Privacy Policy

Introduction

LIBE recognizes the importance of privacy of its users and also of maintaining confidentiality of the information provided by its users as a responsible data controller and data processor.

This Privacy Policy provides for the practices for handling and securing user's Personal Information (defined hereunder) by LIBE and its subsidiaries and affiliates.

This Privacy Policy is applicable to any person (‘User’) who books, intends to book, or inquires about any product(s) or service(s) made available by LIBE through any of LIBE’s customer interface channels including its website, mobile site, mobile app & offline channels including call centers and offices (collectively referred herein as "Sales Channels").

For the purpose of this Privacy Policy, wherever the context so requires "you" or "your" shall mean User and the term "we", "us", "our" shall mean LIBE. For the purpose of this Privacy Policy, Website means the website(s), mobile site(s) and mobile app(s).

By using or accessing the Website or other Sales Channels, the User hereby agrees with the terms of this Privacy Policy and the contents herein. If you disagree with this Privacy Policy, please do not use or access our Website or other Sales Channels.

This Privacy Policy does not apply to any website(s), mobile sites, and mobile apps of third parties, even if their websites/products are linked to our Website. User should take note that information and privacy practices of LIBE’s business partners, advertisers, sponsors, or other sites to which LIBE provides links may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties with whom you interact.

This Privacy Policy is an integral part of your User Agreement with LIBE and all capitalized terms used, but not otherwise defined herein, shall have the respective meanings as ascribed to them in the User Agreement.

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:

Registration on the Website:

Information which you provide while subscribing to or registering on the Website, including but not limited to information about your personal identity such as name, gender, marital status, religion, age, profile picture, etc., your contact details such as your email address, postal addresses, frequent flyer number, telephone (mobile or otherwise) and/or fax numbers. The 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).

Other information:

We may also collect some other information and documents including but not limited to:

• Transactional history (other than banking details) about your e-commerce activities, buying behavior.
• Your usernames, passwords, email addresses, and other security-related information used by you in relation to our Services.
• Data either created by you or by a third party and which you wish to store on our servers such as image files, documents, etc.
• Data available in the public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures, or any other information that is permitted to be received as per your account settings) as a part of your account information.
• Information pertaining to any other traveler(s) for whom you make a booking through your registered LIBE account. In such cases, you must confirm and represent that each of the other traveler(s) for whom a booking has been made has agreed to have the information shared by you disclosed to us and further be shared by us with the concerned service provider(s).
• For international bookings, Users, in compliance with the Liberalized Remittance Scheme (LRS) of RBI or any other law may be required to provide details such as their PAN information or passport details number or any such information required by Service Provider. Such information shall be strictly used as per the aforesaid requirements only. In case a User does not wish to provide this information, LIBE may not be able to process the booking. LIBE will never share User’s PAN details without their prior consent unless otherwise such action is required by any law enforcement authority for investigation, by court order, or in reference to any legal process.

Such information shall be strictly used for the aforesaid specified & lawful purpose only. User further understands that LIBE may share this information with the end service provider or any other third party for provision and facilitation of the desired booking. LIBE will always redact all/any sensitive & confidential information contained in the vaccination certificate, passbook, bank statement, or any other identity card submitted for the purpose of availing a service, promotional offer, or booking a product on the Website. In case a User does not wish to provide this information or opts for deletion of the information already provided, LIBE may not be able to process the desired booking request. LIBE will never share any of the above information collected including PAN card details, Vaccination status & certificate, Passport details, Aadhar Card details without their prior consent unless otherwise such action is required by any law enforcement authority for investigation, by court order, or in reference to any legal process.

HOW WE USE YOUR PERSONAL INFORMATION:

The Personal Information collected may be 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 the 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;
• Customize the content of our 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.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

LIBE 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.

INFORMATION SHARING

In order to provide some of our Services, we may need to share information with certain other third parties, including our group of companies, in the following circumstances:

• Our Group of Companies: We share information with companies in our corporate family so we can provide you with information about products and services, both travel-related and others, which might interest you. This sharing also allows us to better understand how you interact with the websites, apps, and services of our group companies. These companies and websites will comply with this Statement and all applicable laws governing the transmission of promotional communications.
• Experience Suppliers and travelers: We may share travelers’ personal information with suppliers of experiences to allow them to fulfill the bookings made through our Services. We may also share personal information of experience suppliers with travelers, including but not limited to where there is a dispute between the two parties.
• Service Providers: We share information with certain service providers used to facilitate our Services, including to help with transactions.
• Business Partners: We may share information about you, your Devices, and your use of our Services with our trusted business partners. For example, we may share information so that we can facilitate payments for services you may see promoted on the websites of our partners. This sharing is generally pursuant to written agreements which include confidentiality, privacy, and security obligations; please note, however, that we do not control the privacy practices of these third-party business partners.
• Social Media Sites: When you use our Services and elect to share information with third-party social media websites, the information you share will be governed by the privacy policies of those social media websites and the privacy settings you have set with those social media websites.
• Advertising Networks: We sometimes collect and share information about your interests with advertising networks and data aggregators. Some of these companies are members of the Network Advertising Initiative or the Digital Advertising Alliance, which offer a single location to opt out of ad targeting from member companies.
• Fraud Detection Companies: Third parties may assist us by providing us with their fraud detection technologies.
• Other third parties, such as referring websites: Third parties may also assist us in collecting information by, for example, operating features of our website or facilitating the delivery of online advertising tailored to your interests. Other third parties may also provide us with their content and contract generation, management, and hosting tools. Third parties may only collect or access information as needed to perform their permitted functions. If and to the extent these third parties only assist us to perform our processing operations, we have bound them contractually to only act on our behalf as so-called data processors.

Certain Device operating system versions permit you to opt out of certain types of information sharing, including to certain advertising networks. You can change the privacy settings of your Device at any time in order to turn off the functionality that collects and shares location information. Please check your Device settings if you want to limit such tracking. However, turning off location-sharing may affect certain features that we offer. If you have any questions about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:

• To comply with legitimate and enforceable subpoenas, court orders, or other legal processes; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.
• To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of LIBE, our customers, or others; and in connection with our Terms of Use and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

INFORMATION CHOICES

You have options with respect to the processing and use of your information by us. You can access, update, and even deactivate your account by visiting the “Profile” section on our website or app. In addition, you can do the following:

• Choose the way we communicate with you.
• Choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our website.
• Prevent the collection of certain geolocation information (e.g. by switching off location services for our app in the settings of your phone), but note that turning off location sharing may affect certain features of our Services.
• Deactivate your account directly from within your Profile. We may retain some information associated with your account (including past transactions) for internal purposes including backups, fraud prevention, dispute resolution, investigations, our own legitimate business interests, and legal compliance for the period necessary to fulfill the purposes outlined in this Statement.
• As a registered user, you can modify your marketing preferences in the Notifications section of the website.
• Unsubscribe from promotional messages, including emails with travel-related opportunities, in any such email we send.

INFORMATION ON CHILDREN

• Our Services are not intended for children, which we consider to be: (i) individuals that are 13 years of age or under, or the age of privacy consent in your jurisdiction; or (ii) when processing data on the basis of a contract, the age of legal capacity to enter into the agreement.
• We will only collect or process information belonging to children under very limited circumstances. We might need to collect personal information belonging to children as part of our Service if, for example, the personal information is required as part of an experience-related reservation. We will only collect personal information belonging to children if it is provided by and with the consent of a parent or guardian. If we become aware that we have processed the personal information of a child without the valid consent of a parent or guardian, we will delete the personal information.

INFORMATION TRANSFERS

• We offer our Services to users located in many different jurisdictions. If we transfer your information to other countries, we will use and protect that information as described in this Statement and in accordance with applicable law.

INFORMATION SECURITY

We have implemented appropriate administrative, technical, and physical security procedures to help protect your information. We only authorize specific personnel to access personal information and they may do so only for permitted business functions. We use encryption when transmitting your information between your system and ours, and between our system and those of the parties with whom we share information. We also employ firewalls and intrusion detection systems to help prevent unauthorized access to your information. However, we cannot guarantee the security of information from unauthorized entry or use, hardware or software failure, or other circumstances outside of our control.

INFORMATION DELETION AND RETENTION

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise, or defend any legal rights.

COOKIES

We want your access to our Services to be as easy, efficient, and useful as possible. To help us do this, we use cookies and similar technologies to improve your experience, to enhance website security, and to show you relevant advertising.

Cookies are small text files that are automatically placed on your Device when you visit almost any website. They are stored by your internet browser and contain basic information about your internet use. Your browser sends the information from these cookies back to a website every time you revisit it, so it can recognize your Device and improve your experience by, among other things, providing you with personalized content. We also use other tracking technologies, such as pixel, SDKs, or server logs, that have a similar functionality. We also use cookies and tracking technologies to remember your login details, so you don’t have to re-enter them repeatedly when you use our Services or to help us understand your preferences.

To give you control, we provide you with a Cookie Consent Tool which allows you to adjust and customize your cookie settings. You can access the Cookie Consent Tool by clicking the “Cookie Consent” link at the bottom of every page and modify your preferences in our cookie banner. In addition, you can manage cookies through the settings of your internet browser. You have the right to withdraw your consent to cookies at any time by clicking on the “Cookie Consent” link and modifying and saving your preferences. In the settings of your Internet browser, you can choose which cookies to accept and reject.

If you decline certain cookies, your access to some functionality and areas of our Services might be degraded or restricted.

Our use of any information we collect through cookies is subject to this Statement, which is linked on every page of our website.

STATEMENT CHANGES

We may update this Statement in the future. If we believe any changes are material, we will let you know by doing one or more of the following: sending you a communication about the changes, placing a notice on the website, and/or posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices.

PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS

When the LIBE app is installed on your phone or tablet, a list of permissions appear and are needed for the app to function effectively. There is no option to customize the list. The permissions that LIBE requires and the data that shall be accessed and its use is as below:

Android permissions:

• Device & App history: We need your device permission to get information about your device, like OS (operating system) name, OS version, mobile network, hardware model, unique device identifier, preferred language, etc. Basis these inputs, we intend to optimize your travel booking experience, use OS-specific capabilities to drive great in-funnel experiences using components of the device’s OS, etc.
• Camera: This permission enables you to use your camera from within the application to upload a new profile picture, upload an image for sharing hotel reviews, and also allows you to take videos to upload as video reviews on our application. This permission will also enable you to scan QR codes for easy UPI payments.
• Identity: This permission enables us to know about details of your account(s) on your mobile device. We use this info to auto-fill your email IDs and provide a typing-free in-funnel experience. It helps us map email IDs to a particular user to give you the benefit of exclusive travel offers, wallet cash-backs, etc. It also allows facilitating your Facebook and Google+ login.
• Location: This permission enables us to give you the benefit of location-specific deals and provide you a personalized in-funnel experience. When you launch the LIBE app to make a travel booking, we auto-detect your location so that your nearest airport or city is auto-filled. We also require this permission to recommend you nearest hotels in case you are running late and want to make a quick last-minute booking for the nearest hotel. Your options are personalized based on your locations. For international travel, this enables us to determine your time zone and provide information accordingly.
• SMS: If you allow us to access your SMS, we read your SMS to autofill or prepopulate ‘OTP’ while making a transaction and to validate your mobile number. This provides you a seamless purchase experience while making a booking and you don’t need to move out of the app to read the SMS and then enter it in the app.
• Phone: The app requires access to make phone calls so that you can make phone calls to hotels, airlines, and our customer contact centers directly through the app.
• Contacts: If you allow us to access your contacts, it enables us to provide a lot of social features to you such as sharing your hotel/flight/holidays with your friends, inviting your friends to try our app, send across referral links to your friends, etc. We may also use this information to make recommendations for hotels where your friends have stayed. This information will be stored on our servers and synced from your phone.
• Photo/Media/Files: The libraries in the app use these permissions to allow map data to be saved to your phone's external storage, like SD cards. By saving map data locally, your phone doesn't need to re-download the same map data every time you use the app. This provides you a seamless Map-based Hotel selection experience, even on a low bandwidth network.
• Wi-Fi connection information: When you allow us the permission to detect your Wi-Fi connection, we optimize your experience such as more detailing on maps, better image loading, more hotel/ flights/ package options to choose from, etc.
• Device ID & Call information: This permission is used to detect your Android ID through which we can uniquely identify users. It also lets us know your contact details using which we pre-populate specific fields to ensure a seamless booking experience.
• Calendar: This permission enables us to put your travel plan on your calendar.
• Bluetooth: This permission enables us to provide you services of the third parties that make available certain features of their products/services on our application. The permission specifically enables our third-party service providers whose services you book on the application to permit you to lock and unlock your self-driven vehicles seamlessly.
• Video/Audio: This permission enables you to upload videos on our application or to submit video reviews of your hotel/property stays and thereby providing you with new ways of providing reviews of your experience on our application. The audio permission enables us to ensure that the video content that you upload has clear audio in its background.
• Phone Number: We need the permission of access to phone numbers to provide a seamless login experience, to optimize your travel booking experience, and to enable you to obtain UPI services and to prevent fraud in some cases on our application.
• IMEI/IMSI: This permission enables us to identify different users uniquely and helps us to prevent fraud on our application.
• Subscription Information: Your subscription information enables us to provide you with a seamless experience depending upon your network and to optimize the application’s performance. In addition, this also enables us in providing to you the train status even in an offline mode and additionally even in a no network area you can get fully aware of the status of the train you want to search for.
• SIM Serial Number: This permission enables us to read your SIM serial number and helps us in authenticating your mobile number for UPI registration. It helps us to ensure that the mobile number you are using is actually present on your device that you are using to register for UPI.

iOS Permissions:

• Notifications: If you opt-in for notifications, it enables us to send across exclusive deals, promotional offers, travel-related updates, etc. on your device. If you do not opt for this, updates for your travel like PNR status, booking confirmation, refund (in case of cancellation), etc. will be sent through SMS.
• Contacts: If you opt-in for contacts permission, it enables us to provide a lot of social features to you such as sharing your hotel/flight/holidays with your friends, inviting your friends to try our app, send across referral links to your friends, etc. We will also use this information to make recommendations for hotels where your friends have stayed. This information will be stored on our servers and synced from your phone.
• Location: This permission enables us to give you the benefit of location-specific deals and provide you with a personalized in-funnel experience. When you launch our app to make a travel booking, we auto-detect your location so that your nearest Airport or City is auto-filled. We require this permission to recommend your nearest hotels in case you are running late and want to make a quick last-minute booking for the nearest hotel. Your options are personalized based on your locations. For international travel, this enables us to determine your time zone and provide information accordingly.