Privacy Policy

1.1. Who is Via?

EBIX Travels Private Limited (formerly known as FlightRaja Travels Private Limited) ("Via") is an online travel, accommodation, and allied reservation service provider for its customers and agents ("End Users"). Via owns and operates the websites, https://in.via.com and https://www.viaworld.in (collectively the "Websites") and mobile applications (on various platforms including Android, iOS and Windows) (collectively called ("Mobile Applications"). The Websites and the Mobile Applications enable End Users to make travel and accommodation related bookings and reservations. For providing the Services (as defined herein) Via has entered into contracts/arrangements with various holiday, hotel, transport and payment gateway service providers ("Third Party Service Providers").

1.2. What is this Privacy Policy?

This privacy policy ("Privacy Policy") describes Via's policies and procedures on the collection, use and disclosure of the information provided by End Users and the Visitors (as defined herein) of the Websites and the Mobile Applications (together referred to as "Users"). Via shall not use the Users' information in any manner except as provided under this Privacy Policy. Every User who accesses or uses the Websites or the Mobile Applications shall be bound by this Privacy Policy.

1.3. Why this Privacy Policy

This Privacy Policy is published in compliance of:
Section 43A of the Information Technology Act, 2000;
Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 ("SPI Rules"); and
Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
This Privacy Policy states the following:
The type of information collected from the Users, including Sensitive Personal Data Or Information (as defined below);

The purpose, means and modes of usage of such information; and

How and to whom Via will disclose such information.

1.4. What is Personal Information

"Personal Information" is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

The SPI Rules further define "Sensitive Personal Data or Information" of a person to mean Personal Information about that person relating to:
Passwords;

Financial information such as bank accounts, credit and debit card details or other payment instrument details;

Physical, physiological and mental health condition;

Sexual orientation;

Medical records and history;

Biometric information;

Information received by body corporates under lawful contract or otherwise;

User details as provided at the time of registration or thereafter; and

Call data records.


Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as Sensitive Personal Data or Information.

2. Privacy Statements

2.1. Users Note

This section of the Privacy Policy applies to all Users.

A condition of each User's use of and access to the Websites, Mobile Applications and to the other services provided by Via to End Users (together with the Websites and Mobile Applications, the ("Services") is his/her/its acceptance of the terms of use available at Via.com ("Terms of Use"), which also involves acceptance of the terms of this Privacy Policy. Any User who does not agree with any provisions of the same is required to leave the Websites and/or stop using and delete the Mobile Applications immediately.

When browsing the Websites, a User is not required to provide Personal Information unless and until such User chooses to avail or sign up for any of the Services.

Due to the communications standards on the Internet, when a User visits the Website, Via automatically receives the URL of the site from which such User came and the site to which such User is going when he/she/it leaves. Via also receives the Internet Protocol ("IP") address of each User's computer (or the proxy server a User used to access the Internet), the User's computer operating system and type of web browser the User is using, email patterns, as well as the name of User's ISP. This information is used to analyze overall Users' trends to help Via improve its Services. The linkage between User's IP address and User's personally identifiable information is not shared with third-parties without such User's permission or except when required by law or except where required to provide or facilitate the Services. Notwithstanding the above, the User acknowledges Via's right to share some of the aggregate findings (not the specific data) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.

The Websites and the Mobile Applications use temporary cookies to store certain data. Via does not store personally identifiable information in the cookies. Information collected by Via, by any means whatsoever, that does not personally identify the User as an individual (such as, patterns of utilization described above) is exclusively owned by Via and may be used by Via and Third Party Service Providers for the technical administration of the Websites, Mobile Applications, User administration, research and development, business development, statistical analysis and business intelligence purposes. Additionally Via may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.

We may disclose to third party services certain personally identifiable information listed below:
information you provide us such as name, email, mobile phone number.
information we collect as you access and use our service, including device information, location and network carrier.
This information is shared with third party service providers so that we can:
personalize the app for you
perform behavioral analytics

We collect and securely transmit social account information to https://in.via.com to enhance your app experience, as detailed in our privacy policy.

A User can set or amend his/her/its web browsers to delete or disable cookies. If a User chooses to disable cookies on his/her/its computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Websites or the Mobile Applications. Merely closing the web browser should ordinarily clear all temporary cookies installed by Via. However, Users are encouraged to use the "clear cookies" functionality of their browsers to ensure deletion, as Via cannot guarantee, predict or provide for the behaviour of the equipment of all the Users of the Websites.

Via may allow other companies or entities to serve advertisements to Users. These companies or entities include third party ad servers, advertisement agencies, advertisement technology vendors and research firms. Via may "target" some ads to Users that fit a certain general profile. Via does NOT use personally identifiable information to target ads. In the course of serving advertisements or optimizing the Services to its Users, Via may allow authorized third parties to place or recognize a unique cookie on the User's browser.

This Privacy Policy applies to the Websites, Mobile Applications and Services that are owned and operated by Via. Via does not exercise control over the websites displayed as search results or links from within its Services. These other sites may place their own cookies or other files on the Users' computer, collect data or solicit Personal Information from the Users, for which Via is not responsible or liable. Accordingly, Via does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Via guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Via of such websites, the websites' provider, or the information on the website. Via encourages the Users to read the privacy policies of such websites.

When a User visits or uses the Websites or the Mobile Applications by or through a mobile device, Via may access, collect, monitor and/or remotely store "location data," which may include global positioning system coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the mobile device. Location data does not collect or share any personally identifiable information about the User.

Via may keep records of telephone calls received from and made to Users for the purpose of administration of Services, research and development, business development or for User administration.

The Websites may enable Users to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Via hereby expressly disclaims any liability for any misuse of such information that is made available by Users in such a manner, neither does Via warrant or guarantee any such data or communication.

Via does not collect information about the Users of the Websites and the Mobile Applications from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the End Users.

Via may choose to conduct contests and surveys to collect relevant information about the Users' preferences. These surveys and contests are optional and if the User chooses to respond, his/her/its responses will be kept anonymous. The demographic information that the User provides in the registration process and through any surveys or contests is used to help Via improve its services to meet the needs and preferences of Users.

Via does not knowingly collect personal data from children (Only persons above the aged of 18 shall be permitted to use the Services as provided in the Terms of Use).

Via has implemented industry standard security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. It is expressly stated that Via shall not be responsible for any breach of security or for any actions of any third parties that receive Users' personal data or events that are beyond the reasonable control of Via including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.

Via will not disclose any Personal Information to governmental institutions or authorities unless such disclosure is requisitioned under any law or judicial decree or when Via, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

Via may share/use Personal Information provided by Users with its subsidiaries and Third Party Service Providers for the purposes of,
(i) enabling Users to enjoy the Services,
(ii) detecting and preventing identity theft, fraud and other potentially illegal acts,
(iii) correlating related or multiple accounts to prevent abuse of the Services, and facilitating joint or co-branded Services requested by Users, where such Services are provided by more than one corporate entity.

Via may also disclose or transfer the personal and other information provided by the Users, to any thirty party as part of reorganization or a sale of the assets of a Via corporation division or company. Any third party to which Via transfers or sells its assets will have the right to continue to use the personal and other information that Users provide to Via.

All Via employees and data processors, who have access to, and are associated with the processing of Sensitive Personal Data or Information provided by Users, are obliged to respect the confidentiality of every User's Sensitive Personal Data or Information.

The Users acknowledge that this Privacy Policy is part of the Terms of Use and unconditionally agree that becoming a User of the Websites, Mobile Applications and its Services signifies their assent to this Privacy Policy. The User's visit to the Websites, use of the Mobile Applications and any dispute over privacy is subject to this Privacy Policy and Terms of Use. Via may update this privacy policy at any time, with or without advance notice. In the event there are significant changes in the way Via treats User's personally identifiable information, Via will display a notice on the Websites, Mobile Application or send Users an email, as provided for above. Unless stated otherwise, Via's current privacy policy applies to all information that Via has about Users and their account (if applicable). Notwithstanding the above, Via shall not be required to notify the Users of any changes made to the privacy policy. If a User uses the Websites or the Mobile Applications after notice of changes have been sent to such User or published on the Websites or the Mobile Applications, such User hereby provides his/her/its consent to the changed practices.

2.2. Visitors Note:

No Sensitive Personal Data or Information is automatically collected by Via from any visitors of the Websites who are merely perusing or browsing the Websites ("Visitor").

Nevertheless, certain provisions of this Privacy Policy are applicable to Visitors, and Visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave the Websites immediately.

A User will not merely be a Visitor if the User has willingly submitted any personal data or information (including phone numbers, email ids, responses to surveys, etc.) to Via through any means, including email, post, telephone calls, telephonic messaging or through the registration process on the Websites or downloaded the Mobile Application(s) on your mobile telecommunications device. All such visitors will be deemed to be, and will be treated as, End Users for the purposes of this Privacy Policy, and in which case, all the statements in this privacy policy apply to the User.

If you, as a Visitor, have inadvertently browsed any other pages of the Websites prior to reading the privacy statements set out herein, and you do not agree with the manner in which information is obtained, stored or used, merely quitting this browser application should ordinarily clear all temporary cookies installed by Via. All visitors, however, are encouraged to use the "clear cookies" functionality of their browsers to ensure such clearing / deletion, as Via cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Websites.

2.3. End User Note:

All the statements in this Privacy Policy apply to all End Users, and all End Users are therefore required to read and understand the privacy statements set out herein prior to submitting any Sensitive Personal Data or Information to Via, failing which they shall be required to leave the Websites.

End Users may make or confirm bookings through the Websites and/or Mobile Applications. End Users may make bookings on the Websites without creating an account. Unregistered End Users using the Websites can make/confirm bookings by providing their name and phone number. However in order to have access to all the features and benefits on the Websites, End Users must first create an account on the Websites. To create an account on the Websites and/or download and use the Mobile Applications, the End User may be required to provide the following information, which such End User recognizes and expressly acknowledges to be Personal Information allowing others, including Via, to identify the User name, User ID, email address, country, home and office address, ZIP/postal code, age, phone number, password chosen by the End User, valid financial account information, etc. Other information requested on the registration page, including the ability to opt for receiving promotional offers from Via, is optional. Via may, in future, include other optional requests for information from the End User to help Via to customize the Websites and the Mobile Applications to deliver personalized information to the End User. Without the End User's consent, Via will not share, rent or sell any Personal Information with third parties in any way other than what is disclosed in this privacy policy.

Where a User used the Services for making bookings for persons other than himself/herself/itself; the User shall confirm and represent that each of such persons shall be deemed to have agreed and authorised the User to disclose their Personal Information to Via.

Via may require the End User to pay for the Services with a credit card, wire transfer, debit card or cheque. Via will collect such End User's credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the End User through the authentication process. The End User's credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the industry standard degree of care as per current technology. The End User is advised, however, that Internet technology is not completely safe and User should exercise discretion on using the same.

The End User acknowledges that all the information provided to Via by the End User, including Personal Information, is voluntary. The End User has the right to withdraw his/her/its consent at any time, in accordance with the terms of this Privacy Policy and the Terms of Use, but please note that withdrawal of consent will not be retroactive.

If an End User has inadvertently submitted any information to Via prior to reading this Privacy Policy, and does not agree with the manner in which such information is collected, stored, or used, then the End User may access, modify, correct and eliminate the data about him/her/it which has been collected pursuant to his/her/its decision to become an End User. If the End User updates any of his/her/its information, Via may keep a copy of the information which such End User originally provided to Via in its archives for uses documented herein. Via takes the End Users' rights seriously and encourages the End User to use them if the End User deems this to be appropriate. The End User may exercise these rights by emailing Via at care@via.com.

Via may communicate with End Users through emails, notices posted on the Websites, text, and other forms of messaging. An End User can change his/her/its email and contact preferences at any time by logging into their account on the Websites and changing their account settings.

The End Users' personally identifiable information they choose to provide on the Websites and/or the Mobile Applications is used to help the Users describe / identify themselves. Additionally Via may choose to conduct contests and surveys to collect relevant information about the End Users' preferences. These surveys and contests are optional and if an End User chooses to respond, his/her/its responses will be kept anonymous. The demographic information that Via collects in the registration process and through any surveys or contests is used to help Via improve its Services to meet the needs and preferences of the End Users.

3. Registration Process

3.1. As part of the registration process, Via may collect the following Personal Information from End Users

(i) name,
(ii) gender,
(iii) age,
(iv) contact information including favourite locations including home address and office address, email address and mobile number,
(v) password chosen by the End User,
(vi) demographic information such as postal code, preferences, interests, etc.
(vii) information regarding type of cell phone used, and
(viii) other information as the End User may provide.

3.2.This information specified in clause 3.1 above is collected on the registration form for several reasons including but not limited to,

(i) personal identification,
(ii) to facilitate travel, accommodation and allied reservations offered by Via,
(iii) to allow Via to contact the User for customer service purposes, if necessary,
(iv) to customize the content of the Websites and the Mobile Applications to meet specific needs of the User, and/or
(v) to make improvements to the Websites and the Mobile Applications.

3.3.  In addition, the email address provided by the User will be used to confirm his/her/its new registration and each transaction that is initiated. As a member of Via, the End User may also receive updates about special offers, new services, and other noteworthy events. However, you may, at any time, choose to no longer receive such types of emails. For further details, please refer to the Clause 4 of this Privacy Policy.

3.4. All the information listed in Clause 3.1 of this privacy policy ("End User Information") is maintained by Via in electronic form on online severs/clouds systems and shall be accessible by certain employees of Via as mentioned below. End User Information may also be converted to physical form from time to time. Regardless of the manner of storage, Via will keep all End User Information confidential, and will only disclose End User Information to the persons mentioned below:
Its employees on a need-to-know basis. All Via employees and data processors, who have access to, and are associated with the processing of Sensitive Personal Data or Information, are obliged to respect the confidentiality of every End User's Sensitive Personal Data or Information.

Third Party Service Providers to the extent necessary to provide the End Users with the Services. Via may provide the Personal Information to Third Party Service Providers who work on behalf of or with Via to provide End Users with the Services, to help Via communicate with End Users or to maintain the Websites and the Mobile Applications. Generally the Third Party Service Providers do not have any independent right to share this information, however certain service providers who provide services on the Websites, including the providers of online communications services, will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.

Notwithstanding the above, Via shall not be responsible for any breach of security or for any actions of any third parties that receive Users' personal data or events that are beyond the reasonable control of Via including, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.

4. Opt-Out Policy

4.1. The subsidiaries and Third Party Service Providers with whom Via may share Personal Information provided by Users are not permitted to market their own services or send promotional e-mails to Users. Via provides all Users with the opportunity to opt-out of receiving non-essential, promotional, or marketing-related communication from itself or its partners. These settings can be found on Websites.

4.2. If a User wishes to remove his/her/its contact information from all Via lists and newsletters, the User can click on the "unsubscribe" link or follow the instructions in each e-mail message. Alternatively, the User can contact Via at care@via.com. Via reserves the right to limit membership based on availability of contact information. All Users will be notified by email prior to any actions taken.