Privacy Policy

INTRODUCTION

This Privacy (“Policy”) applies to the securing and processing of personal data by airnexia.com (owned by Telspace LLC, USA) in connection with personal data provided by any person (“User”) who has purchased or intends to purchase or inquiries about any product(s) or service(s) made by airnexia.com through any of airnexia.com interface channels including website, mobile site and mobile app (collectively referred herein as “Sales Channels”).

For the purposes of this Privacy Policy:

• References in this policy to “you” or “your” are references to the ‘User’
• References to “we”, “us” or “our” are references to ‘airnexia.com’
• References to “website” mean a reference to ‘website(s)’, ‘mobile site(s)’ and mobile app(s)

By accessing or using the website or any other sales channel, the User agrees with the term of the Privacy Policy and the contents herein. If you disagree with the Privacy Policy, please do not access or use our website or any other Sales Channels.

This privacy policy does not apply to any third-party website(s), mobile site(s) and mobile app(s). Users are requested to take note that information and privacy practices of airnexia.com business partners, advertisers, sponsors or other sites to which airnexia.com provides hyperlink(s), may be different from this privacy policy. Hence, it is recommended that you review the privacy policy of any such third parties before you interact.

Your privacy is important to us, and we recognize that the use and disclosure of personal data has important implications for us and for the users whose personal data we process.

PURPOSE OF THIS POLICY

We respect your need to understand how and why information is being collected, used, disclosed, transferred and stored. Thus, we have developed this Policy to familiarize you with our practices. This policy sets out the way in which we process your information (when you use our Website or other digital platforms) in accordance with applicable data protection laws. It is important that you read this policy together with any other policies we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. This policy supplements the other notices and is not intended to override them.

DEFINING CONTROLLER & PROCESSOR OF PERSONAL DATA

A “Controller” is a person or organization who alone or jointly determines the purposes for which, and the way any personal data is, or is likely to be, processed. This notice is issued on behalf of airnexia.com as controller.

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

As the circumstances warrant, airnexia.com may be Controller or Processor of your personal data.

TYPE OF PERSONAL DATA WE COLLECT

Personal data includes any information about any user from which that person can be identified. It does not include personal data where the identity has been removed (anonymous data).

You may be asked for personal data anytime you are in contact with airnexia.com directly or indirectly through a third party.

We collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

We do not collect any special categories of personal data about you through our Website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, data on or about children). Nor do we collect any information about criminal convictions and offences.

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this Notice:

• Contact Data: including your residential address, work address, email address and telephone numbers.
• Identity Data: including your first name, last name, username or similar identifier, title.
• Website User Data: Usernames, Passwords and other security related information used by you in relation to our services.
• Transaction Data: Transactional history about your e-commerce activities, buying behaviour. Information pertaining to any other traveller(s) for whom you made a booking through your registered airnexia.com account.
• Marketing and Communications Data: including your marketing and communication preferences. We also track when you receive and read marketing communications from us.
• Public Domain or Third Party Data: Data available in public domain or received from any third party including social media channels.
• Profile Data: including information collected progressively when you visit our site including your referral website, pages you visit, actions you take, patterns of page visits and information from forms you fill in.
• Technical Data: includes information collected when you access our website, mobile site or mobile app your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using;
• Usage Data: information about how you use our website.
• Any other Personal Data: If you request airnexia.com to provide visa related services, then copies of your passport, bank statements, originals of the filled in application forms, photographs, and any other information which may be required by the respective embassy to process your visa application.

MODES OF COLLECTING PERSONAL DATA

The only way we will get any kind of personal data is if you choose to give it to us in the following circumstances:

• Direct Interactions: When you make an enquiry or quotation request or make a reservation or purchase from our ‘Website’ or through our customer service team - by email(s), letter(s), fax, on the phone or in physical store.
• Cookies & other technologies: We receive Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see cookie policy for further details of the information collected.
• Third parties or publicly available sources: We receive Technical Data from analytics providers such as Google.

GROUNDS FOR PROCESSING OF DATA

When you use our Website, we will use your personal data in the following circumstances:

• Performance of a contract: where we need to perform a contract which we are about to enter into or have entered into with you as a party or to take steps at your request before entering into such a contract.
• Legal or regulatory obligation: where we need to comply with a legal or regulatory obligation that we are subject to.
• Legitimate interests: where necessary for our interests provided that your fundamental rights do not override such interests.
• Consent: We rely on consent as a legal basis for processing your personal data in relation to sending direct marketing communications to you via email or text message.

USE OF PERSONAL DATA

We will only process (i.e. use) your personal data when the law allows us to, that is, when we have a legal basis for processing. We generally use the information to establish and enhance our relationship with our users for the following purposes:

• While you make a booking: We may use your Personal Information available with us to ease your booking process.
• We may also use your Personal Information for several reasons including but not limited to: keep you informed of the transaction status, send booking confirmations either via SMS or WhatsApp or any other messaging service.
• We may share your personal data with third parties for reasons cited below but not limited to: Where it is necessary to process your booking, enquiry or participation.

Collection and Use of Non-Personal Data

Non-personal data is data which can never be used to identify an individual. We may collect information regarding customer activities on our various portals. This aggregated information is used in research, analysis, to improve and monitor products and for various promotional schemes. It may be shared in aggregated, non-personal form with third party to enhance customer experience, products offering or services.

Cookies and Other Technologies

We use cookies and other technologies to enhance your experience when you use our Website. To that effect, we have developed a cookie policy to familiarize you with our practices. You can access the cookie policy.

Links

For your convenience, our website provides links to other sites. When you click on one of these links, you are leaving our website and entering another site. We are not responsible for such third-party sites. You should carefully review the privacy statements of any other sites you visit, because those privacy statements will apply to your visit to such other sites.

With Whom Your Personal Data is Shared

Group Companies (Companies in the same group):

In the interests of improving personalization and service efficiency, we may, under controlled and secure circumstances, share your Personal Information with our affiliate or associate entities. If the assets of airnexia.com are acquired, our customer information may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, as part of business expansion/development/restructuring or for any other reason whatsoever, if we decide to sell/transfer/assign our business, any part thereof, any of our subsidiaries or any business units, then as part of such restructuring exercise customer information including the Personal Information collected herein shall be transferred accordingly.

Service Providers and suppliers:

Your information shall be shared with the end service providers like airlines, hotels, visa consulates, bus service providers, cab rental, railways or any other suppliers who are responsible for fulfilling your booking. You may note that while making a booking with airnexia.com you authorize us and consent to share your information with the said service providers and suppliers. It is pertinent to note that airnexia.com does not authorize the end service provider to use your information for any other purpose(s) except as for fulfilling their part of service.

Third Party Vendors and Business Partners:

We may also share certain filtered Personal Information to our corporate affiliates or business partners who may contact the customers to offer certain products or services, which may include free or paid products/services, which will enable the customer to have better travel experience or to avail certain benefits specially made for airnexia.com customers. Examples of such partners are entities offering savings/EMI on travel, co-branded credit cards, travel insurance, insurance cover against loss of wallet, banking cards or similar sensitive information etc. If you choose to avail any such services offered by our business partners, the services so availed will be governed by the privacy policy of the respective service provider.

Disclosure of Information

Where required, we will (subject to our professional obligations and any terms of business which we may enter with you) disclose your personal data to:

• Any person or entity to whom we are required or requested to make such disclosure by any court of competent jurisdiction or by any governmental, taxation or other regulatory authority, law enforcement agency or similar body;
• Our professional advisers or consultants, including lawyers, bankers, auditors, accountants and insurers providing consultancy, legal, banking, audit, accounting or insurance services to us; and
• Service-providers who provide information technology and system administration services to us.

International Transfer

Due to the multinational character of airnexia.com, some of the affiliated companies and other recipients may be in countries (including the United States) that do not provide a level of data protection equivalent to that set forth by the law in your home country. airnexia.com will take steps to make sure that such recipients act in accordance with applicable law and provide an adequate level of protection for your personal data including appropriate technical and organizational security measures, also through implementation of appropriate contractual measures to secure such transfer, in compliance with the applicable law.

User Generated Content

airnexia.com provides an option to its users to post their experiences by way of reviews, blog articles, ratings and general poll questions. The customers also have an option to give their feedback or ask questions w.r.t a service offered by airnexia.com or post answers to questions raised by other users. airnexia.com may also engage a third party to contact you and gather your feedback about your recent booking with airnexia.com. Though the participation in the feedback process is purely optional, you may still receive emails, notifications (app, SMS, WhatsApp or any other messaging service) for you to share your review(s). These reviews may be written (with or without images) or in video format. The reviews written or posted will be visible on airnexia.com and may also be visible on other travel or travel related platforms.

Permissions Required for Using Our Mobile Applications

Android Permissions:

• Location: This permission enables us to give you the nearest branch details from your location in case you require any physical assistance with regards to any travel query.
• SMS: If you allow us to access your SMS, we can send you SMS related to ‘OTP’ and send holiday package details to your mobile number.
• Phone: The app requires access to make phone calls so that you can make phone calls to our customer contact centres directly through the app.
• Contacts: If you allow us to access your contacts, it enables us to provide a lot of social features to you such as sharing holiday packages with your friends, etc.
• Photo / Media / Files: The libraries in the app use these permissions to save and cache images and document data for your ease and faster use of the app while you browse with us the next time.

IOS Permissions:

• Notifications: If you opt in for notifications, it enables us to send across exclusive deals, promotional offers, travel related updates, etc. on your device.

Information Protection and Security

Considering the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing, including:

• The pseudonymisation and encryption of personal data.
• The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
• The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
• A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims.

Changes to the Policy

We reserve the right to update or change this Policy at any time, and we will provide you with the updated policy when we make any substantial updates at the earliest either through email or by providing a prominent notice of change on our website. You should check the policy periodically. Your continued use of our website after we post any modifications to the policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified notice.

Your Rights

Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data. It is our policy to respect your rights, and we will act promptly and in accordance with any applicable law, rule or regulation relating to the processing of your personal data. Details of your rights under General Data Protection Regulation (GDPR) are set out below:

• Right to be informed about how personal data is used
• Right to access personal data
• Right to have inaccurate personal data rectified
• Right to have personal data erased in certain circumstances
• Right to restrict processing of personal data in certain circumstances
• Right to data portability
• Right to object to processing of personal data in certain circumstances
• Right not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect

Complaints

If you have any complaint about how we have handled a Subject Access Request, please let us know and we will try to fix it. You can email the Data Protection Officer (DPO) at dpo@telspace.us. If you are dissatisfied with handling of any privacy complaints, if you do not receive timely acknowledgement of your complaint, or your complaint is not satisfactorily addressed please contact our team at custrelations@telspace.us.

Further Information

If you have any questions about this privacy notice or questions or complaints about the processing of your personal data by airnexia.com, please contact:

Data Protection Officer
Corporate Office
501, Silverside Road, St 105, Wilmington, Delaware-19809, USA
Email: support@telspace.us