INTRODUCTION
The Privacy (“Policy”) is applicable to the protection the processing and protection of your personal information from Spabi Exim (OPC) Private Limited which operates the visafill.com (hereinafter “VisaFill”) visafill.com (hereinafter “VisaFill” with respect to or in connection with personal data supplied by anyone (“User”) that has made a purchase or has inquiries regarding or inquiries about any product(s) or service(s) offered by VisaFill via any of VisaFill’s interface channels, including the mobile website, website and mobile apps (collectively called “Sales channels”).

In the context of this Privacy Policy:

In this policy, references”you” or “you” as well as “your” are reference to “User” references to “we”, “us” or “our” refer to VisaFill when you participate in surveys or give us feedback, references to “website” refers to ‘website(s)”, mobile site(s) and mobile app(s)

PURPOSE OF THIS POLICY

We understand that you need to be aware of how and why data is collected, used as well as disclosed, transferred and stored. This is why we’ve developed this policy to provide you with our procedures. This policy describes the manner in which we use your data when you visit our website and other digital platforms, in line with the applicable laws regarding data protection. It is crucial to review this policy in conjunction with any other guidelines we might provide on certain occasions where we are collecting or processing personal information so that you are aware of the ways and reasons we process your personal information. This policy is in addition to the other notices, and does not intend to supersede these notices.

DEFINING CONTROLLER OF PERSONAL DATA

“Controller “Controller” is an individual or organization that, on their own or in conjunction with others determines the reasons for which, and the way of processing any personal data is or will be processed. This notice is made by VisaFill acting as the controller. Processor is a legal or natural person an agency, public authority or any other entity that manages personal information on behalf of the Controller. When the circumstances warrant, VisaFill could be the the Controller or Processor of your personal information.

TYPE OF PERSONAL DATA WE COLLECT

Personal data refers to any information about an individual that is identifiable. It is not personal data whose identity of the user has been erased (anonymous personal data).

You could be asked for personal information whenever you’re communicating with VisaFill either directly, or via a third party.

We gather, use and share aggregated information like demographic or statistical information for any purpose. The aggregated data could be obtained from your personal information, but it isn’t considered to be personal data under the law since this information doesn’t directly or in any way identify you. For instance, we could combine information from Usage Data to determine the proportion of users using certain features on our website. If we do connect aggregated data to your personal data in a way that it is able to directly or indirectly identify you, we will treat the aggregated data as personal information that is processed according to this policy.

We do not gather any specific types of personal information on you via our website (this includes information on your ethnicity or race as well as philosophical or religious beliefs, sexual orientation gender identity, political views as well as trade union membership details about your health, and biometric and genetic information). We also do not collect information regarding criminal convictions or crimes.

We collect, process to store, transfer and use different types of personal information regarding you. We have put together the below categories of personal information to describe how this kind of data is utilized by us.

These terms are employed all throughout the Notice.

“Contact Data” include your residence address, your work address email address, and phone numbers;

“Identity Data” include your name, username, last name or similar identifier, title

“Website Information about Users” Users’ names, passwords and other security-related information that you use in connection to our services.

“Transaction Data”: Transactional history regarding your online transactions as well as your buying behavior. Information about to any other traveler(s) that you booked via your existing VisaFill account. In the event of such a situation you must verify and confirm that each other traveler(s) who the booking was made and has consented to having the details you share with us with us, and to be communicated by us to the services provider(s). “Marketing Data” and “Communications Data” include your preferences for marketing and communications. We also monitor the time you read and receive our marketing messages and use this information to enhance our marketing offerings and offer you more relevant information and enhance how we present our materials to you. Further information regarding the personal data we use for marketing purposes is provided in the marketing materials we send you.

“Public Domain or Third Party Data” Data that is in the public domain or obtained from any third party, including social media channels, such as but not exclusive to personal or non-personal data from your connected social media accounts (like name email address, friends list, profile images as well as any information permitted to be accessed as according to your account settings) as element of your account details.

“Profile Data” includes information gathered in a continuous manner as you browse our website including the website you refer to pages, the pages you browse and the actions you perform such as patterns of page visit and the information you fill out;

“Technical Data” is information that we collect when you visit our website our mobile site, mobile site or mobile app. This includes your Internet Protocol (IP) address and login information as well as the type of browser and version, your time zone setting and location the type of browser plug-in and their versions, the operating system, platforms and other technologies on the devices you’re using and

“Usage Data” Information about how you use our website.

“Any other personal data” If you want VisaFill to provide visa-related services, you must provide copies of your passport and bank statements, the originals of your filled-in applications, photographs as well as any other information that might be required by the Embassy in charge of processing Visa applications. If you ask VisaFill for services for foreign exchange (forex) or related service, then passport copies, forms A2, airline tickets or an authenticity documents to confirm confirmed travel and any other documents needed to complete your Forex transaction

MODES OF COLLECTING PERSONAL DATA

The only way we can receive any personal information from you is if decide to provide it to us under the following conditions:

Direct interaction:

If you send us an enquiry or request for quotation or request a reservation or purchase through our website or through our customer support team, you can do so via email(s), letter(s) or fax, over the telephone or in the physical stores

When you register with us, subscribe to our newsletter, enter in lucky draws/competitions/surveys/feedback, send us queries or register for promotions

When you interact with us on any online and offline events, promotion or page that we host on a third-party platform or at a specific location

Cookies on our Website

Cookies, as well as other technology:

We gather Technical Data regarding your device browsing habits, patterns and actions. We collect this data via cookies servers logs, cookies and similar technology. Check out our the cookie policy for more details about the data we collect.

Third parties, or publicly accessible sources:

The data we receive is Technical Data from analytics providers like Google

GROUNDS FOR PROCESSING OF DATA

“performance of the terms of a contract”: when we have to fulfill a contract we are planning to enter into together with you, as your participant or take action at your request prior to concluding contract.

“legal or regulatory requirement”: when we have to fulfill an obligation of a regulatory or legal nature that we are obligated to,

“legitimate legitimate interests””legitimate interests” : where it is necessary for our own interests, provided that your fundamental rights don’t override these interest. This could mean that, for example, we have a legitimate best interest to observe the way you use our portals or websites to ensure your security on our website or our client portals or systems are maintained. We will consider the potential impact on your personal data (both positive as well as adverse) as well as your privacy rights prior to we collect your personal information to fulfill our legitimate interest; and

“consent””consent”: We base our decisions on consent as the legal basis to process your personal information for sending direct marketing messages to you by text message or email.

We don’t employ your personal information to carry out actions which are overridden by the consequences for you (unless you give us your permission or are legally allowed or required to do so by the law).

USE OF PERSONAL DATA

We will only use (i.e. make use of) your personal information when the law permits it or when we have an appropriate legal basis to process. The majority of the time, we use this information to establish and improve our relationships with our customers to fulfill the following reasons:

While you are making a booking:

We can make your personal Information provided to us to facilitate your booking process. This could include all data supplied by you in the past i.e. contact data. We also may use the information from your travelers’ list that is available or associated to your account. The information is provided to the user when making a reservation to allow you to make your reservations promptly.

We could also utilize your Personal Information for various reasons, not just to:

Keep you informed about the status of transactions

Send booking confirmations via an SMS, WhatsApp or another messaging service.

Send any changes or updates in your booking(s) let our customer service team to reach you if needed.

Make sure you confirm your reservations with the specific service providers. They will make changes to the content of our mobile site, website and mobile app

Request reviews of products or services, or for any other enhancements, send confirmation message(s) in addition to email(s)

validate/authenticate your account and to prevent any misuse or abuse

Contact you for your birthday or anniversary to present a special present or special offer

Send you important notifications and information concerning our products and services available or any changes to the policies and/or terms and conditions.

Send information on services and products offered through VisaFill or its partners.. VisaFill will also send you payment reminders or travel vouchers

Newsletters that keep you informed about the travel industry. In the event you don’t want to receive this type of information you can unsubscribe from this service in the email you receive.

We may provide your personal data with third parties for the reasons listed below, but not restricted to:

If it is necessary to process your reservation or enquiry, or to process your participation.

To fulfill the service offered or to book or reservation, as well as any other such action initiated by the user.

We may share your personal information with companies that provide services like information processing and credit extension, as well as fulfilling orders from customers, delivering goods to you, coordinating and enhancing customer information as well as providing customer support and evaluating your desire to use our services and products, and conducting customer satisfaction or research surveys. These companies are legally bound to secure your data.

We could use your personal information to conduct Marketing Promotions, Research and other purposes.

If you are a registered user, you will be notified of the latest announcements regarding our services and products promotional offers, special offers and event announcements. If you want to stop receiving our emails you may opt out.

We also may use personal information to enhance our product offerings, develop and offer goods, services and information and even to promote our products.

Personal data can also be used internally to conduct research, analysis, and auditing

VisaFill could from time to start promotions that give its Users the chance to win exciting prizes for travel and related. In these promotions, the personal data we collect might include contact details and survey questions. We will use the details to contact winners of surveys and contests, as well as for product and promotion improvement.

VisaFill might introduce reward or travel programs from time-to-time in which members will be able to win rewards for travel or other benefits. We may utilize your personal information to register you into the rewards program. Based on the rewards program, every time you receive a reward VisaFill will provide your personal data to a third party, who is accountable for the fulfillment of the prize to you. However, you can choose to remove yourself from the reward programs if you decide to opt out. In this regard, when we award anyone, we could verify the information of our customers in a limited manner for different reasons like fraud protection or for other reasons.

COLLECTION AND USE OF NON-PERSONAL DATA

Non-personal information is data that is not employed to locate an person. We might collect information about customer activity on our different websites. The information we collect is used for research, analysis for improving and monitoring products as well as for different promotional strategies. The information may be shared in unrelated, non-personal format with third parties to improve customer service, the products offered or other services.

COOKIES AND OTHER TECHNOLOGIES

We make use of cookies and other technologies to improve the experience you get when using our website. In this regard we have created an official cookie policy that will familiarize you with our procedures. The cookie policy here.

LINKS

To make your life easier Our Website offers hyperlinks to other websites. If you click on an of those links you’re departing our Website and navigating to another website. We are not responsible for these third-party websites. It is important to read the privacy statements on the other websites that you visit, since the privacy statements of those sites will be applicable to your visit on these other websites.

WITH WHOM YOUR PERSONAL DATA IS SHARED:

Group Companies (Companies within that same class):

In the interest of improving the quality of our services and personalization We may, in secured and controlled circumstances provide Your Personal Data with our affiliates or associated entities.

If VisaFill’s assets VisaFill are purchased, our customer data could also be provided to the acquirer, based on the nature of this 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 personal information will be shared with the appropriate service providers such as airlines, hotels bus service companies taxi rental railways, or any other providers responsible to complete your booking. It is important to note that when making a booking through VisaFill you grant us permission and accept sharing your data with those service providers and other suppliers. It is essential to remember that VisaFill does not permit the service provider in charge to make use of your personal information in any way or for another purpose(s) other than providing their services to you. VisaFill does not rent or sell individual names of customers or any other personal information to any third party, with the exception of sharing this information with our business/alliance partner or with vendors contracted by us to provide various services, and to provide promotional and other benefits with our customers on a regular the time based on their booking history with us.

Third Party Vendors and Business Partners:

We may also disclose certain personal information that has been filtered our corporate affiliates and business partners who could contact our customers to promote specific products or services that may include either free or paid goods or services, which allow the customer to enjoy a more enjoyable travel experiences or enjoy certain benefits specifically designed to VisaFill customers. Some examples of these partners are businesses that provide savings/EMI on trips credit cards that are co-branded and travel insurance. They also offer protection against the losing your wallet, banking cards, or other sensitive information and similar sensitive information. If you decide to use the services of one of our partners in business, products used will be governed by the privacy policies of the particular service provider.

VisaFill may provide the information you provide to a any third party VisaFill may contract to carry out certain tasks on behalf of VisaFill such as but not restricted to payment processing, hosting of data and platforms for processing data.

We might provide non-personal information based on these data to advertisers, suppliers and affiliates as well as other existing and prospective business partners. We can also make use of such data in aggregate form to inform third parties of the amount of visitors who have clicked on their websites.

At times, VisaFill will hire a third-party for surveys, market research etc. and will supply information to the third party specifically to use to these projects. The data (including the aggregated cookie and tracking information) we share with these third parties, alliance partners or vendors is protected under confidentiality agreements. This information will be only used for the purpose of completing the particular project and in compliance with applicable laws.

DISCLOSURE OF INFORMATION

When required, we’ll (subject to the professional requirements of us as well as any other terms of business that we may negotiate with you) divulge your personal information to:

any person or entity which we are required or asked to make a information by any judge with competent jurisdiction, or by any taxing, governmental or another regulatory authority or law enforcement organization or similar entity;

our consultants or professional advisers include lawyers, bankers auditors, accountants, and insurance companies that provide consultancy legal, banking, audit accounting, or insurance services to us and

Service providers that provide information technology and administration of systems to us.

USER GENERATED CONTENT

VisaFill offers its customers to share their experiences via reviews, blog posts or ratings, as well as general poll questions. Customers can also choose to have an opportunity to leave comments or ask questions w.r.t an option that is provided by VisaFill or provide answers to questions asked by other customers. VisaFill might also work with an outside party to reach you and collect feedback regarding your last reservation using VisaFill. While taking part in the feedback procedure is completely optional however, you could still be receiving messages, emails, or notifications (app SMS, app, WhatsApp or any other messaging service) in order to allow you to post the review(s). Reviews can include text (with pictures or not) or recorded in video format. Reviews written or published will be available on VisaFill and could also be available on other travel or travel-related platforms.

The User-Generated Content that VisaFill collects can include the following types of content:

Articles for Website or Blog

Review and Ratings

Question and Answers

Crowd Source Data Collection (poll questions).

Every User who writes reviews or ratings, questions and answers or photos must be able to create a profile on the site, which others are able to view. Other users can view the amount of trips, reviews written, queries asked and answered, and photos posted by the User. The User must be diligent and exercise due attention to make sure that any opinions posted via the Social Media platform or on the VisaFill website are not demeaning or in opposition to public policy, law or morality, religion creeds, castes, colours race, sex or culture, ethical customs and traditions, decency good morals, intellectual property of third parties, etc. By uploading pictures, views, images, contents, visuals, audios, experiences etc. via this social platform, or on the VisaFill site, you agree to allow VisaFill to reproduce, use copies, upload images views, perspectives, look and feel, images, content audios, visuals, experiences, etc. in any way, as can be deemed appropriate by VisaFill and without any obligation or liability, compensation, or cost owed to you or any other third person, on behalf of VisaFill. VisaFill is hereby releasing all or any claims, obligations and liabilities, lawsuits or costs or compensations. related to or relating to the reproduction, use copies, uploads, or other use of views, images or look and feel images, content, visuals or audios, as well as experiences. Contributed, shared, or expressed by you, on behalf of you and/or to any third-party.

PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS

After the VisaFill application is installed on your smartphone, an authorization list will be displayed and they are required to ensure the proper functioning of the app. The permissions Thomas Cook requires and the information that can be accessed and used are listed below:

Android permissions:

Location: This authorization allows us to provide you with the branch nearest to your current location should you require any assistance in connection with any travel issue.

SMS: If we let us to read your SMS, we’ll send you SMS relating to “OTP” and also send information about your holiday package to your mobile.

Phone App requires access to make phone calls, so you can make calls directly to one of our service centers directly from the application.

Contacts: If you permit us access to contact information, it permits us to provide lots of social services for you, such as sharing holidays with your contacts, sharing holiday packages.

Photos/Media/Files The libraries that are part of the app make use of these permissions to save and store images and documents to facilitate your speedy and easy use of the app as you browse the next time. When you save image documents and other data locally, your phone does not have to download the same each time you open the app.

IOS Permissions:

Notifications If you choose to sign up for notifications, it permits us to notify you of exclusive deals, promotions as well as travel related updates etc. on your device.

INFORMATION PROTECTION AND SECURITY

In assessing the cost of implementation, as well as the nature of the processing, its scope, context, and purpose of the processing, as well as the potential for varying levels of degree of severity and likelihood in relation to the rights and rights of natural persons, we take appropriate organisational and technical measures to ensure that we have a level of security that is appropriate for the risks of processing, such as:

the encryption and pseudonymisation of personal information;

the ability to guarantee the permanent security integrity, reliability, accessibility and reliability in processing equipment and the services they provide;

the ability to restore accessibility to personal information promptly in the occasion of a technical or physical incident or

a method of regularly checking, evaluating and testing the efficacy of technical and organizational measures to ensure the security of processing.

We make sure that individuals who have regular or continuous access to personal information, or who have a role in processing personal information or the development of tools that handle personal data are properly trained and informed about their rights and responsibilities in the processing of personal data.

To safeguard your personal information and ward off unauthorized access to your personal data, we have implemented appropriate security measures and certified. We’ve got an SSL website and the user must utilize it to secure the transmission of information while shopping online.

We expect any third party that process your information to what we do and implement the same levels of protection for your personal information. While no system can be 100% secure like ours, we’ll keep employing internet security measures to ensure your data is secure when you are with us. By browsing, opening, using this website for transactions or to store any information or data you are agreeing to abide by the most recent updated privacy notice which is in effect at the time you visit. If you sign up to a social media or other service that keeps your data and data, you must abide by their terms of service as well as their privacy policy.

DATA RETENTION

We will keep only your personal information for as long as is necessary for the purposes we obtained it to fulfill. This could include, for instance fulfilling any regulatory, legal and accounting requirements, as well as reporting obligations in the course of carrying legal tasks, or for the purpose of establishing or defending for legal rights.

We will keep your personal data within our databases as per our retention, management of documents and destruction policy as well as the applicable laws. This time period could extend past the termination of your relationship with us, however it will only be so long as it’s required to us to have the necessary information to address any issues that might develop afterward. For instance, we might require or need to retain certain data to enable you to receive credit for a the trip you booked but have to cancel. It is also possible that we need to keep certain details to stop fraud; to safeguard ourselves from liability, and allow us to pursue any remedies available or limit the damages we might incur; or when we believe that the law or regulation, rule, or guideline demands it.

In certain situations, we can anonymize your personal information (so that it will no be used to identify you) to conduct research or for statistical purposes. In this case, we can use the information for a period of time without communication to you.

How to Delete Your Account and Data

If you would like to remove your account as well as the associated information, comply with these steps:

1. Send an email to request your account Contact support@visafill.com and include the following subject: “Account and Data Deletion Request.”
2. Give the required details In the body of your message, add the following details:
   a. Your full name
   b. The contact information you provided when registering (e.g. contact number or email address)
   C. A short statement that confirms that you would like your account and all data to be removed
3. Verification Process to protect your information we may require additional information to confirm your identity prior to making any decisions on your request.
4. Confirmation of Deletion When you have verified your identity the process will begin to delete your account as well as associated information. You will receive an email confirmation when the deletion process is completed.
5. Processing Time Allow up to [define the period, e.g., Upto 30 daysfor your request be processed.
6. Exclusivity exceptions In certain circumstances we can keep certain information in order to fulfill legally binding obligations, or for legitimate commercial needs according to the Privacy Policies.

If you have questions or need assistance, please call us at supportvisafill.com

CHANGES TO THE POLICY

YOUR RIGHTS

In certain circumstances you are entitled to certain rights under the applicable law regarding data protection with respect to the personal information you provide us. We will protect your rights and respond promptly and in compliance the applicable laws, rules, or regulation regarding data processing. information.

Information on your rights under General Data Protection Regulation (GDPR) are provided below:

Right to be informed of the way in which personal data is used. You are entitled to being informed of how we utilize and share your personal information. This information will be made available in a clear understandable, clear, and easily understandable format. it will be presented in plain and clear words;

the right to view personal data the right to access personal data to verify the extent to which we process your personal information, gain access to your personal information and information about how your personal information is processed by us;

the right for inaccurate personal information rectified. You have a right to have inaccurate or incomplete personal information corrected. If we’ve disclosed pertinent personal information to third party and we be able to inform these third parties about the correction if it is it is possible to do so;

rights to have personal information deleted in certain situations – you are entitled to request that specific personal data we have be erased. This is also referred to by the term “right to be erased. This isn’t an absolute right that demands the deletion of all personal data erased. We will evaluate every request in accordance with the provisions of any law that governs the processing of personal data.

rights to restrict processing of personal information in specific circumstances. You can exercise your right to stop data processing for your private information under certain conditions. This right is available when you dispute the authenticity of personal information or if you have made opposition to the processing or when the processing of your personal data is illegal and you object to the erasure of data and instead request restriction or if your personal information is no longer needed by us, but you need the data to be retained in order to establish the validity of an legal claim;

the right to data portability under certain circumstances, you are able to ask for copies of your personal information in an electronic format. This is only applicable to data you’ve given us (for instance, by filling out an application form or submitting information via a website). Data about you that has been collected through monitoring your behavior can also be subject to to data transferability. This right is only applicable when the processing is based on your consent, or if the personal data is processed to fulfill an agreement and the processing takes place through automated means (i.e. electronically);

right to object to the processing of personal data under certain situations, for example when personal data is processed for marketing purposes. You are entitled to oppose processing conducted by us when (a) we process personal information based on legitimate interest or in the fulfillment of a function of public benefit (including the profiling), (b) if we use personal data for direct marketing purposes or (c) the data is being used to conduct research or scientific research or for statistical purposes. We will notify you of your right to object prior to the time of collection of your data and the decision to opt-out will be specifically made clear to you and will be made clear and distinct from other information and

the right to not be subject to automated decisions when the decision will have an impact that is legally binding or similar effects you are entitled not to be subjected to any decision built on automated processing when the decision is likely to have legal consequences or the same effect on you.

You can make use of any of the mentioned rights by submitting a request to legal@visafill.com

You are not required to pay any fee in order to obtain access to your personal information (or in order to use any additional rights). However, we could be able to charge a reasonable cost when your request is not substantiated, repetitive or overly. In addition, we could not be able to fulfill your request under these conditions.

In addition, if you have any comments, questions or issues regarding this Policy or any other matter, please email legal@visafill.com

We may have to ask particular information from you in order to ensure your identity and confirm the rights to view your personal information (or in exercising one additional rights). This is a measure of security to ensure that your personal information is not divulged to anyone who does not have the right to be able to. We can also contact you to request more information about your request in order to speed up our response.

We strive to answer all legitimate requests within a calendar month. Sometimes it can take longer than a calendar month in the event that your request is complicated or you’ve submitted a variety of requests. In the event of this we will inform that you are waiting and keep you updated.

Grievance Officer

In line with Information Technology Act 2000 and the rules thereunder the name and contact information for the Grievance Officer are listed below:

Mr. Gopal Subramanium

Email: grievance@visafill.com

Nodal Officer

If your query or concern is not resolved within seven business days of reporting it to the Grievance officer, or you are not satisfied with the response of the Grievance Officer You can speak to the Nodal Officer.

The response will be made within three business days of the date of reception of your email.

Nodal officer email address: officer@visafill.com

Facebook

We want to let you know that upon getting your consent, VisaFill will be only collecting and using the basic account information on your Facebook profile including your email address, name as well as your gender and profile photo. The information we collect is only to signing-up and logging-in to VisaFill. Your activity that is associated with Facebook will be accessible by VisaFill.

Remove Facebook Account Information If you’d like to erase this information from our system, you need to send us an email using your registered email address and send it to hello@visafill.com and your information will be removed within 72 hours. You will receive an email confirmation after our deletion post.

Please be aware that VisaFill will delete your profile as a user, along with the booking information. These data can’t be restored in the future. Therefore, make sure you have backed up all essential data before you delete your profile.

Thanks,

Team VisaFill