Effective
October 15, 2005 Your
privacy is very important to Travelguru ("we"
or "us"). This Privacy Policy describes the
principles and practices that apply to Personal Information
(defined below) collected from users of our services ("you")
on our Site, in telephone or e-mail communications, or
in interviews, surveys, sweepstakes, contests, or raffles.
Simply put:
We will not collect Personal Information without your
knowledge and permission;
We will not knowingly disclose your Personal Information
to third parties, except as provided in this Privacy
Policy
We will allow you to view, correct or remove your Personal
Information and
We will take reasonable steps to protect the security
of the Personal Information we collect from you.
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Definitions
In this Privacy Policy, terms that commence with a capital
letter are defined in this Section or in the preamble.
"Guest" means an individual who can search
and purchase Products or Services on the Site without
being a Member.
"Member" means an individual who has registered
with the Site. Members choose a Member ID and a password.
"Member ID" means the e-mail address you
use (with your password) to login to our Site.
"Travelguru" or "we" means Travelguru
and its subsidiaries and affiliates.
"Personal Information" means any information,
recorded in any form, about an identified individual,
or an individual whose identity may be inferred from
the information. This includes, for example, name, e-mail
and mailing address and telephone number, billing and
account information, and other information incidental
to providing Products or Services (including information
about individuals traveling with you).
"Products or Services" means the airline
travel, hotel accommodation, car rental, ground transportation,
tours, theater tickets, attractions, travel insurance,
care alerts, and other items available from the Site.
To "Purchase" means to book, reserve or purchase.
"Session Data" means usage information, such
as the type of Internet browser and operating system
an individual use, the domain name of the site from
which the individual came, the date, time and duration
of the visit, number of visits, average time spent on
the individual's site, pages viewed, domain name of
the individual, and number of cookies accumulated.
"Site" means the www.travelguru.com site
and/or the www.travelguru.co.in site, and their respective
sub sites together with the respective content, Products
and Services available from these sites and sub sites.
"Subscriber" means an individual who elects
to receive offers or promotions from Travelguru without
becoming a Member or a Guest.

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Consent
BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY
USING OUR SITE, YOU AGREE THAT WE MAY COLLECT, USE AND
DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH
THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY
LAW.
If you do not agree with these terms, do not provide
any Personal Information to us. If you refuse or withdraw
your consent, or if you choose not to provide us with
any required Personal Information, we may not be able
to provide you with Products or Services that can be
offered on our Site only if we have access to certain
Personal Information.
Minors
Minors (as defined under the laws of their jurisdiction
or residence) are not eligible to register for, use,
or Purchase the Products or Services available on our
Site. We do not knowingly collect Personal Information
from any Minor, and will not use this information if
we discover that it has been provided by a Minor.
Other Travelers or Contacts
If you Purchase Products or Services for other travelers
using your Member ID and password, or if you provide
us with contact information of a third party for Care
Alerts, you must make sure that you have the right to
do so. By providing the Personal Information of another
traveler, you represent that you have all necessary
authority and/or have obtained all necessary consents
from such person to enable us to collect, use and disclose
his or her Personal Information as set forth in this
Privacy Policy.

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How we use the information we collect
We use Personal Information in order to provide and
enhance the Products or Services offered on our Site:
To record your travel preferences, to make reservations
or acquire travel insurance on your behalf, or to communicate
with you about your travel plans
To issue invoices, administer accounts, collect and
process payments
To provide tips or guidance on how to use our Site,
inform you of new features on our Site, or provide other
information that may be of interest to users
To personalize the service we provide to you, tailor
your experience at our Site to your interests and make
more appropriate travel recommendations
To send you e-mails, e-newsletters, personalized offers
via direct messaging or other communications about our
services, if you have subscribed to receive this information
To manage our Site, diagnose technical problems, improve
content, and allocate the resources of our systems so
that your experience with our Site is as efficient as
possible
To process and track your transactions and to send you
information about our and our affiliates' and business
partners' products and services and other information
and materials that may be of interest to you
To develop, enhance, market, sell or provide Travelguru's
Products or Services, or those of companies with which
we have a commercial relationship, but only if you have
granted us permission to do so
To evaluate credit standing and to match credit bureau
or credit reporting agency information; to investigate,
detect and protect Travelguru and other third parties
against error, negligence, breach of contract, fraud,
theft and other illegal activities
To effect a corporate transaction, in connection with
the sale, merger, spin-off, or other corporate reorganization
of our corporation, where the information is provided
to the new controlling entity in regular course of business
To audit compliance with our policies and contractual
obligations
As permitted by, and to comply with, any legal or regulatory
requirements or provisions; or
For any other purpose to which you consent.
Aggregated Information
Aggregated information is information, recorded in any
form, about more than one individual, where the identity
of the individual is not known, and cannot be inferred
from the information. We may use aggregated information
to describe our user base to current or potential partners
investors and advertisers; after a survey, to understand
and respond to market needs and preferences; or to make
recommendations to other users of our Site. For example,
if users of our Site who have traveled to a particular
destination told us that they had positive experiences
at a hotel in that destination, we might recommend that
hotel.

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To whom we disclose Personal Information
From time to time, we may disclose your Personal Information
as follows:
To those travel service providers with which you make
arrangements through our Site, for example, airlines,
car rental, hotel, ground transportation, theater, attraction,
or travel insurance. We provide them with the Personal
Information needed to make and complete the purchase,
booking, or reservation.
To organizations that perform services for or on behalf
of Travelguru, for example to provide customer service,
deliver tickets, ship items, process credit cards, for
research, marketing, data processing, to measure the
use of our Site, to facilitate usage by a Visitor, or
to offer credit card services or evaluate your creditworthiness.
We will share with these companies only that Personal
Information which they need to work on our behalf. Some
of these service providers may be located in other countries.
Your Personal Information will be provided to these
organizations only if they agree to use such information
solely for the purpose of providing services to Travelguru,
and under the instructions of Travelguru, and with respect
to that information, to act in a manner consistent with
the relevant principles articulated in this Policy.
We may collaborate with other companies to offer you
additional Products or Services, for example, through
sweepstakes, raffles, and promotions. We will share
Personal Information that is necessary for these other
companies to provide the Products or Services that you
have requested.
This policy will not cover the use of your Personal
Information by these other companies. We encourage you
to read a company's privacy policy before requesting
any of its products or services.
We may also disclose your information to our affiliates
and non-affiliated business partners for their use both
on our behalf and for their own business purposes. For
example, our affiliates and business partners may use
such information to send you information about their
products, services, other information, and materials
that may be of interest to you.
To protect our Site and our rights under our Terms and
Conditions of Use; to protect ourselves against liability
or prevent fraudulent activity; or where it is necessary
to permit us to pursue available remedies or limit any
damages that we may sustain.
To effect a corporate transaction, in connection with
the sale, merger, spin-off, or other corporate reorganization
of our corporation, where the information is provided
to the new controlling entity in regular course of business.
Where the information is public:
To our insurers and to regulatory agencies

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How we retain and store Personal Information
My Trips contains information about your current, canceled,
or past trips.
My Account contains your name, e-mail address, password,
and departure city from which you usually travel. It
may also contain other information so that you do not
need to re-enter it each time you Purchase a Product
or Service. For example, My Account may contain your
billing information unless you tell us not to store
it. It may also contain your preferences for seat selection
or special meals, details about your participation in
loyalty or awards programs and applicable membership
numbers, and other travel preferences.
We also keep in My Account all other information that
you have elected to provide us, such as gender, favorite
activities and lifestyle preferences, and favorite destinations.
Retention and storage
We will retain your Personal Information in our databases
in accordance with our document management, retention
and destruction policy and applicable laws. This period
may extend beyond the end of your relationship with
us, but it will be only as long as it is necessary for
us to have sufficient information to respond to any
issues that may arise later. For example, we may need
or be required to retain information to allow you to
obtain credit for trip your Purchased but had to cancel.
We may also need the retain certain information to prevent
fraudulent activity; to protect ourselves against liability,
permit us to pursue available remedies or limit any
damages that we may sustain; or if we believe in good
faith that a law, regulation, rule or guideline requires
it.
Your Personal Information will be stored in secured
locations, and on servers controlled by Travelguru,
located either at our offices, or at the offices of
our service providers, as described in How we protect
Personal Information.
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How we protect Personal Information
Travelguru employs physical, administrative and technical
safeguards to help protect the confidentiality and integrity
of Personal Information and to reduce the risk of loss,
misuse, unauthorized access disclosure or modification
of Personal Information. When Personal Information is
sent to our service providers, we require, in our contracts
with them, that they protect all Personal Information
in a manner consistent with the principles articulated
in this Privacy Policy.
If you choose to contact Travelguru through the Site,
you should be aware that any information transmitted
electronically via the World Wide Web might not be secure.
Travelguru assumes no liability for the loss of any
information that you transmit to us via the World Wide
Web. However, should you choose to pay by credit card
when making a booking, reservation or purchase on the
Site, your card details are encrypted for the transaction.
In communicating with you, we may send e-mail as unencrypted
plain text because we are aware that most Members, Guests,
or Subscribers cannot readily process encrypted e-mail.
This is done for your convenience, but with the security
concern that, if misrouted or intercepted, it could
be read more easily than encrypted e-mail.
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Changes to the Privacy Policy
We may change or supplement this Privacy Policy from
time to time. We may also undergo a change of ownership.
We will post an appropriate notice of changes to the
Privacy Policy and changes or ownership on our Site.
Pirvacy Policy changes will apply to the information
collected from the date we post the revised Privacy
Policy to the Site, as well as to existing information
held by us.
If we decide to change this policy in a material way,
we will obtain the necessary consents required under
applicable privacy laws if we seek to collect, use or
disclose Personal Information for purposes other than
those to which consent has been obtained, unless otherwise
required or permitted by law. If any proposed change
is unacceptable to you, you may request that we remove
your Personal Information (and/or that of other individuals
for whom you made travel reservations or who have received
your Care Alerts) from our records.
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Disputes
If any dispute arises between you and Travelguru during
your use of the Site or thereafter, in connection with
the validity, interpretation, implementation or alleged
breach of any provision of the Terms and Conditions,
the dispute shall be referred to a sole Arbitrator who
shall be an independent and neutral third party identified
by Travelguru. The place of arbitration shall be Mumbai.
The arbitration proceedings shall be in the English
language.
The Terms and Conditions shall be governed and construed
in accordance with the laws of India

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