At Navigatio Travel Solutions Private Limited (“Navigatio”), we understand the significance of your privacy and are committed to safeguarding the confidentiality of the personal information you entrust to us. As a responsible data controller and processor, we take every reasonable measure to ensure that your data is handled securely and transparently.

This Privacy Policy outlines the principles and practices followed by Navigatio and its affiliated entities regarding the collection, use, processing, and protection of your personal information (“Personal Information”) across our various service platforms.

This Policy applies to any individual (“User”) who accesses, inquiries about, or purchases any product or service offered by Navigatio through its customer engagement channels, including the website, mobile application, mobile site, and offline touchpoints such as call centres and physical offices (collectively referred to as “Sales Channels”).

For the purposes of this Policy, the terms “you” or “your” refer to the User, while “we,” “us,” or “our” refer to Navigatio. The term “Website” encompasses all of our online platforms, including websites, mobile sites, and mobile applications.

By using any of the Sales Channels, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with this Policy, we advise you not to access or use our platforms or services.

Please note that this Policy does not extend to third-party websites, mobile sites, or mobile applications, even if they are linked through our website. The data practices and privacy policies of such third parties may differ substantially from ours. We encourage you to independently review the privacy policies of any external parties with whom you interact.

This Privacy Policy forms a part of and should be read in conjunction with the User Agreement governing your use of Navigatio’s services. Any capitalized terms not otherwise defined herein shall carry the meaning assigned to them in the User Agreement.

CONTENT

By accessing the Booking Platform, submitting information, or availing of the services offered thereunder, you expressly consent to the collection, use, storage, disclosure, and processing of your personal information, including any sensitive personal data or information, in accordance with this Policy.

Type of Information We Collect and Its Legal Basis

The information detailed herein is collected to enable Navigatio to provide the services requested by you and to comply with applicable legal obligations, contractual requirements, and responsibilities toward third parties, as per the User Agreement.

"Personal Information" of the User shall include any data voluntarily shared by the User or collected by Navigatio for the following purposes:

Registration on the Website: information provided at the time of subscribing or registering, which may include:
- Full name, gender, marital status, religion, age, profile photo;
- Contact information such as email address, postal address, phone numbers, and frequent flyer numbers;
- Financial information including bank account details, credit/debit card data, income details, lifestyle preferences, billing history, and payment preferences.

Other Information and Documents: Navigatio may also collect:

-Transactional history relating to bookings and services (excluding banking data);
- Login credentials, passwords, and authentication details used in connection with our Services;
- Uploaded files including images and documents stored on Navigatio’s servers;
- Public data or information obtained from third-party sources including linked social media profiles (e.g., name, email, friend lists, profile images);
- Information pertaining to co-travelers for whom bookings are made, with confirmation that consent has been obtained for data sharing;
- Documents required for visa facilitation services, including passport copies, bank statements, completed application forms, and photographs;
- PAN and passport details for international bookings, as mandated by applicable regulations or the Liberalized Remittance Scheme (LRS) of RBI;
- Government-issued identification and declarations required for contactless hotel check-ins (e.g., Aadhaar, driver’s license, voter ID);
- Covid-19 vaccination status and certificates, when relevant to travel requirements or as voluntarily submitted.

This information is used strictly for the specified purposes, including fulfillment of service obligations and legal compliance. Navigatio may share such data with end service providers or third parties for facilitation of bookings. Sensitive and confidential information—such as vaccination certificates, bank passbooks, identity documents—shall be redacted before being shared.

If the User chooses not to share this information or requests deletion of data already provided, Navigatio may be unable to fulfill the relevant booking or service. Navigatio shall not disclose such personal information to any external party without the prior consent of the User, except as required under applicable law, by order of a court, or in response to a lawful investigative request from a competent authority.

How We Use Your Personal Information

Navigatio Travel Solutions Private Limited uses the Personal Information collected from Users for the provision and improvement of services offered through its platform. Such usage includes, but is not limited to, the facilitation of bookings, communication with users, and personalization of content.

During the Booking Process:

- Payment details including the cardholder’s name, encrypted credit/debit card number, expiration date, wallet information, and banking details, as provided and permitted by the User;
- Saved traveler profiles associated with the User’s account to streamline the booking process.

This information is used to efficiently complete and confirm transactions and reservations with the relevant service providers.

General Usage of Personal Information:

- To confirm reservations with third-party service providers;
- To inform the User of transaction status and booking details;
- To send booking confirmations, updates, or alerts via SMS, WhatsApp, or other messaging platforms;
- To notify Users of modifications or cancellations to existing bookings;
- To allow Navigatio’s customer service representatives to assist or contact the User as necessary;
- To personalize the content and functionality of the website, mobile site, and mobile application;
- To request User feedback, ratings, or reviews on availed services;
- To send verification communications and authenticate accounts;
- To detect and prevent fraudulent activity, misuse, or abuse of services;
- To contact Users on occasions such as birthdays or anniversaries with personalized messages, offers, or rewards.

Personal Data Collected from Other Sources and Through Automated Means

A. Data Collected Automatically

When you interact with the website, mobile site, or mobile application of Navigatio Travel Solutions Private Limited (“Navigatio”), certain information is collected automatically, regardless of whether a booking is completed. This data includes:

• IP address.

• Date and time of access.

• Device and system information, such as browser type, operating system, application/software version, and language preferences.

• Usage and navigation data, including page views, clicks, and referring URLs.

For mobile device users, we may also collect:

• Device identifiers and settings.

• Device-specific characteristics.

• System activity logs, including crash reports and performance diagnostics.

• Information relating to the source and method of accessing the Navigatio platform (e.g., referrer site or application).

This information is used to ensure optimal functionality of our services, enhance user experience, perform diagnostics, and secure our systems.

B. Data Received from Third Parties

In addition to the data, you provide directly, Navigatio may also obtain Personal Information from other sources, including:

• Affiliate and distribution partners.

• Subsidiaries and affiliated entities within the Navigatio group.

• Independent third-party service providers or business associates.

This information may be combined with the data you have shared with us to improve our service delivery and manage your booking more efficiently.

For example, when Navigatio’s services are accessed through a partner’s platform, the booking information you submit is forwarded to us by that partner. Likewise, payment details necessary to complete a transaction may be received from third-party payment processors to ensure the fulfilment of your booking and support any post-booking processes.

In the unfortunate event of a complaint raised by a booking agency—such as in cases of misconduct—Navigatio may receive relevant information pertaining to that incident to investigate and take appropriate action.

Additionally, if you use communication tools integrated into our platform to interact with service providers (e.g., hotels, transport operators), we may collect metadata related to those interactions, including caller identity, contact origin, and the date, time, or duration of the communication.

Personal Data Provided About Others

In circumstances where you are making bookings, reservations, or initiating service requests on behalf of other individuals, you may be required to furnish their personal data, including but not limited to names, contact information, identification details, or travel preferences.

Users of business accounts or other shared service features may maintain contact records or utilize address book functionalities to facilitate the management and coordination of travel or stay arrangements for colleagues, employees, or associates.

Additionally, certain features of the Booking Platform, such as Wishlist’s, travel communities, or referral programs, may involve the sharing of personal data with other users or third parties. Where such features are used, you are deemed to have the authority to disclose such data and are solely responsible for ensuring that the individuals concerned have been informed of, and have consented to, such disclosure and the way their information will be used in accordance with this Privacy Policy.

Marketing, Promotions, Research and Programs

Navigatio may conduct marketing activities, promotions, surveys, and research initiatives to assess user preferences, enhance service offerings, and improve overall user experience. These activities may include, but are not limited to, contests, rewards programs, promotional events, and service-specific communications.

In connection with such programs, Navigatio may collect personal data such as contact information, survey responses, and interaction history. This information may be used to:
(a) Notify participants regarding contest outcomes or rewards;
(b) Analyze survey results for service enhancement and promotional strategy;
(c) Send targeted communications regarding fares, offers, deals, and new services;
(d) Facilitate user interaction with newly launched or enhanced features on the Booking Platform.

Registered users may receive periodic marketing emails, newsletters, and promotional content unless they opt out in accordance with this Policy. Navigatio may, at its discretion, introduce reward programs wherein user information may be shared with third parties responsible for reward fulfillment. Users may opt out of such programs by contacting us directly.

Navigatio may also engage third-party service providers for tasks such as payment processing, data analytics, hosting, and credit assessment, and may share anonymized or aggregated user data for these purposes, subject to appropriate data protection safeguards.

Data Retention

Navigatio shall retain personal data for no longer than is necessary to fulfill the purpose for which it was collected or as mandated by applicable law. Anonymized or aggregated data may be retained for research or statistical purposes.

Data Security

Navigatio implements industry-standard technical and organizational measures to safeguard your personal data against unauthorized access, alteration, disclosure, or destruction. While we strive to protect your information, we disclaim liability for breaches occurring beyond our reasonable control.

Withdrawal of Consent and Permissions

Users may, at any time, withdraw their consent for the collection, processing, or disclosure of their Personal Information or may decline to provide any permissions previously granted on the Website or mobile application.

Such withdrawal may result in limited access to certain features or services, or in some cases, render Navigatio unable to fulfill service obligations.

To withdraw consent or modify permissions, Users may send a written request to:

Email: privacy@navigatio.guru

Navigatio shall process such requests in accordance with applicable data protection regulations and within a reasonable timeframe.

Access, Correction, and Deletion of Your Personal Information

Users may access their Personal Information by logging into their registered account on the Navigatio travel solutions private limited platform. Through the user account, you may review, update, or delete your Personal Information, except for certain mandatory fields required for continued service provision or regulatory compliance.

If you do not hold a registered user account, or if you are unable to access or modify your information through the platform, you may submit a request for access, correction, or deletion by contacting us at:

Email: privacy@navigatio.guru

Navigatio shall process such requests in accordance with applicable laws and within a reasonable timeframe.

Eligibility to Transact

To use the services offered by Navigatio travel solutions private limited and to lawfully enter into agreements on the Booking Platform, Users must be at least 18 years of age.

By accessing or using the Website, mobile application, or any other interface provided by Navigatio, you confirm that you meet the minimum age requirement and are legally competent to provide consent for the collection and processing of your Personal Information in accordance with this Privacy Policy.

Cookies

Navigatio travel solutions private limited (“Navigatio”) employs the use of cookies to enhance user experience on its website and to facilitate the display of advertisements that may be relevant to the User. The use of cookies by Navigatio aligns with standard industry practices adopted by reputable online platforms.

Cookies are small data files stored on a user’s device by the web browser. These files allow Navigatio to provide more efficient service by, among other things, eliminating the need to repeatedly input login credentials, customizing content, and enabling the display of targeted advertisements based on the User’s interests and interactions on the Website.

In certain instances, cookies may be placed by third-party advertising servers or partner companies to assess the effectiveness of advertisements displayed across the Website or to track aggregate user behaviour. This may involve the use of technologies such as pixel tags or similar tools that gather anonymous statistical data. No personally identifiable information is collected during this process. The information collected remains anonymous and is used solely to optimize content delivery and advertising.

Most internet browsers accept cookies automatically. However, Users retain the right to manage cookie preferences by adjusting browser settings to refuse or selectively accept cookies. Blocking or restricting Navigatio’s cookies may affect the usability or functionality of specific features on the Website.

Session Data Logging

Each time a User accesses the Website, Navigatio may collect and log session data, which may include the User’s IP address, browser type, operating system, and usage patterns during the visit. Session data provides insights into how Users interact with the Website, including pages accessed, duration of visits, and usage trends.

This data helps Navigatio to improve system performance, diagnose technical issues, and refine service offerings. While session data does not directly identify individual Users, it may be possible to infer general geographic location, or the Internet Service Provider (ISP) used to access the Website.

Disclosure and Sharing of Personal Information

Service Providers and Suppliers

Your Personal Information may be shared with third-party service providers such as airlines, hotels, railways, bus operators, cab rental agencies, or other suppliers responsible for fulfilling your bookings. By proceeding with a booking through Navigatio travel solutions private limited (“Navigatio”), you expressly authorize us to share your information with such service providers.

Navigatio only shares data necessary for the fulfillment of services, and these providers are not authorized to use your information for any purpose beyond the agreed service provision. However, these service providers operate as independent data controllers, and Navigatio does not assume liability for their processing of Personal Information. Users are encouraged to review the privacy policies of any such third-party service providers prior to engaging their services.

Navigatio does not sell or rent individual customer names or other Personal Information to unrelated third parties. However, we may share such data with alliance partners or vendors that are contractually engaged with us to offer value-added services, referral benefits, or promotional offers based on the User’s interaction history.

Companies Within the Navigatio Group.

To provide enhanced personalization and improved service delivery, Navigatio may share your Personal Information with its affiliate or associate entities under secure and controlled conditions. Such information may be used to provide you with travel or leisure-related services, respond to your inquiries, or offer customer support.

In the event of a corporate restructuring, acquisition, or sale of business assets, customer information, including Personal Information, may be transferred to the acquiring entity. Such transfer will be subject to the terms of this Privacy Policy, or another comparable policy as required by law.

Business Partners and Third-Party Vendors

Navigatio may share limited Personal Information with trusted business partners for the purpose of offering travel-related services such as insurance, wallet protection, or destination-specific benefits. These offerings may include free or paid services curated for Navigatio customers. Users opting into such services are advised that the usage of their data will be governed by the privacy policies of the respective service providers.

Additionally, Navigatio may engage third parties to provide technical and operational support services, including but not limited to: data hosting, payment processing, marketing analytics, and fraud detection systems. These partners are bound by confidentiality agreements and authorized to use the data solely for the purposes defined in their contract.

We may also use anonymized or aggregated data for service improvement, statistical analysis, and performance tracking. Such information may be shared with advertisers, business affiliates, or external consultants without revealing any individual’s identity. Navigatio retains all rights to this aggregated information, which may be used for commercial or analytical purposes.

On occasion, Navigatio may hire external agencies to conduct market research, surveys, or analytics. The data shared in such cases, including cookie-based information, will remain protected by strict confidentiality clauses and limited in use solely to the contracted scope of work, in compliance with applicable legal regulations.

Disclosure of Information

Navigatio may disclose a User’s Personal Information under the following exceptional circumstances:

When mandated by applicable law, regulatory orders, court directives, or requests from enforcement authorities.

In the ordinary course of business operations or audits.

To maintain system security and prevent data breaches.

To enforce Navigatio’s legal rights or protect the rights, safety, or property of its employees, affiliates, or Users.

Where reasonably necessary to identify, investigate, or take legal action against persons or entities causing harm or interference with Navigatio’s operations, whether intentional or otherwise.

Such disclosure may be made without prior notice to the User, and Navigatio shall not be held liable for any damages arising from such lawful disclosure or storage of information.

Personal Data of Children

Navigatio travel solutions private limited (“Navigatio”) does not knowingly collect Personal Information from individuals under the age of 16. Our services and the Booking Platform are not intended for use by children unless such data is provided directly by, and with the express consent of, a parent or legal guardian.

Limited exceptions may apply wherein Personal Information of children under 16 is required for purposes such as:

Completing a reservation or booking.

Procuring ancillary travel-related services.

Participating in features or promotions specifically designed for families. In such cases, all information must be submitted by a parent or guardian who consents to the collection and use of the data on behalf of the minor. If Navigatio becomes aware that it has inadvertently collected or processed the Personal Information of a child under the age of 16 without verifiable parental consent, such data will be promptly deleted from our systems

User Feedback and Surveys

Navigatio may, from time to time, conduct voluntary surveys for the purpose of collecting feedback, suggestions, or opinions from users of its Booking Platform. Such surveys may be administered either online or offline and participation therein shall be strictly optional.

The information collected pursuant to such surveys shall typically be aggregated and utilized for the enhancement of the Booking Platform, improvement of services, and the development of user-centric content, features, and promotional offerings. Unless expressly stated to the contrary at the time of participation, the identity of respondents shall remain anonymous and shall not be linked to any personally identifiable information.

By participating in a survey, the user acknowledges and agrees to the processing of any information provided therein in accordance with this Privacy Policy.

Permissions Required for Using Our Mobile Applications

When the Navigatio mobile application is installed on your device (Android or iOS), specific permissions are requested to ensure optimal functionality and user experience. These permissions are integral to delivering our services and are governed by applicable privacy and data protection laws. Users acknowledge that by granting these permissions, they consent to the corresponding access and data usage as detailed below.

Android Permissions

Device & App History: Allows us to access device metadata such as OS version, device model, network information, and preferred language. This information is used to tailor the booking experience and ensure compatibility with device-specific features.

Camera: Enables capturing and uploading profile pictures, scanning QR codes for UPI payments, and submitting hotel or travel video reviews.

Identity: Allows auto-filling of user email accounts and supports single sign-on features (e.g., Facebook, Google).

Location: Used to auto-detect the user’s current location for personalized search results and booking options (e.g., nearby hotels, airports).

SMS: Facilitates automatic reading of OTPs for seamless verification and checkout processes.

Phone: Allows in-app calling features to contact hotels, airlines, or Navigatio’s support team directly.

Contacts: Enables social sharing functions, referrals, and travel suggestions based on your network’s activity, where permitted.

Photo/Media/Files: Supports offline map usage by allowing temporary storage of map data, improving app performance under limited connectivity.

Wi-Fi Connection Information: Optimizes app performance such as faster loading of images, maps, and content.

Device ID & Call Information: Used for identifying users via Android ID to enhance personalization and facilitate fraud detection.

Calendar: Allows saving of booking-related events directly to the user’s calendar.

Bluetooth: Facilitates use of third-party services (e.g., locking/unlocking of self-drive vehicles booked through the app).

Video/Audio: Permits uploading and recording of hotel or travel-related video reviews with synchronized audio.

Phone Number: Accesses the phone number to streamline login, support UPI features, and help prevent fraudulent activity.

IMEI/IMSI: Used to uniquely identify devices and detect fraudulent behavior.

Subscription Information: Optimizes performance based on network type and enables offline features such as real-time train status updates.

iOS Permissions

Notifications: If granted, enables delivery of real-time alerts, promotional offers, booking confirmations, and travel-related updates.

Contacts: Allows sharing of bookings with friends and facilitates referrals or personalized hotel recommendations.

Location: Used to customize user experience based on real-time location, including nearest airport or hotel search functionality and localized offers

Amendments

Navigatio travel solutions private limited reserves the right to amend, update, or modify this Privacy Policy at its sole discretion from time to time, to comply with evolving legal, regulatory, operational, and business requirements. Where material changes are made, Users will be notified in a manner deemed appropriate—such as through a notice on the Website or by email, where applicable. Users are encouraged to review this Privacy Policy periodically to stay informed about how their Personal Information is being protected and processed. For questions or concerns relating to this Privacy Policy, you may write to us at:

Email: privacy@navigatio.guru

Navigatio shall make reasonable efforts to respond to all legitimate queries and concerns in a timely manner.

Contact Us

Navigatio travel solutions private limited has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws and for addressing any concerns regarding the collection, use, or handling of your Personal Information.

If you have any questions, complaints, or concerns regarding this Privacy Policy or the way in which your personal data is processed, you may contact our Data Protection Officer at:

Email: dpo@navigatio.guru