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General

EasyTravelDeal has established a set of "Binding Corporate Rules". These Binding Corporate Rules are a commitment by EasyTravelDeal to protect your information regardless of where the data resides. Depending upon where you live, the Binding Corporate Rules may provide additional privacy rights through your local privacy regulator or government. For more information about our Binding Corporate Rules, including information on how to contact us with any questions, write to us at legal@easytraveldeal.com

Traffic Data Collected

We automatically track and collect the following categories of information when you visit our Website:

  • IP addresses
  • Domain servers
  • Types of computers accessing the Website
  • Types of web browsers used to access the Website
  • Referring source which may have sent you to the Website; and
  • Other information associated with the interaction of your browser and the Website (collectively "Traffic Data").

Information Collected from You

In order for you to access certain areas of the Website, we may require you to provide us with certain information ("Personal Information"). Personal Information includes the following information:

  • Your full name, address, e-mail address, telephone number, date of birth and bank or payment card details and any proof of your identity and/or address that we may request;
  • Details of any transactions you carry out through our Website using your easytraveldeal account and of the fulfilment of your requests;
  • Details of any bank account (including but not limited to, account holder, account name, account number, sort code, online banking PIN, Transaction Authentication Number "TAN" and password, available balance and transaction history of your bank account), ITR, TAX certificates or any other income documents as necessary by us;
  • Details of any credit, debit or other card used by you for transactions;
  • Your participation in any promotion sponsored by us;
  • Correspondence that you send us;
  • Calls that we make to you or you make to us;
  • Surveys that you complete through the Website or based on our request;
  • Information collected through cookies. Please see Paragraph I (Cookies) of this Privacy Policy for more details;
  • Your IP address, log-in times, operating system and browser type; and
  • Details of your visits to our Website including, but not limited to, Traffic Data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our Website.
  • In order to fulfil our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies ("Third Party Information"), including your financial history, court judgements and bankruptcies, from credit reference and fraud prevention agencies when you open a easytraveldeal account and at any time when we feel it is necessary to prevent fraud and minimise our financial risks. Please refer to Paragraph 5.2 (Anti-Money Laundering Policy) of this Privacy Policy for further details.

Personal Information and Third Party Information are collectively referred to as "Information".

We use your Information for the following purposes:

  • To operate and administer your easytraveldeal account and to provide services that you have requested;
  • To carry out your instructions to make and receive payments and undertake transactions using our services, including verifying that you have sufficient funds in your easytraveldeal wallet to make such payments;
  • To allow you to participate in interactive features of the Website;
  • To notify you about changes to our service(s);
  • To improve our internal customer training,
  • To comply with financial services regulations including retention of financial information and transactions;
  • For financial and identity checks, fraud prevention checks, anti-money laundering and credit checks;
  • For customer service, including answering questions and responding to feedback and complaints;
  • To enhance the security of our services;
  • To ensure that content on our Website is presented in the most effective manner for you and for your computer; and
  • To provide you with information, products or services that you request from us or which we feel may interest you.

Retention of Data

We are required under applicable laws to retain certain records for a period of at least 5 (five) years after closure of your easytraveldeal account, which will include your personal data such as your name, contact details, customer number and transaction history, etc. ("Retained Data"). Other than the Retained Data, we will delete and destroy all Personal Information that we hold about you when you (or we) terminate your easytraveldeal account. We do not store your online banking login PIN, TAN and/or password.

We do not disclose your Information to any third parties other than the Website's affiliates and the following

  • A prospective buyer of our business or a buyer of a substantial number of the shares in our business;
  • the police, other lawful enforcement body, regulatory body or court if we are under a duty or required by law to disclose or share your personal data , or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others;
  • third parties where you have expressed an interest in receiving information about their goods and services;
  • third parties who referred you to us initially and to whom we owe a commission payment as a result of the referral. Where the commission payment is based on transaction volumes, numbers or types of transactions, we may share that information with that third party, but we will not disclose the full details of each of your transactions without your further written consent; and
  • third parties we may occasionally use to provide you with the services that you have requested. We require these third parties to not use your personal information for any other purpose.

We also use Information in aggregate form (so that no individual user is identified):

  • Report such transaction to the applicable central, state, provincial or local authorities and law enforcement agencies
  • De-activate or terminate your EasyTravelDeal account forthwith.
  • Withhold any funds held in your EasyTravelDeal wallet
  • Restrict you from registering an EasyTravelDeal account on or with our Website or any of our affiliated websites.

Fraud and Credit Agencies

When you open EasyTravelDeal account at intervals of up to every 3 (three) months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your EasyTravelDeal account, financial history and transactions as part of our normal business operations with banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies (including, but not limited to) to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. We can provide you with a list of the credit reference agencies we use upon your written request to EasyTravelDeal Helpdesk. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to them to request access to your information.

In order to comply with anti-money laundering laws that exist in various jurisdictions we reserve the right to report suspicious transactions to federal, state, provincial or local authorities and law enforcement agencies within those jurisdictions. In exchange for us permitting you to participate in, use and access our Website and services you hereby grant us the right to report any transactions which we deem suspicious, as determined solely by EasyTravelDeal acting in its sole discretion. Examples of a suspicious transaction include but are not limited to use of funds suspected to be derived from illegal activities, any suspected intention to conceal or disguise funds derived from illegal activities, or suspicion that the involvement of our Website and services is in any manner intended to facilitate criminal activity. If for any reason we are of the belief or become aware of any transaction which we deem suspicious in nature, we may without prior notice or explanation to you take the following actions, which are in addition to all other rights and remedies available to us under this Privacy Policy, at law or in equity:

  • To build up marketing profiles;
  • To aid strategic development;
  • To audit usage of the Website

Communications

We may contact you via the e-mail address and phone number registered with your easytraveldeal account. You may also receive system-generated transactional e-mails such as confirmations, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your easytraveldeal account. You expressly consent to receive such communications from us, irrespective of whether your phone number is registered on the National Do Not Call Registry.

As easytraveldeal account holder, you will occasionally receive information by e-mail from us, unless you have expressly chosen not to receive such communication, about products, services and special deals which we think will be of interest to you via our newsletter. You can change whether or not you receive newsletters from us. However please note that you will still receive communication regarding your easytraveldeal account such as transactional e-mails or other notifications affecting the operation of your easytraveldeal account or our legal relationship.

Phishing

Phishing is the name given to attempts to steal personal details and financial account details from a website user. "Phishers" use fake or "spoof" emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, user names and passwords.

If you receive such an e-mail or are asked for your password by anyone claiming to work for us please forward the e-mail or report the incident by e-mail to our Data Protection Officer.

Links to Our Website and to Other Websites

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own terms of use and privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Please also note that the products and services offered on these websites may be limited to persons located or residing in only that particular jurisdiction. In addition, the content on these linked websites may not be intended for persons located or residing in jurisdictions that restrict the distribution of such content.

Our Website also includes social media features, such as the Facebook Like button and widgets, such as the "Share this" button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our Website, and may set a Cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

You must always obtain the prior written approval of easytraveldeal before creating a hyperlink in any form from a third party website to any webpage on the easytraveldeal Website. easytraveldeal may or may not give such approval at its absolute discretion. In normal circumstances, we may only approve a hyperlink which displays plainly our name or website address. Any use or display of our logos, trade names and trademarks as a hyperlink will not be approved unless in very exceptional circumstances and may be subject to a fee as easytraveldeal may determine at its absolute discretion. easytraveldeal is not responsible for the setup of any hyperlink from a third party website to any easytraveldeal website. Any links so set up shall not constitute any form of co-operation with, or endorsement by, easytraveldeal of such third party website. Any link to our website shall always be an active and direct link to our website and shall be made directly to the home or front page of our website only and no "framing" or "deep-linking" of any webpage of our Website or content is allowed. Please contact easytraveldeal Helpdesk if you wish to create a hyperlink to any page of our Website on a third party website.