
4.3 We may implement technical and organizational security measures to protect your information. Please ensure that any personal information that you send to us is sent securely.
4.4 In certain instances we may transfer certain information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
4.5 Notwithstanding anything contained in this Privacy Policy or elsewhere, SGPL shall not be held responsible for any loss, damage or misuse of your personal information, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below). A “Force Majeure Event” shall mean any event that is beyond the reasonable control of SGPL and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption, power or electricity failure or unavailability of adequate power or electricity.
4.6 While we will endeavour to take all reasonable and appropriate steps to keep secured any personal information which we hold about you and prevent unauthorized access, you acknowledge that the internet or computer networks are not fully secured and that we cannot provide any absolute assurance regarding the security of your personal information. Please note that ensuring security of your information is only an endeavour and shall not be construed as an obligation on the part of SGPL. You agree and acknowledge that the information available/collected online runs an inherent risk of being stolen or leaked or infringed.
4.7 Because the internet is an open system, the transmission of information via the internet is not completely secured. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any personal information that you send to us are sent securely.
4.8 You agree that all personal information shall be retained till such time required in reasonable view of SGPL. Non-personal information will be retained indefinitely.
5. Sharing and Disclosure
5.1 You hereby unconditionally agree and permit that SGPL may transfer, share, disclose or part with all or any of your information, within and outside of the Republic of India to any third party service providers/partner/collaborators /associates/banks and financial institutions for one or more of the Purposes or as may be required by applicable law. In such case, we will contractually oblige the receiving parties of the information to ensure the same level of data protection that is adhered to by SGPL under the applicable law.
5.2 SGPL may share statistical data and other details without your express or implied consent to facilitate various programmes or initiatives launched by SGPL, its affiliates, agents, third party service providers, partners or banks & financial institutions, from time to time. SGPL may transfer / disclose / share information to those parties who support our business, such as providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertisements, providing customer / buyer services, facilitating payments, or conducting academic research and surveys. These affiliates and third party service providers shall adhere to confidentiality obligations consistent with this Privacy Policy.
5.3 We may also share personal information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of various terms and conditions or our policies.
5.4 We reserve the right to disclose your information when required to do so by law or regulation, or under any legal obligation or order under law or in response to a request from a law enforcement or governmental agency or judicial, quasi-judicial or any other statutory or constitutional authority or to establish or exercise our legal rights or defend against legal claims.
5.5 You further agree that such disclosure, sharing, and transfer of your information shall not cause any wrongful loss to you or to any third party, or any wrongful gain to us or to any third party.
6. Third Party Websites
6.1 Links to third-party advertisements, third-party websites and/or any third party electronic communication service may be provided on this website which are operated by third parties and are not controlled by, or affiliated to, or associated by/ with SGPL, unless expressly specified on this website.
6.2 We are not responsible for any form of transmission, whatsoever, received by you from any third party website. Accordingly, SGPL does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such third party websites, nor does SGPL control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such third party websites. The inclusion or exclusion does not imply any endorsement by SGPL of the third party websites, the website’s provider, or the information on the website. The information provided by you to such third party websites shall be governed in accordance with the privacy policies of such third party websites and it is recommended that you review the privacy policy of such third party websites prior to using such websites.
7. International Transfers of Information
7.1 Because of the international nature of our business, we may need to transfer your information with our group companies and to third parties, in connection with the purposes set out in this Privacy Policy. For this reason, we may transfer your information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
8. Data Accuracy
8.1 SGPL shall take every reasonable step to ensure that your information that is processed, is accurate and, where necessary, kept up to date, and any of your information that we process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified.
9. Data Minimisation
9.1 SGPL shall take every reasonable step to ensure that your information that is processed is limited to the information reasonably necessary in connection with the purposes set out in this Privacy Policy or as required to provide you services or access to the services available on this Website.
10. Data Retention
10.1 SGPL shall take every reasonable step to ensure that your information is only retained as long as they are needed. The criteria for determining the duration for which SGPL will keep your information are as follows:
i. we will retain copies of your information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Privacy Policy, unless applicable law requires a longer retention period.
ii. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfil a legitimate business need.
11. Discretion
11.1 You agree and acknowledge that you are providing your information out of your free will. You have an option not to provide or permit SGPL to collect your personal information or later on withdraw your consent with respect to such personal information so provided herein by sending an email to the grievance officer or such other electronic address of SGPL as may appear on this website. In such case, you should neither visit this website nor use any services provided by SGPL. Further, SGPL may deny you access from using certain services offered on this website.
11.2 You can also directly take steps to unsubscribe to the newsletters that you receive from us. Please allow thirty (30) to forty five (45) business days for change to take effect. If you are an EU resident, you may have certain rights including: the right not to provide your personal information to us; the right to access your personal information; the right to request erasure, or restricting of Processing of your personal information; the right to have your personal information transferred to another controller; the right to withdraw your consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
12. Copyright Policy
The contents of this website may not be reproduced partially or fully, without due permission from SGPL. If referred to as a part of another publication, the source must be appropriately acknowledged. The contents of this website cannot be used in any misleading or objectionable context.
13. Disclaimer
We cannot ensure that all of Your Information including Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although We are committed to protecting Your privacy, We do not promise, and You should not expect, that Your Information or private communications will always remain private. As a user of the Platform, You assume all responsibility and risk for Your use of the Platform, the internet generally, and the information You post or access and for Your conduct on the Platform
14. Governing law and Jurisdiction
This Privacy Policy is governed by and operated in accordance with the laws of India. If any of the parties wish to seek legal recourse, they may do so by using the courts of law in GautamBudhNagar/Noida, Uttar Pradesh.
15. Changes to the Privacy Policy
15.1 From time to time, we may make changes to this Privacy Policy. Please check our Privacy Policy on a regular basis.