Privacy Policy Notice Last updated: 24 May 2018 Protecting your privacy is very important for eChutti. This Privacy Policy applies to all of the services offered by eChutti and third party affiliated companies. OUR PRIVACY POLICY EXPLAINS HOW WE COLLECT, USE AND DISCLOSE INFORMATION ABOUT YOU. BY REGISTERING AN ACCOUNT OR BY CONTINUING TO USE OUR PLATFROM OR SERVICES OR BY ACCESSING THE INFORMATION, YOU AGREE TO BE BOUND BY THESE UPDATED PRIVACY POLICIES. PLEASE READ THE POLICIES CAREFULLY. IF YOU DO NOT AGREE TO ALL OF THESE POLICIES, DO NOT USE THE SERVICES. Definitions: • “Applicable Law” shall mean any law, statute, order, decree, rule, injunction, license, permit, consent, approval, agreement and/or regulation of any government authority, and/or other legislative or administrative action of a government authority, and/or a final decree, judgment or order of a court which relates to and/or shall be rendered applicable, directly or indirectly, to the provisions of these Terms and Conditions, the User and/or the Platform Company. • “eChutti” shall mean the mobile and web-based information services forming a social platform for travellers. • “Platform Company” shall mean eChutti. • “Content” will include (but is not limited to) images, photos, audio, video, location data, nearby places, and all other forms of information or data. • “User Content” means content that the User uploads, shares or transmits to, through or in connection with the services, such as likes, ratings, reviews, images, photos, messages, profile information, and any other materials that the User publicly displays or displayed in his account profile. • “eChutti content” means content that Platform Company creates and make available in connection with the services including, but not limited to, visual interfaces, interactive features, graphics, design, compilation, computer code, products, software, aggregate ratings, reports and other usage-related data in connection with activities associated with his account and all other elements and components of the services excluding Your Content and third party content. • “Third Party Content” means content that comes from parties other than eChutti or its users and is available on the services. • “Trip(s)”, “Travel Plan(s)”, “Event(s)”, “Tour(s)” refer to the tours or trips planned by Individuals or Tour operators or Companies. • “Content provider” shall be any person or persons engaged in providing information about their respective tourist spots, logistics, hotels, restaurants and eateries bar, pub, lounge and other social places. • “User” shall include all the users or members who sign up on the Platform. • “Us”, “our” “We” Shall denote the Platform Company through the agreement. • “You”, “He”, “Your” Shall denote the User. 1. Collection Of Information We collect information about you when you: Create an account; Use the Platform; Attend an event/trip; Visit our website; and Communicate with us. We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies. If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts. 1.1 Information You Provide to Us We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, choose interests or groups, fill out a form, or communicate with us. The types of information that we may collect include your name, username, password, email address, date of birth, location, postal address, phone number, payment method data, photos, social media profile links, identity proofs for verification, choices of interests and groups, and any other information that you choose to provide. The information that you provide is used to personalize our recommendations and other content to you. On occasion, the information that you give us when you join a group may imply information about your beliefs, political views, health conditions; or your sexual identity. This, and other kinds of sensitive information, is given special protection. Posting personal or sensitive information about yourself or others is against our Community Guidelines. 1.2 Information We Collect Automatically When You Use the Platform When you use our Platform, we automatically collect information about you, including: Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform. Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information. Location Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information. Information Collected by Cookies and Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies and pixel tags (which are also called clear GIFs, web beacons, or pixels). Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, and track usage of our Platform. Pixel tags are electronic images that may be used in our Platform or emails, and track usage of our Platform and effectiveness of communications. Other Information: With your permission, we may collect other information from your device, such as photos from your camera roll, contacts of individuals you wish to find or connect with, or calendar information you want to manage via the Platform. 1.3 Information We Collect From Other Sources We may collect information about you from other sources, such as through certain features on the Platform you elect to use, but only where these third parties either have your consent or are otherwise legally permitted or required to disclose your information to us. Examples include: Social Media Services. If you register or log into your account through a third-party social media service, we will have access to some of your third-party account information from that service, such as your name and other information in that account, and used for purposes such as improving your eChutti recommendations. We may also have access to third-party account information if you use the Platform feature to share a link. See this article for more information on how to enable or disable the connection between our Platform and your third-party account. Invitations. If another member sends you an invitation through our Platform, we may receive certain personal information, such as your name, email address, or phone number. If you are an invited guest, we will automatically send you an invitation to our Platform, and, if unanswered, a follow-up invitation. eChutti stores this contact information only to send these invitations and evaluate their success. You may unsubscribe from future invitations using the instructions in those messages. You may also contact us at support@eChutti.com to request that we remove this information from our database. Member Content. We may receive information about you when you or another member uploads photos or posts other content to the Platform. Information From Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources and other third parties as permitted by law. For more information about the data that we obtain from these providers, please contact us at support@eChutti.com. 2. Use Of Information We use information about you to: Operate, improve, promote, and protect eChutti and our Platform; Communicate with you; and Personalize content. 2.1 Operating our Platform We may use information about you for various purposes related to operating our Platform, including to: Provide, maintain, and improve our Platform, including to process transactions, develop new products and services, and manage the performance of our Platform; Display information about you, for instance, your list of interests, which will be visible on your profile; Personalize the Platform, for example, to suggest content in which we think you may be interested (including content given special protection under EU law or that relates to sensitive topics such as health, political opinions, religion, and sexual identity); Allow you to share information about your use of the Platform through a third-party social media service, if you connect your account through that service (which you can turn off at any time) and to provide you with better recommendations; Trip organizers contact details including name, profile photo, registered email id, specified contact numbers, website and social profile links are shared with members and third party email marketing activities to benefit the trip organizers. Monitor and analyze trends, usage, and activities in connection with our Platform; and Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of eChutti and others; to enforce compliance with our policies; and to comply with applicable law and government requests. Perform accounting and administrative tasks, and enforce or manage legal claims. 2.2 Communicating With You We may use information about you for various purposes related to communicating with you, including to: Respond to your comments, questions, and requests, and provide customer service; Communicate with you, in accordance with your account settings, about products, services, and trips offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, to contact you about trips on our Platform that are being held near your location, and to otherwise communicate with you in accordance with advertising. Notify you about communications of other members, in accordance with the communication preferences that you indicate in your account; and Send you technical notices, updates, security alerts and support, and administrative messages. 2.3 Advertising And Other Uses We may use information about you for various other purposes, including to: Provide content, features, or sponsorships that match member profiles or interests; Facilitate contests and other promotions; Combine with information that we collect for the purposes described in this Privacy Policy; and Carry out any other purposes described to you at the time that we collected the information. We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. 2.4 Legal Basis for Processing Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it. We process information about you in order to provide our services in accordance with our Terms of Service, for example to allow you to join groups, or to display your profile to other members, and to allow us to send you important service updates. We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform). Sometimes you provide us with sensitive information about you; for instance, the mere fact of joining a certain group may indicate information about your health, religion, political views, or sexual identity. Joining such groups, or posting information on the Platform about these topics is entirely voluntarily and done with your explicit consent. In some cases, we may also have a legal obligation to collect information about you, or may otherwise need the information to protect your vital interests or those of another person. We may also process information to comply with a legal requirement or to perform a contract. 3. Sharing Of Information We do not share information about you in any way other than as described in this Privacy Policy. We may disclose information about you: to members or social media services, subject to the choices you may make via the Platform; Trip organizer details may be shared to members or social media or email marketing service providers so that interested members can contact organizers directly for any queries regarding the trip or concerns. to our third-party service providers who help us to operate or improve our Platform; to authorities to comply with legal obligations and to protect and defend our rights and property; and to an affiliate or successor entity as part of a corporate transaction. We may also share de-identified or aggregated information. When you confirm your attendance for a trip or travel or any activity, your information will be transmitted to the organiser or co-ordinator or agent or affiliates/associates or contractors and other tour activity suppliers for booking purpose. By registering with eChutti, we have your permission or under the following circumstances- Complying with Law and Law enforcement agencies– We respond to summons, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of eChutti’s terms of use, or as otherwise required by law. Confidentiality and Security: eChutti takes every precaution to protect our members’ information. We give members full control to set privacy on personal information and other contact information to protect personal information about you. All eChutti.com Accounts’ passwords are encrypted. 3.1 Through Our Platform We share some of the information that we collect by displaying it on our Platform according to your member profile and account settings. Some information, such as user name, is always public. Some information, such as interests, is public by default, but can be hidden on our Platform. Trip organizers contact details including name, profile photo, registered email id, specified contact numbers, website and social profile links are shared with members and third party email marketing activities to benefit the trip organizers. contact numbers, website and social profile links are optional. Trip organizers may find it helpful to have access to the email addresses of members, to easily communicate and organize trips, members may share their details publicly by commenting on trip or messaging trip organizer on platform or contacting them directly on provided contact details, and we do not control to use of the shared data with trip organizers. Some information, such as group memberships, will always be visible to other members of that eChutti group, and may be public, depending on the settings of that group. We recommend that you check the group settings and what information will be available before joining the group to ensure that you are happy with the information that is visible to others. 3.2 With Our Service Providers We may use service providers in connection with operating and improving the Platform to assist with certain functions, such as payment processing, email transmission, email marketing, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations. 3.3 Following The Law And Protecting eChutti We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, eChutti or others. 3.4 Social Sharing And Other Tools The Platform may offer social sharing and email promotion/marketing features and other integrated tools which let you share actions that you take on our Platform with third-party services, and vice versa. Such features let you share information with your friends or the public, depending on the settings you have chosen with the service. The third-party services' use of the information will be governed by the third-parties’ privacy policies, and we do not control the third-parties’ use of the shared data. 3.5 Affiliate Sharing And Merger, Sale, Or Other Asset Transfers If eChutti is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates. 3.6 Other Situations We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. We may also share information about you with your consent or at your direction or where we are legally entitled to do so. 4. Additional Details With your permission, we may allow others to use technologies that collect information about you to provide analytic services, and to serve ads for eChutti. You may be able to disable the collection or use of this information by contacting us at support@eChutti.com. The governing law of the Agreement shall be the laws of the Republic of India and we will be processing, transferring, and storing information in and to the India, U.S. and other countries. We use commercially reasonable efforts to protect your personal information and have implemented technical and organizational measures in line with industry best practices. We cannot guarantee these controls will provide absolute security. This Privacy Policy is periodically updated, and does not apply to third parties. 4.1 Analytics and Advertising Services Provided by Others With your permission, we may allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Platform and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services. 4.2 Transfer Of Information To The India, U.S. And Other Countries eChutti is currently based in India. Information about you will be transferred to, and processed in, the India and countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy. 4.3 Security We employ technical and organizational measures designed to appropriately protect your information that is under our control and that we process on your behalf from unauthorized access collection, use, disclosure, copying, modification or disposal, both during transmission and once we receive it. We store all information that you provide to us on secure servers. We train employees regarding our data privacy policies and procedures, and permit authorized employees to access information on a need to know basis, as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure. Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password. 4.4 Data Retention We may temporarily block your account if you have not logged in for certain period of time. You may contact us if you wish to reactivate your account in such case. We retain certain information that we collect from you while you are a member of the Platform, and in certain cases where you have deleted your account, for the following reasons: So you can use our Platform; So ensure that we do not communicate with you if you have asked us not to; To provide you with a refund, if entitled; To provide accurate accounting information to other members about the groups that they organize or administer, and associated memberships; To better understand the traffic to our Platform so that we can provide all members with the best possible experience; To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of Service; and To comply with applicable legal, tax or accounting requirements. When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it. 4.5 Policy Scope This Privacy Policy does not apply to information that you provide to third parties, such as other members, including trip organizers, group organizers and network administrators, and others with whom you may share information about you. Our Platform may direct you to a third-party service, such as social media services, or a portion of our Platform may be controlled by a third party (typically through the use of a frame or pop-up window separate from other content on our Platform). Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. We are not responsible for the third-party privacy policy or content, even if we link to those services from our Platform or if we share information with these third parties. eChutti is a data controller. Members, including trip organizers, group organizers and network administrators, are directly responsible for complying with all requirements of applicable EU privacy laws in connection with the information that they obtain and process for the purposes of managing their contacts, or organizing trips, organizing groups, or administering networks 4.6 Revisions To This Policy We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. If we make any material change to this policy, we will provide additional notice to you by displaying a prominent notice on our Platform. 5. Your Choices You can review and change information about you or deactivate your account in your account settings, but we may retain certain information. You can remove photo tags if you wish. With your consent, we will use information about your location. You can deactivate this feature at any time. You have the right to opt out of receiving eChutti’s notification messages by changing the notification settings and you may opt out of third party promotional messages including email marketing through meetup by unsubscribing on third party websites directly, but you may still receive other non-promotional communications. 5.1 Account Information Choices You may update or correct your account information by editing your account settings or by sending a request to support@eChutti.com. You may deactivate your account directly from platform or by sending an email to support@eChutti.com. You will also be able to choose what information others see about you by using the Privacy Settings section in your Account. 5.2 Location Information Choices When you first access the Platform, we will collect information about your location, which we use to make better recommendations for groups and trips in your area, and to improve our Platform. If you do not want us to collect information about your location, then you can prevent this: If using a mobile app, by changing the settings on your device. If using our website, your location data will be obtained via a cookie. Note that our Platform or its features may no longer function properly if you do. Your mobile device settings may also give you the option to choose whether to allow us to view your location on a continuous basis, when only using the app, or never. Allowing us to view your location when you are not using the app allows us to provide you with recommendations on a regular basis. Please refer to your device’s guide for additional information on how to adjust location services. 5.3 Cookies Choices We may use and allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Platform and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services. 5.4 Promotional Communications Choices You can control messages or emails that you receive from eChutti and other members by modifying notifications, you can also control messages or emails from third parties by selecting the unsubscribe link in the message that you receive, or by adjusting the communication preferences or notification settings in your account. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations. 5.5 Photo Tagging Choices You can tag photos of yourself and others. When a photo has been tagged it means that the name of that person will appear alongside the photo, and the tagged photo will appear on the tagged member’s group profile. You can remove tags by selecting the “untag” option next to your name. You can also report inappropriate content to eChutti. Please inform guests who are not members of this Privacy Policy and their rights regarding their personal information should a photograph be posted on the Platform. 6. Data Rights You may have the right to exercise your data protection rights, including to request that eChutti deletes, amends, or provides you access to your information. You have the right to opt out of receiving eChutti’s promotional messages, notifications, but you may still receive other communications. You can complain to your local data protection authority about the use of your information. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to support@eChutti.com. Rights that you may have, depending on the country in which you live, include: Accessing, correcting, updating, or requesting deletion of your information. Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information. Opting out from receiving marketing communications that we send you at any time. You can exercise this right by adjusting the notification settings in your account or by selecting the “unsubscribe” or “opt-out” link in the marketing emails we or third party service provider sends you. Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent. Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available here. Note that eChutti is a controller of your information. Other members, such as trip organizers, group organizers and network administrators, may also act as controllers of your information. You should contact these members if you have any questions about how they use information that you have provided to them. 7. Using Social Network data: If you decide you would like to sign-up with eChutti.com using the using the social networking sites such as facebook, google plus, twitter, linkedin etc, then you are giving eChutti access to – Your ‘basic account information’ (including your date of birth) and ‘public information’ which is defined by Facebook as per the definitions provided at http:/developers.facebook.com/policy/#definitions You authorize eChutti to pull posts from your Facebook account. You authorize eChutti to push posts to your Facebook account. 8. Cookies Browser cookies are used to simplify the use of the website and obtain information that can help us make website user friendly and to better tailor our products to your interests and needs. Cookies may also be used to help speed up your future activities and user experience on eChutti. 9. Google Analytics eChutti uses Google Analytics on our master site and on those of our affiliate partners. Analytics is a web service provided by Google, Inc. Google Analytics uses cookies (see above), to help the website analyze how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. You may refuse the use of cookies (see above). You can also opt out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add on for your current web browser. 10. Governing Law and Dispute Resolution 10.1. Any dispute, controversy or claim arising out of or relating to this Agreement or the validity, interpretation, breach or termination thereof (“Dispute”), including claims seeking redress or asserting rights under the applicable law shall be amicably settled, in the offices of the Company in Bengaluru through mutual consultation and escalation at such offices of the Company as Company may designate. 10.2. If the Dispute is not settled amicably as aforesaid within a period of [14] (Fourteen) calendar days, the matter would be referred to arbitration in accordance with the provisions of the Indian Arbitration and Conciliation Act, 1996 and any amendments, re-enactments and modifications thereof. 10.3. The venue of arbitration at all times shall be Bengaluru, India. 10.4. Arbitration shall be presided over by a sole arbitrator named and appointed by Platform Company. 10.5. If the proceeding has been initiated by the Platform Company, the arbitrator shall be name the arbitrator in the written notice sent to the Contractor in relation to commencement arbitration. 10.6. If the proceeding has been initiated by the Contractor, the arbitrator shall be named by Platform Company with 14 days in a written communication from the date of receipt of the notice of commencement of the arbitration. 10.7. The arbitration proceedings shall be conducted in the English language. 10.8. The governing law of the Agreement shall be the laws of the Republic of India. 10.9. Subject to the aforesaid clause, the courts of Karnataka shall have exclusive jurisdiction in all matters arising out of this notice or Agreement as well as the arbitration proceedings envisaged herein (including but not limited to applications under Section 9 of the Indian Arbitration and Conciliation Act, 1996). 11. Contact Us If you have any questions, you can contact us at support@eChutti.com. Under European data protection law, the controller of your information is eChutti. If you have any questions or complaints about this Privacy Policy or how we use your information, please contact support@eChutti.com.