Privacy Policy Newsletter
Last updated October 2023
We recognise the importance of protecting your privacy and your rights with regards to data protection. The Internet is a very powerful medium when it comes to transmitting personal information; for that reason, we and all other companies belonging to the lastminute.com group (“lm group”) undertake the serious task of respecting the current laws regarding the protection of personal data and the security of the same, with the aim of guaranteeing secure, controlled and confidential navigation for its users and customers who visit and/or use the Website and/or use our Comparison Service (you as a "User") or then purchase or register on our services, download our app and/or give us their consent for a specific purpose (you as a "Customer").
This Privacy Policy describes how we collect, use, process, and disclose your personal data in conjunction with your access to and use of our Website and services and, specifically:
1. Who is the controller of your data? 2. What categories of your data do we collect and use? 3. Why and how do we collect your data? 4. Who sees, receives and uses your data and where? 5. How long do we retain your data? 6. What are your data protection rights and how can you exercise them? 7. Contact details of the data controller 8. Contact details of our data protection officer 9. Identity and contact details of Grievance Officer
10. Information about cookies
11. Privacy notice for Facebook 12. Update and old versions of this privacy policy
13. Data Security
14. Miscellaneous
15. Force Majeure
16. Governing Laws and Jurisdiction
It also informs you of how you can exercise Your Rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the section below.
If you see an undefined term in this Privacy Policy (such as “Service” or “Website”), it has the same definition as in our Company's contractual service conditions.
1. Who is the controller of your personal data?
When this Privacy Policy mentions “Company”, “we,” “us,” “our” or “Data Controller”, it refers to: Bravoventure India Private Ltd, an Indian company belonging to the lm group, with registered office at 3 rd Floor, Wing B, Etamin Block, Exora Business ParkKadubeesanahalli Village, Varthur Hobli, Outer Ring Road Bengaluru - 560103 India, which is responsible for the processing of Users’ and/or Customers’ personal data under this Privacy Policy (hereinafter, referred to as the “Company”, “we”, “us”, “our”, “Data Controller”).
We, being an entity located in India, are subject to Indian law regarding the protection of personal data.
2. What categories of your data do we collect and use?
When you visit the Website and use our Comparison Service (you as a "User") or then purchase or register to our services (you as a "Customer") we collect the categories of personal data as follows:
2.1. Personal data provided by you
The personal data that you share with us including when you register for an account, subscribe to marketing communications and which you provide to us when using our services, downloading our app, including the information entered into our booking platform and included in your comments, reviews or messages sent via telephone to our Customer Care Team, or through the Live Chat or through social media channels.
More specifically:
When you subscribe to the personalised marketing services you may provide us with: Your personal details (email address), information about when you click on our adverts, the way you access the website, including IP address, online identifiers and browsers details. You may also provide us with your browsing behaviour or your personal interests. Please note that some of this information might be collected automatically in accordance with p. 2.2.
The provision of the above personal data, where requested, is necessary for the adequate performance of the requested service and to allow us to comply with our legal obligations except when we rely on consent as legitimate basis for processing and or our legitimate interest. Without it, we may not be able to provide you with all the requested services.
It is important that all the personal data you give us is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.
2.2. Personal data collected automatically from our Website, from communication we send, and/or from third parties
We collect information about your visits to and use of the Website, such as information about the device and browser you are using, your IP address or domain names of the computers connected to the Websites, uniform resource identifiers for requests made, the time of request, the method used to submit the request to the server, the size of the archive obtained as a response, the numerical code indicating the status of the response given by the server (correct, error, etc.) and other parameters relative to the operating system and the computer environment used, the date and time that you visited, the duration of your visit, the referral source and website navigation paths of your visit and your interactions on the Website including the Services and offers you are interested in. Please note that we may associate this information with your account.
See the cookies section of this Privacy Policy (9. Information about cookies) for further information on the purposes for which we collect and use this information. Please note that your personal information may also be linked to Cookies to i.e. to collect information on how you use our product and services.
We may use this style to also understand how you engage with communication material that we send to you, such as emails, including the action you take such as any links in them that you click on, your duration and frequency of your engagement with the email.
To the extent permitted by the applicable law wherein we receive additional information about you, such as fraud detection information and warnings from third party service providers and/or partners for our fraud prevention activities.
3. Why do we collect your data?
In general terms, we use your personal data to provide you with the services you request, send you marketing and promotional communications, notify you about important changes to our Website and to deliver our content and ads which we think may be of interest to you. More specifically:
A. n.a
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B. n.a
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C. To meet the legal, regulatory and compliance requirements and to respond to requests by government or law enforcement authorities conducting an investigation.
On which legal basis? To comply with the law (i.e. to share personal data with regulatory authorities)
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D. To carry out aggregative statistical analyses on anonymised groups or to analyse identifiable individuals behaviour so that we can see how our Website, products and services are being used and how our business is performing.
On which legal basis? To pursue our legitimate interest (i.e. improving our Website, its features and our products and services)
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E. n.a
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F. To send you personalised and profiled marketing communications
Only with your prior explicit consent, to share with you via email and/or on our website or third party ones (e.g. using ads) the best deals and offers on products and services we think you might find interesting. If you have already given us your consent to profiling activities through marketing cookies or other means, we may send personalised communications. The personalised service or the offers can be related to the following sectors (please note that we do not share your email address with third parties): tourism, leisure, entertainment, high technology, fashion, decoration, consumer goods, food and beverage, finance, banking, insurance, energy, environment, communication, mass media, real estate, pharmaceuticals, clothing and textiles, education and training, energy, publications and publishing, information and communications technology, retail, sport, telecommunications and general services.
For this purpose we may:
- analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you.
- combine the information you give us via cookies and other tracking technologies with information related to your purchases.
- analyse information about the way you engage with communication material you receive from us, such as data on when emails have been opened or to determine if you have viewed or interacted with an ad, to record the number of times you have viewed each ad, to prevent a single ad being shown to you too frequently etc.
- temporarily share an encrypted version of your email address, with carefully selected partners who may combine this information with other forms of online identifiers or other personal data in order to present you with our offers cross device or cross channel, for example on social networks (Facebook, Pintrest, Instagram, twitter ).
- use automated decision making to segment and target product offers based on your demands and needs. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant. You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. For further details, you may contact our Data Protection Officers whose details are provided in this privacy policy.
On which legal basis? Where you give your consent (by ticking the appropriate checkbox or by inserting your email address into the proper field to receive personalised communications about us and our selected third parties).
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G. n.a
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H. n.a
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I. To verify compliance with our terms and conditions and for the establishment, exercise or defence of legal claims.
On which legal basis? To pursue our legitimate interest (i.e. compliance with our terms and conditions, protection of our rights in the event of any dispute or claim)
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J. To tailor and personalise online marketing notifications and advertising for you based on the information on your use of our Website, products and services and other sites collected through cookies (please see the Cookies section of this Privacy Policy for further information).
On which legal basis? Where you give your consent (i.e. through the cookie banner
or by your browser's settings)
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K. n.a
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4. Who sees, receives and uses your data and where?
4.1. Categories of recipients of your data
We share your personal data, for the purposes described in this Privacy Policy, to the following categories of recipients:
Our authorised employees and/or collaborators that assist and advise us on administration, products, legal affairs, and information systems, as well as those in charge of maintaining our network and hardware/software equipment;
Our third-party service providers (including other entities of the lmastminute.com group), which process your personal data on our behalf and under our instructions for the purposes described hereinabove acting as data processors, such as those providing us with IT and hosting services and customer support, analytics and administration services etc.
Our business partners who are social media platforms when it is explicitly requested by you (e.g. when you share information generated from our website onto those platforms), when using social media authentication methods or downloading our App whereby you agree either with our privacy policy or with the platforms that we may share information about your online activity with these partners even when you are not logged in to the social media platform). or when these business partners that provide us with functionality capabilities request information about the specifications of the device that the App has been installed on, which they have obtained the right to do. The information you share will be governed by the social media's privacy policy. Please check clause 2.3 of this Privacy Policy for more information.
Competent authorities when we are required to do so by the current law.
Competent authorities and Law and enforcement third parties when this is necessary so that we can enforce our terms of use and protect and defend our rights or property or the rights or property of any third party.
Third parties that receive the data (e.g. business consultants, professionals for delivering due diligence services or assess value and capabilities of the business) when it is necessary in connection with any sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners.
The complete list of parties to which your personal data may be disclosed is available at our registered office and may be requested by writing to privacy.in@lastminutegroup.com.
4.2. International transfer of your data
Users’ and/or Customers’ personal data is processed in the Data Controller’s registered office (see point 1), on the lm group servers, and at the offices of other entities to which data may be provided in order to provide the services requested of the Data Controller.
Given the fact that we are an international travel company, we also transfer your personal data to:
we disclose your data to autonomous data controllers such as airlines, hotels, car hire companies, tour operators etc. that might process your data outside India in order to provide you with the requested services.
we disclose your data to our service providers who act as data processors on our behalf that might be located in a country outside India, including Morocco, Albania, UK, European Economic Area, Switzerland and Tunisia. Our providers, acting as data processors, may be engaged in, among other things, the fulfilment of your service request, the processing of your payment details, the provision of advertising and marketing services on our behalf and the provision of support services through electronic communications or call centres.
Should you want to obtain further details about the safeguards put in place, you can contact us by writing to privacy.in@lastminutegroup.com.
5. How long do we retain your data?
We retain your personal data for as long as is required to achieve the purposes and fulfil the activities as set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law.
6. What are your data protection rights and how can you exercise them?
You can exercise the rights provided by the Information Technology Act, 2000 read with the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, including the right to access, update and object and the other rights as granted by the applicable legislation.
You can exercise these rights and the other rights as granted under the applicable privacy and data protection legislation at any time by:
Contacting us via email at privacy.in@lastminutegroup.com.
As for direct marketing, please note that you can also object at any time by clicking the unsubscribe link which we provide in each communication sent to you
As for online targeted ads and the withdrawal of your consent please refer to our Cookie section of this Privacy Policy.
In case you exercise any of the above rights, please note that we will attend your request considering the personal information held by all the companies within the lm group where Bravoventure India Private Ltd holds, directly or indirectly, 100% of the shares.
Your rights in relation to your personal data might be limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process your personal data which you have asked us to delete.
You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Data Protection Supervisory Authority
7. Contact details of the data controller
The contact details of the Data Controller of the data processing described hereinabove are:
Bravoventure India Private Ltd, a Indian company belonging to the lm group,with registered office at 1st Floor, B4 Wing, C/o Innovant Spaces Pvt ltd , Khata no 207/132,(Sy no 19/4&27), Kadubisanahalli Village,Varthur Hobli, Outer Ring Road (Bangalore).
8. Contact details of our privacy Team:
9. Identity and contact details of Grievance Officer
The Grievance Officer is Ms. Sowmya Rajesh, domiciled at the registered office of the lastminute.com group’s Company and available at the address privacy.people@lastminute.com or via the other communication channels at your disposal (e.g. chat etc.).
10. Information about cookies
For any information about Cookies please read the following Cookie Policy.
11. Privacy notice for Facebook
11.1. Facebook Custom Audiences - Facebook pixel We use the remarketing function “Custom Audiences” of Facebook Inc. (1601 Willow Road, Menlo Park, California 94025) or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. This function allows us to show our Users and/or Customers of our website interest-based ads when they visit Facebook (“Facebook ads”), and to analyze such Facebook ads for statistical and market research purposes, which helps us optimize future advertising. This allows us to serve more relevant advertising.
For this purpose we use the so-called Facebook pixel for our website.
When a User or a Customer visits our website and takes an action (for example, buying something), the Facebook pixel is triggered and reports this action. This way, we will know when a customer took an action after seeing our Facebook ad. We will also be able to reach this customer again by using a Custom Audience. Therefore, this pixel allows user behavior to be tracked after they have been redirected to our Website by clicking on a Facebook ad. This way, we will know when a customer took an action after seeing our Facebook ad. We will also be able to reach this customer again by using a Custom Audience.
Therefore, this enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy. Such data may allow Facebook and its partners to show ads on or off Facebook. A cookie may also be stored on your computer for these purposes.
12. Update and old versions of this privacy policy
We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our Website and update the “Last Updated” date at the top of this Privacy Policy.
13. Data Security
While aiming to guarantee a secure, confidential, safe handling of your personal data, we use certain physical, managerial, technical or operational safeguards as per industry standards and established best practices to protect the information we collect. We use reasonable security practices and procedures and use secure servers as mandated under applicable laws for protection of your information. We review our information collection, storage and processing practices, including physical security measures to guard against unauthorized access to systems. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet. You accept the inherent security implications of data transmission over the internet and the world wide web cannot always be guaranteed as complete secure. Therefore, your use of the website will be at your own risk. If you have any concerns please feel free to contact the Data Protection Officer at the details given above.
14. Miscellaneous
The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any information other than the information collected by us through the Platform. This Privacy Policy shall be inapplicable to any unsolicited information you provide us through the Platform or through any other means. All unsolicited information shall be deemed to be non-confidential and we shall be free to use and/ or disclose such unsolicited information without any limitations. The rights and remedies available under this Privacy Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.
15. Force Majeure
Notwithstanding anything contained in this Privacy Policy or elsewhere, the Company shall not be held responsible for any loss, damage or misuse of your personal data, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below) or any act or omission attributable to you or any person claiming on your behalf. A "Force Majeure Event" shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of god, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond our reasonable control), power or electricity failure or unavailability of adequate power or electricity.
16. Governing Laws and Jurisdiction
This Privacy Policy, our services and the use of it is governed by the laws of India and the courts in Bangalore shall have exclusive jurisdiction over any disputes connected to our website or the services.
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