Privacy Policy

Last Updated on 15 jan,2024

ebo Solutions Private Limited (“ebo”),a company incorporated under the Companies Act, 2013 and having its registered office at OFFICE NO. 273, PLOT NO. 19, SECTOR - 19D, SATRA PLAZA, VASHI, MUMBAI Mumbai City MH 400705, India is the owner of the brand ebo and web based platform ‘ebonow.com’ and mobile application ‘ebo’ (collectively, the “Platform”).

This privacy policy (Privacy Policy) describes the policies and procedures applicable to the collection, use, disclosure and protection of your information shared with Us while You use the Platform, and for the purpose of this Privacy Policy "We", "Us", or "Our" refers to any of the Company or ebo or both of them, wherever context so require and the terms “You”, “Your”, “Yourself” or “User” refer to user of the Platform.

This Privacy Policy is an electronic record under the Information Technology Act, 2000 and the rules made there under. This Privacy Policy does not require any physical, electronic, or digital signature by Us and has been published in accordance with the provisions of the Information Technology Act, 2000 and the rules made there under that require publishing the privacy policy and terms of use on the Platform.

Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing any material, information or availing any Services through the Platform.

This Privacy Policy specifies the manner in which Your information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by Us. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any Third-Party Sites that You access or use in connection with the Services offered on the Platform.

By visiting the Platform or setting up/creating an user account (Account) on the Platform, You accept and agree to be bound by the terms and conditions of this Privacy Policy and consent to Us collecting, storing, processing, transferring and sharing information including Your Personal Information (defined below)in accordance with this Privacy Policy.

TYPE OF INFORMATION WE COLLECT AND ITS LEGAL BASIS

The information as detailed below is collected for us to be able to provide the services chosen by you and also to fulfill our legal obligations as well as our obligations towards third parties as per our User Agreement.

"Personal Information" of User shall include the information shared by the User and collected by us for the following purposes:

1) Collection of Information: We collect various information from You when You access or visit the Platform, register or set up an Account on the Platform or use the Platform. You may browse certain sections of the Platform and the Content, without registering an Account on the Platform. However, to avail certain Services on the Platform, You are required to set up an Account on the Platform. This Privacy Policy applies to information(s), as mentioned below and collected about You:

a) Personal Information: You may provide certain information to us voluntarily while registering on the Platform for availing Services including but not limited to Your complete name, mobile number, email address, date of birth, gender, age, address details, proof of identity such as Permanent Account Number (PAN), passport, driving license, the voter's identity card issued by the Election Commission of India, or any other document recognized by the Government for identification, and any other information voluntarily provided through the Platform (“Personal Information”). The act of providing Your Personal Information is voluntary in nature and We hereby agree and acknowledge that We will collect, use, store, transfer, deal with and share such details in compliance with applicable laws and this Privacy Policy.

b) Sensitive Personal Information: For the purpose of this PrivacyPolicy, Sensitive Personal Information consists of information relating to the following:

i) Passwords.

ii) Financial information such as bank account or credit card or debit card or other payment instrument details.

iii) Physical, physiological and mental health condition.

iv) Sexual orientation.

v) Medical records and history.

vi) Biometric information.

viii) Any details relating to the above, received by a body corporate for processing, stored or processed under lawful contract or otherwise.

ix) Any other information that may be regarded as SensitivePersonal Information” as per the prevailing law for the time being in force.

Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information.

You may be asked for the payment details to process payments for the Services. You may also be asked to provide certain additional information about Yourself on a case to case basis.

c) Transactional Information: If You choose to avail the Services through the Platform, We will also collect and store information about Your transactions including transaction status, order history, number of transactions, details and Your behaviour or preferences on the Platform. Information may also include information such as your banking details (including credit/debit card) and any other information relating to your income and/or lifestyle; billing information payment history etc. (as shared by you). All transactional information gathered by Us shall be stored on servers, log files and any other storage system owned by any of Us or by third parties.

d) Location based information: When and if You download and/or use the Platform through Your mobile, tablet, and/or any other computer sources or electronic devices, We may receive information about Your location, Your IP address, including a unique identifier number for Your device. The informationYou provide may be used to provide You with location-based Services including but not limited to search results and other personalized content. If You permit the Platform to access Your location through the permission system used by Your device operating system, the precise location of Your device when the Platform is running in the foreground or background may be collected. You can withdraw Your consent at any time by disabling the location ­tracking functions on Your device. However, this may affect Your experience of certain functionalities on the Platform. In addition to the above, Your IP address is identified and used to also help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP address is also used to help identify You and to gather broad demographic information.

The primary goal in doing so is to provide You a safe, efficient, smooth, and customized experience on the Platform. The information collected allows Us to provide the Services and/or features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier. More importantly, while doing so, We collect the above - mentioned Personal Information from You that We consider necessary for achieving this purpose.

HOW WE USE YOUR PERSONAL INFORMATION:

The Personal Information collected maybe used in the following manner:

While making a booking

While making a booking, we may use Personal Information including, payment details which include cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details, wallet details etc. as shared and allowed to be stored by you. We may also use the information of travelers list as available in or linked with your account. This information is presented to the User at the time of making a booking to enable you to complete your bookings expeditiously.

We may also use your Personal Information for several reasons including but not limited to:

  • ● Confirm your reservations with respective service providers.
  • ● Keep you informed of the transaction status.
  • ● Send booking confirmations either via sms or Whatsapp or any other messaging service.
  • ● Send any updates or changes to your booking(s).
  • ● Allow our customer service to contact you, if necessary.
  • ● We use the information, for the following.
  • ● To provide and improve the Services on the Platform that You request.
  • ● For internal business purposes and services, including without limitation, warehousing services, delivery services, IT support services, and data analysis services.
  • ● To resolve disputes, administer our service and diagnose/troubleshoot technical problems.
  • ● To help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users.
  • ● To design and improve the products and Services and customer relationship management processes.
  • ● To collect money from You in relation to the Services, to inform You about online and offline offers, products, services, and updates.
  • ● To customize Your experience on the Platform or share marketing material with You
  • ● To detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform.
  • ● To enforce and inform about Our Terms.
  • ● To process and fulfil Your request for Services or respond to Your comments, and queries on the Platform.
  • ● To contact You through email, SMS, WhatsApp, telephone and any other mode of communication in relation to the Services.
  • ● To allow Our service providers, business partners and/or associates to present customized messages to You.
  • ● To communicate important notices or changes in the Services, use of the Platform and the Terms/policies which govern the relationship between You and the Company and/or ebo, as applicable.
  • ● To conform to the legal requirements, compliance/reporting to regulatory authorities, as may be required and to comply with applicable laws.
  • ● To carry out Our obligations and enforce Our rights arising from any contract entered into between You and Us.
  • ● To carry out research with relevant partners.
  • ● For any other purpose after obtaining Your consent at the time of collection. (collectively “Purposes”).
  • ● Customize the content of our website, mobile site and mobile app.
  • ● Request for reviews of products or services or any other improvements.
  • ● Send verification message(s) or email(s).
  • ● Validate/authenticate your account and to prevent any misuse or abuse.
  • ● Contact you on your birthday/anniversary to offer a special gift or offer.

Surveys:

The Company and/or ebo may occasionally ask You to complete optional online surveys. These surveys may ask You for Your contact information and demographic information (like pin code, or age). We value opinions and comments from our Users and frequently conduct surveys, both online and offline. Participation in these surveys is entirely optional. Typically, the information received is aggregated, and used to make improvements to Website, other Sales Channels, services and to develop appealing content, features and promotions for members based on the results of the surveys. Identity of the survey participants is anonymous unless otherwise stated in the survey.

We use this information to tailor Your experience on the Platform, providing You with content that We think You might be interested in and to display content according to Your preferences. We use Your information to send You promotional emails, however, We will provide You the ability to opt-out of receiving such emails from Us. However, You will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications. We will not share YourPersonal Information with another user of the Platform and vice versa without Your express consent.

3) SHARING OF INFORMATION:

a)Third Party Service Providers: We may disclose Your PersonalInformation to third party vendors, delivery partners, consultants, partners for carrying out research and other service providers who work for either of Us or provide Services through the Platform and are bound by contractual obligations to keep such Personal Information confidential and use it only for the purposes for which We disclose it to them and maintain the same level of data protection that is adhered to by Us. This disclosure may be required, for instance, to provide You access to the Services and process payments including validation of Your Payment Details, to facilitate and assist marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to the Services. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage Your payment-related information. We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.

b) Compliance with law: We may disclose Your information including Personal Information, to the extent necessary: (a) to comply with laws, regulatory requirements and to respond to lawful requests and legal process or an investigation, (b) to protect Our rights and property, the users, and others, including to enforce the Terms or to prevent any illegal or unlawful activities, and (c) in an emergency to protect Our personal safety and assets the users, or any person. In all such events We shall in no manner be responsible for informing You or seeking Your approval or consent. We may also share aggregated anonymized (and de-identified) information with third parties at Our discretion.

c) Acquisition Sale or Merger: We may, in compliance with applicable laws, share all of Your Personal Information (including SensitivePersonal Information) and other information with any other business entity(ies), in the event of a merger, sale, reorganisation, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of any of Us.

d) Sharing of information with third party for operation of the Platform: In the event the license agreement is terminated or the territory of the license is modified or limited in any manner, We may share any or all Your Personal Information (including Sensitive Personal Information, if any) and Non-Personal Information with the incoming licensee continuity of smooth operation of the Platform and seamless user experience.

e) Sharing of information with any member of Our Group or affiliated entities, third parties and transfer outside India: Subject to applicable law, we may at Our sole discretion, share Personal Information(including Sensitive Personal Information) to Our Group or affiliated entities, any third party that ensures at least the same level of data protection as is provided by Us under the terms hereof, located in India or any other country. By using the Platform, You accept the terms hereof and hereby consent to Us, sharing of Your Personal Information and Sensitive Personal Information to OurGroup or affiliated entities, third parties, including in any location outsideIndia, provided that they ensure that Your Personal Information and Sensitive Personal Information is protected in compliance with standards that are comparable to the standards of protection afforded to it in India.

For the purpose of this clause the term “Group” shall mean, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, including any Relative or Related Party (as such term defined in the Companies Act, 2013 to the extent applicable) of such person, holding, subsidiary Companies, etc.

You also specifically agree and consent to Us collecting, storing, processing, transferring, and sharing information (including Personal Information and Sensitive Personal Information)related to You with third parties such as with entities registered under applicable laws including payment gateways and aggregators, solely for Us to provide Services to You including processing Your transaction requests for theServices or to improve Your experience on the Platform.

4) Security Precautions and Measures: The Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration, in compliance with applicable laws. Further, whenever You change or access Your Account on the Platform or any information relating to it, the use of a secure server is offered. It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly)the obligation to ensure that You shall at all times take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.

You will be responsible for maintaining the confidentiality of the Account information and are fully responsible for all activities that occur under Your Account. You agree to (a)immediately notify Us of any unauthorized use of Your Account information or any other breach of security, and (b) ensure that You exit from Your Account at the end of each session. We cannot and will not be liable for any loss or damage arising from Your failure to comply with this provision. You may be held liable for losses incurred by any of Us or any other user of or visitor to thePlatform due to authorized or unauthorized use of Your Account as a result of Your failure in keeping Your Account information secure and confidential.

When payment information is being transmitted on or through the Platform, it will be protected by encryption technology. Hence, we cannot guarantee that transmissions of Your payment-related information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by Us or Our third-party service providers. We assume no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third-party access, or other causes beyond Our control. You play an important role in keeping Your Personal Information secure. You shall not share Your Personal Information or other security information for Your Account with anyone. We have undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of thePlatform and the Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your Personal Information made by any third parties who are not subject to Our control.

Notwithstanding anything contained in this Privacy Policy or elsewhere, We shall not be held responsible for:

a) Any security breaches on third-party websites or applications or for any actions of third-parties that receive Your PersonalInformation.

b) Any loss, damage or misuse of Your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. For the purpose of this Privacy Policy, a “Force Majeure Event” shall mean any event that is beyond Our reasonable control and shall include, acts of God, fires, explosions, wars or other hostilities, insurrections, revolutions, strikes, labour unrest, earthquakes, floods, pandemic, epidemics or regulatory or quarantine restrictions, unforeseeable governmental restrictions or controls or a failure by a third party hosting provider or internet service provider or on account of any change or defect in the software and/or hardware of Your computer system.

5) Retention of Your Personal Information: We maintain records of Your Personal Information only till such time it is required for the Purposes, or for as long as required by applicable law. When You request us to delete Your information, we will honour the said request, but we may retain certain information about you for the purposes authorized under thisPrivacy Policy unless prohibited by law.

6) Links to Other Third–Party Sites and collection of information: The Platform may link You to other third-party Platforms(“Third-Party Sites”) that may collect Your Personal Information including Your IP address, browser specification, or operating system. We are not in any manner responsible for the security of such information or their privacy practices or content of those Third-Party Sites. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the Third-Party Sites and it is hereby clarified that the Platform does not control the use of cookies by these Third-Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of Your information that You may be subject to. This Privacy Policy does not govern any information provided to, stored on, or used by these third-party providers and Third-Party Sites. We recommend that when You enter a Third-Party Site, You review the Third-Party Site’s privacy policy as it relates to safeguarding of Your information. We may use third-party advertising companies to serve ads when You visit the Platform. These companies may use information (not includingYour name, address, email address, or telephone number) about Your visits to the Platform and Third-Party Sites in order to provide advertisements about goods and services of interest to You. You agree and acknowledge that We are not liable for the information published in search results or by any Third-Party Sites.

7) Public Posts: You may provide Your feedback, reviews, testimonials, etc. on the Platform on Your use of the Services (“Posts”). Any content or PersonalInformation and Posts that You share or upload on the publicly viewable portion of the Platform (on discussion boards, in messages and chat areas, etc.) will be publicly available, and can be viewed by other users and any and all intellectual property rights in and to such Posts shall vest with Us. Your Posts shall have to comply with the conditions relating to Posts as mentioned in the Terms. We shall retain an unconditional right to remove and delete any Post or such part of the Post that, in Our opinion, does not comply with the conditions in the Terms or where applicable law requires us to remove such Post. We reserve the right to use, reproduce and share Your Posts for any purpose. If You delete Your Posts from the Platform, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by other Users.

8) Your Consent, Rectification and Changes to Privacy Policy:

THIRD PARTY ANALYTICS:

We use third-party analytics services to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and internet usage. These third parties use cookies and other technologies to help analyze and provide us the information and, in some cases, connect such information with other data held by our, or third party, environments. You consent to the processing of information about you by these analytics providers in the manner and for the purposes set out in this Policy.

At present, we work with the following analytic partners:

  • Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for Customers. We use Google AdSense Advertising on our Platform. Google, as a third-party vendor, uses cookies to serve ads on our Platform.

We have implemented the following:

  • Remarketing with Google AdSense

Third party tools and software: We use third party in Our App. Majority of them are different payment options by which You can make a payment for an order. In order to enhance Your personal and overall experience some of the tools are used therein.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

ebo will retain your Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this policy. In some circumstances we may retain your Personal Information for longer periods of time, for instance where we are required to do so in accordance with any legal, regulatory, tax or accounting requirements.

Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

COOKIES AND SESSION DATA

Cookies:

ebo uses cookies to personalize your experience on the Website and the advertisements that maybe displayed. ebo’s use of cookies is similar to that of any other reputable online companies.

Cookies are small pieces of information that are stored by your browser on your device's hard drive. Cookies allow us to serve you better and more efficiently. Cookies also allow ease of access, by logging you in without having to type your login name each time (only your password is needed); we may also use such cookies to display any advertisement(s) to you while you are on the Website or to send you offers (or similar emails – provided you have not opted out of receiving such emails) focusing on destinations which may be of your interest.

A cookie may also be placed by our advertising servers, or third party advertising companies. Such cookies are used for purposes of tracking the effectiveness of advertising served by us on any website, and also to use aggregated statistics about your visits to the Website in order to provide advertisements in the Website or any other website about services that may be of potential interest to you. The third party advertising companies or advertisement providers may also employ technology that is used to measure the effectiveness of the advertisements. All such information is anonymous. This anonymous information is collected through the use of a pixel tag, which is an industry standard technology and is used by all major websites. They may use this anonymous information about your visits to the Website in order to provide advertisements about goods and services of potential interest to you. No Personal Information is collected during this process. The information so collected during this process, is anonymous, and does not link online actions to a User.

Most web browsers automatically accept cookies. Of course, by changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. ebo supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking ebo cookies may disable certain features on the Website, and may hinder an otherwise seamless experience to purchase or use certain services available on the Website. Please note that it is possible to block cookie activity from certain websites while permitting cookies from websites you trust.

Automatic Logging of Session Data:

Each time you access the Website your session data gets logged. Session data may consist of various aspects like the IP address, operating system and type of browser software being used and the activities conducted by the User while on the Website. We collect session data because it helps us analyze User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on. It also helps us diagnose problems with our servers and lets us better administer our systems. The aforesaid information cannot identify any User personally. However, it may be possible to determine a User's Internet Service Provider (ISP), and the approximate geographic location of User's point of connectivity through the above session data.

USER GENERATED CONTENT

ebo provides an option to its users to post their experiences by way of reviews, ratings and general poll questions. ebo may also hire a third party to contact you and gather feedback about your recent booking with ebo. 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), answer questions posted by other users or a. The reviews may be written or in a video format. The reviews written or posted may also be visible on other event or celebrationl related platforms.

The UGC that ebo collects may be of the following kinds:

Photographs

Review and Ratings

Question and Answers

Crowd Source Data Collection (poll questions).

Each User who posts review or ratings, Q&A, photographs shall have a profile, which other Users will be able to access. Other Users may be able to view the number of trips, reviews written, questions asked and answered and photographs posted.

HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?

You will occasionally receive e-mail updates from us about fare sales in your area, special offers, new ebo services, and other noteworthy items. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the "unsubscribe" link or follow the instructions in each e-mail message.

GRIEVANCE OFFICER

ebo hereby appoints ebo Support as the grievance officer for the purposes of the rules drafted under the Information Technology Act, 2000, who may be contacted at contact@ebonow.com. You may address any grievances you may have in respect of this privacy policy or usage of your Protected Information or other data to him.

CHANGES TO THE PRIVACY POLICY

From time to time, we may update this Privacy Policy to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.