This Privacy (“Policy”) applies to the securing and processing of personal data by KHAMA GHANI HOLIDAYS (hereinafter “KHAMA GHANI HOLIDAYS”) 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 KHAMA GHANI HOLIDAYS through any of KHAMA GHANI HOLIDAYS interface channels including website, mobile site and mobile app (collectively referred herein as “Sales Channels”).

For the purpose of Privacy Policy:
– References in this policy to “you” or “your” are references to ‘User’
– References to “we”, “us” or “our” are references to ‘KHAMA GHANI HOLIDAYS’
– 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 KHAMA GHANI HOLIDAYS business partners, advertisers, sponsors or other sites to which KHAMA GHANI HOLIDAYS 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 recognise 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 OF PERSONAL DATA

A “Controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This notice is issued on behalf of KHAMA GHANI HOLIDAYS 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 KHAMA GHANI HOLIDAYS 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 KHAMA GHANI HOLIDAYS 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). 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 any other traveller(s) for whom you made a booking through your registered KHAMA GHANI HOLIDAYS account. In such case, you must confirm and represent that each of the other traveller(s) for whom a booking has been made, has agreed to have the information shared by you disclosed to us and further be shared by us with the concerned service provider(s). “Marketing and Communications Data”: including your marketing and communication preferences. We also track when you receive and read marketing communications from us, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials. Additional information about the personal data we process in connection with marketing is included with the marketing communications we send you;

“Public Domain or Third Party Data”: Data available in public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per your account settings) as a part of your account information.

“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; and

“Usage Data”: information about how you use our Website.

“Any other Personal Data”: If you request KHAMA GHANI HOLIDAYS 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. If you request KHAMA GHANI HOLIDAYS to provide foreign exchange (forex) related services then passport copies, A2 form, air tickets or travel authentication document to verify confirmed travel or any other documents required to process your Forex transaction

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:

(a) Direct interaction:

• 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

• 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 engage with us in any online or offline event, promotions, page hosted by us on a third party platform or location

• Through cookies on our Website

(b) Cookies and 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.
(c) Third parties or publicly available sources:

• We receive Technical Data from analytics providers such as Google

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:

(a) right to be informed about how personal data is used – you have a right to be informed about how we will use and share your personal data. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language;

(b) right to access personal data – you have a right to obtain confirmation of whether we are processing your personal data, access to your personal data and information regarding how your personal data is being used by us;

(c) right to have inaccurate personal data rectified – you have a right to have any inaccurate or incomplete personal data rectified. If we have disclosed the relevant personal data to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible;

(d) right to have personal data erased in certain circumstances – you have a right to request that certain personal data held by us is erased. This is also known as the right to be forgotten. This is not a blanket right to require all personal data to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your personal data;

(e) right to restrict processing of personal data in certain circumstances – you have a right to block the processing of your personal data in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us but you require the personal data to be retained to establish, exercise or defend a legal claim;

(f) right to data portability – in certain circumstances you can request to receive a copy of your personal data in a commonly used electronic format. This right only applies to personal data that you have provided to us (for example by completing a form or providing information through a Website). Information about you which has been gathered by monitoring your behaviour will also be subject to the right to data portability. The right to data portability only applies if the processing is based on your consent or if the personal data must be processed for the performance of a contract and the processing is carried out by automated means (i.e. electronically);

(g) right to object to processing of personal data in certain circumstances, including where personal data is used for marketing purposes – you have a right to object to processing being carried out by us if (a) we are processing personal data based on legitimate interests or for the performance of a task in the public interest (including profiling), (b) if we are using personal data for direct marketing purposes, or (c) if information is being processed for scientific or historical research or statistical purposes. You will be informed that you have a right to object at the point of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information; and

(h) right not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect – you have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.

You may exercise any of the above-mentioned rights by sending a request to dpo@ssc.tcgc.in. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Additionally, in case you have any questions, comments or concerns about this Policy, you may contact dpo@ssc.tcgc.in.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.