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Privacy Policy


PRIVACY NOTICE

Tata Digital Private Limited (“Tata Digital” or “we”) takes the privacy of your
information seriously. This Privacy Notice describes the types of personal
information we collect from you through our website (including sub-domains and
microsites) and the Tata Consumer Platform ("Tata Neu"). It also describes the
purposes for which we collect that personal information, the other parties with
whom we may share it and the measures we take to protect the security of your
data. It also tells you about your rights and choices with respect to your
personal information, and how you can contact us about our privacy practices.

You are advised to carefully read this Privacy Notice before using or availing
any of our products and/or services.

1. DEFINITIONS AND KEY CONCEPTS

In this Privacy Notice, the following definitions are used:

Data

personal information, including sensitive personal information and special
category personal data (as defined under Data Protection Laws) about you, which
we collect, receive or otherwise process in connection with your use of our
website and/or the Tata Neu.

Cookies
a small file placed on your device by our website or Tata Neu when you either
visit or use certain features of our website or Tata Neu.  A cookie generally
allows a website or mobile application to remember your actions or preference
for a certain period of time.

Data Protection Laws
any applicable law for the time being in force relating to the processing of
Data.

Partners

select third parties (including Tata Group Entities) with whom we have contracts
for the businesses described in this Privacy Notice.

Service Providers

includes entities which provide services to Tata Digital and to whom we may
disclose your Data for a specific purpose pursuant to a written contract.

Tata Digital

Tata Digital, a company incorporated in India whose registered office is at Army
& Navy Building, 148 M. G. Road, Fort, Mumbai 400001, India.

Tata Group Entity

Tata Sons Private Limited, and its subsidiaries, affiliates, associate companies
and joint venture companies.

User or you

the natural person who accesses our website or Tata Neu.

Tata Digital's status as controller or processor:

Tata Digital's business involves:

(a) hosting third party applications of Tata Group Entities and other
participating entities ("Third Party Applications") on Tata Neu for the purposes
of offering you access to these Third Party Applications in which case our
primary purpose for using your Data is to provide you with access to the Third
Party Applications on behalf of the relevant Tata Group Entities and other
participating entities (though we may under certain circumstances also use your
Data for our own purposes in this context);

(b) operating our website and Tata Neu to provide you with "bundles" of products
and/or services offered by one or more Tata Group Entities that we have grouped
together or our own products or services, in which case we use your Data for our
own purposes; and

(c) operating loyalty programmes and benefits (either our own or on behalf of
Tata Group Entities), in which case we either use your Data for our own purposes
(where we are operating the loyalty programme and offering it to you directly)
or on behalf of the relevant Tata Group Entities (where we are operating the
loyalty program on behalf of Tata Group Entities).

 For the purposes of certain applicable Data Protection Laws, we will act as a
"controller" when we use your Data for   our own purposes and a "processor" when
we use your Data for and under the instructions of a Tata Group Entity   and
other participating entities.

 This Privacy Notice primarily explains how we use your personal data when we
act as a controller of your Data.   Where we act as a "processor" on behalf of a
Tata Group Entity or other participating entity (i.e. the “controller”), 
 please refer to the privacy notice policy of the relevant Tata Group Entity or
other participating entity for information about how they use your Data.

2. WHAT DATA DO WE COLLECT ABOUT YOU

 Tata Digital collects Data for various purposes set out in this Privacy Notice.

 This Data includes, without limitation, the following categories:

(a) Contact information: first and last name, email address, postal address,
country, phone number and other similar contact data.

(b) Financial information: payment instrument information, transactions,
transaction history, preferences, method, mode and manner of payment, spending
pattern or trends, and other similar data.

(c) Technical information: website, device and mobile app usage, Internet
Protocol (IP) address and similar information collected via automated means,
such as cookies, pixels and similar technologies.

(d) Product and service information: Your website or Tata Neu account membership
number, registration information, and program-specific information, when you
request products and/or services directly from us or participate in marketing
programs.

(e) Your reviews, feedback and opinions about our products, programmes and
services.

(f) Loyalty programme information: your loyalty membership information, account
details, profile or password details and any frequent flyer or travel partner
programme affiliation.

(g) Transaction information: date of the transaction, transaction amount,
transaction history and related details;

(h) Other information (which may include sensitive personal information or
special category personal data): Age, sex, date of birth, marital status,
nationality, details of government identification documents provided, occupation
or any other personal information provided by you.

3. HOW WE COLLECT DATA

We collect Data in the following ways:

· Information You Give Us: We receive and store any information you enter on our
website or Tata Neu or give us in any other way. Please see the section below,
titled “Data Shared by You” for more information.

· Automatic Information We Collect: We use “cookies”, pixels and similar
technologies to receive and store certain types of information whenever you
interact with us. Please see the section below, titled “Data That is Collected
Automatically” for more information.

· E-mail Communications: We often receive a confirmation (if your device
supports such capabilities) when you open e-mail from us or click on a link in
the e-mail. You can choose not to receive marketing emails from us by clicking
on the unsubscribe link in any marketing email.

· Automatic Information We Collect from Other Websites: We receive and store
certain types of information when you interact with third-party websites that
use our technology or with whom we have a specific agreement. 

· Information from Other Sources: We may obtain information from other
sources. An example of this is when you authorize a third-party website (such as
the website of another Tata Group Entity) to interact directly with our website
or Tata Neu to provide or receive information about you. In that case, we may
receive information to identify your account with that website. Another example
is where we receive your Data from Tata Group Entities in connection with Tata
Neu for the purposes of enrolment, offering you products, services and benefits
on Tata Neu.

· Information Previously Provided to Tata Group Entities: Where you have shared
any information previously with any of the Tata Group Entities and such Tata
Group Entity is permitted to further share such information, it will share such
information with us. If such information is sensitive personal information or
special category personal data, the Tata Group Entity will only share such
information with us with your consent. Regardless of the terms on which you had
originally provided the information to a Tata Group Entity, you acknowledge
that: (a) we will collect such information from such Tata Group Entity for the
purposes set out in this Privacy Notice; (b) the Tata Group Entity that provides
such information to us is subject to its own compliance obligations under the
Data Protection Laws, and (c) we are not responsible for  any acts or omissions
of such Tata Group Entity in relation to any such compliance obligations under
the Data Protection Laws.

You can make choices about our collection and use of your Data. For example, you
may want to access, edit or remove your Data on our website or Tata Neu. When
you are asked to provide Data, you may decline. For more information, please see
the section below, titled “Your Rights and Choices”.

4. DATA SHARED BY YOU

Tata Digital may collect your Data in several ways from your use of our website
or Tata Neu. For instance:

(a) when you register with us to receive our products and/or services;

(b) when you conduct a transaction or attempt a transaction on our website or
Tata Neu;

(c) when you complete surveys conducted by or for us;

(d) when you elect to receive any communications (including promotional offers)
from us;

(e) from the information gathered by your visit to our website or Tata Neu;

5. DATA THAT IS COLLECTED AUTOMATICALLY

(a) We automatically collect some information when you visit our website or use
Tata Neu. This information helps us to make improvements to our content and
navigation.  The information collected automatically includes your IP address.

(b) Our web servers or affiliates who provide analytics and performance
enhancement services collect IP addresses, operating system details, browsing
details, device details and language settings. This information is aggregated to
measure the number of visits, average time spent on the site, pages viewed and
similar information. Tata Digital uses this information to measure the site
usage, improve content and to ensure safety and security, as well enhance
performance of our website or Tata Neu.

(c) We may collect your Data automatically via Cookies, pixels and similar
technologies in line with settings on your browser. For more information about
Cookies, please see the section below, titled “Cookies, Pixels and Similar
Technologies”.

6. OUR USE OF DATA

Data collected by us may be used by us for the following reasons:

(a) carry out our obligations arising from any contract entered into between you
and us;

(b) provide products and/or services and communicate with you (including through
WhatsApp) about products and/or services offered by us including processing any
payment transactions;

(c) enable Tata Group Entities and Partners to offer their products and/or
services and communicate with you about such products and/or services;

(d) process, disclose, transmit, and/or share the Data with Tata Group Entities,
and other third parties which have business or contractual dealings with us;

(e) provide you with offers (including for financial products and/or services),
personalized services and recommendations and improve your experience on our
website and Tata Neu, including, where permitted under applicable law, by
storing and/or using your payment information to enable future transactions on
Tata Neu to run more smoothly;

(f) operate, evaluate and improve our business, website and Tata Neu;

(g) generate aggregated data to prepare insights to enable us to understand
customer behaviour, patterns and trends with a view to learning more about your
preferences or other characteristics;

(h) provide marketing and promotional campaigns to you based on your profile; 

(i) in connection with loyalty programs owned and operated by us or by other
Tata Group Entities;

(j) communicate with you (including to respond to your requests, questions,
feedback, claims or

disputes) and to customize and improve our services;

(k) enforce the terms of use of our website and Tata Neu;

(l) protect against and prevent fraud, illegal activity, harm, financial loss
and other legal or information security risks; and

(m) serve other purposes for which we provide specific notice at the time of
collection, and as otherwise authorized or required by applicable law.

Where required under relevant Data Protection Laws, we may need to ensure that
there is a legal basis to justify our processing of your Data. There are a
number of different ways that we are lawfully able to process your Data. We have
set these out below.

· Where processing your Data is necessary for us to carry out our obligations
arising from any contracts entered into between you and us: If you enter into a
contract with us in relation to any of our product or service offerings,
including products or service offerings we offer to you directly on Tata Neu, we
may process certain Data about you in order to perform our obligations under
this contract, including to enable us to communicate with you about such
products and/or services and to process your payment transactions.

· Where processing your personal information is within our legitimate
interests: We can process certain Data where it is necessary for the purposes of
the legitimate interests pursued by us or by a third party, except where such
interests are overridden by the interests or fundamental rights or freedoms of
yours which require protection of your Data. The ways in which we may process
your Data for the purposes of our legitimate interests include: 

(a) enforcing the terms of use of our website and Tata Neu;

(b)  generating aggregated data to prepare insights to enable us to understand
customer behaviour, patterns and trends with a view to learning more about your
preferences or other characteristics;

(c) improving our website and Tata Neu and ensuring that they run smoothly;

(d) providing you with offers, personalized services and recommendations and
improving your experience on our website and Tata Neu;

(e) protecting against, and preventing, fraud, illegal activity, harm, financial
loss and other legal or information security risks;

(f) providing marketing and promotional campaigns to you based on your profile;

(g) where permitted under applicable law, storing and/or using your payment
information, including payment instrument information, information about your
transactions, transaction history, preferences, method, mode and manner of
payment and other similar data (collectively, “Payments Data”) for future
transactions on Tata Neu and to inform a third-party merchant, whose site or
application you visit, when you have an account on Tata Neu that can be used for
making payment to such merchant;

(h) communicating with you (including responding to your requests, questions,
feedback, claims or disputes) and customising and improving our services;

(i) operating, evaluating and improving our business;

(j) enabling Tata Group Entities and Partners to offer their products and/or
services and to communicate with you about such products and/or services;

(k) in connection with loyalty programs owned and operated by us or by other
Tata Group Entities; and

(l) processing, disclosing, transmitting, and/or sharing the Data with Tata
Group Entities, and other third parties which have business or contractual
dealings with us.

 Where you give us your opt-in consent to process your personal information: In
certain circumstances, where required under relevant Data Protection Laws, we
will seek to obtain your consent before we undertake certain processing
activities with your Data.


Where required under relevant Data Protection Laws (e.g. under direct marketing
legislation), we will obtain your opt-in consent prior to sharing your Data with
third parties and carrying out certain marketing activities (unless we are
permitted by relevant Data Protection Laws to contact you without your opt-in
consent in relation to goods and services which are similar to those which you
have already purchased, used or interacted with).

You have the right to withdraw your consent to these activities. You can do so
at any time, and details of how to do so can be found in the section below,
titled "Your Rights and Choices".

· Where processing your personal information is necessary for our compliance
with a legal obligation: In certain circumstances, we may disclose your Data for
the purposes of compliance with a legal obligation (for example, to comply with
a law, regulation or compulsory legal request). We do not think that any of the
above activities prejudice you in any way. However, you do have the right to
object to us processing your personal information in certain circumstances. If
you would like to know more about these circumstances and how to object to our
processing activities, please see the section below, titled "Your Rights and
Choices".

Some of the above grounds for processing will overlap and there may be several
grounds which justify our use of your Data.

Further, where required under relevant Data Protection Laws, we will only
process special category personal data’ (as defined under Data Protection Laws)
if there is a valid legal basis, which might involve obtaining your explicit
consent.

Where we use or share or otherwise process your Data as a processor on behalf of
a Tata Group Entity or other participating entity (i.e., the controller) for the
purposes of offering you access to Third Party Applications on Tata Neu or as
part of any services that we provide to that entity, we do so under the
instructions of that entity and that entity is responsible for ensuring that
there is a legal basis for us to use or share your Data on its behalf (if such
legal basis is required under relevant Data Protection Laws).

7. MINORS

Our website and Tata Neu do not offer products or services for use by minors. If
you are under 18, you may use our website or Tata Neu only with the involvement
of a parent or guardian.

8. SHARING OF DATA


We may share your Data in the following ways (and for the purposes of relevant
Data Protection Laws, we may do so either as a controller in our own right or as
a processor on behalf of and under the instructions of another entity in
accordance with our obligations under our agreement with that entity):

(a) Partners: We may make available to you services, products, or applications
provided by Partners for use on or through our website or Tata Neu. If you
choose to use such services, products or applications, Data related to these
uses may be shared with such Partner. 

Such Partners use your Data for the purposes of providing their own products or
services to you. Their use of your Data is subject to their own privacy
policies. For further information on how these Partners process your Data,
please refer to their privacy policies.

(b) Tata Group Entities: We may share your Data with Tata Group Entities for
them to make their products, services and /or applications available to you, to
assist them in reaching out to you in relation to their programs or campaigns
and to process your queries and requests. If such Data is sensitive personal
information or special category personal data, we will only share such Data with
Tata Group Entities with your consent. We may also share your Data with the Tata
Group Entities as is relevant for the purposes set out in Clause 6 above, and to
facilitate the operation of our business. Their use of your Data is subject to
their own privacy policies. For further information on how these Tata Group
Entities process your Data, please review their privacy policies.

(c) Tata Neu: Your Data may be shared with Tata Group Entities and other
participating entities on Tata Neu for the purposes of offering you products and
services on Tata Neu and in connection with loyalty programs. Accordingly, we
may share your Data with other Tata Group Entities, Partners and Service
Providers. 


(d) Service Providers:  We may share your Data with Service Providers who may,
in the course of providing their respective services, receive and process Data.
Examples include storing and analyzing Data, protecting and securing our
systems, providing search results and links, providing customer service, credit
analysis, processing your Data for profiling, user analysis and payment
processing.


These Service Providers will be required to only process Data in accordance with
our instructions. The Service Providers will also be required to safeguard the
security and confidentiality of the Data they process by implementing
appropriate technical and organizational security measures.

(e) When Tata Digital acts as a Service Provider: We may process and share your
Data with Tata Group Entities and Partners when we act as a service provider to
such Tata Group Entities and Partners. In this case, for the purposes of
relevant Data Protection Laws, we act as a processor of the Data on behalf of,
and under the instructions of, the relevant Tata Group Entity or Partner (i.e.
the controller).

(f) Protecting Tata Digital: We may release Data when we believe that disclosure
is reasonably necessary (a) to comply with a law, regulation or compulsory legal
request; (b) to protect Tata Digital or a Tata Group Entity's intellectual
property rights; (c) to protect Tata Digital against harm or financial loss; (d)
when we believe disclosure is necessary to protect individuals’ vital interests,
or (e) in connection with an investigation of suspected or actual fraudulent or
illegal activity. This may include exchanging information with other companies
and organizations for fraud protection, risk management and dispute resolution.

(g) Business Transfers: As we continue to develop our business, we might sell or
buy subsidiaries or business units. Your Data (including in relation to loyalty
programs) may be transferred as part of such transactions.

(h) Third Parties:  We may also share your Data with other third parties where:

a) You request or authorize us to do so;

b) We need to comply with applicable law or respond to valid legal process; or

c) We need to operate and maintain the security of our website or Tata Neu,
including to prevent or stop an attack on our computer systems or networks.

The sharing of your Data will be in line with the processes set out in this
Privacy Notice.


Please note that Tata Group Entities and Partners may have privacy practices
that differ from those of Tata Digital. The use of your Data will be governed by
their privacy statements when you provide Data on their websites.

9. KEEPING DATA SECURE

We will use technical and organisational measures to safeguard your Data and we
store your Data on secure servers.  Technical and organisational measures
include measures to deal with any suspected data breach.  If you suspect any
misuse or loss or unauthorised access to your Data, please let us know
immediately by contacting us by e-mail.

The security of your Tata Neu account depends on you keeping your account
password(s), PINs and other access information confidential. If you share your
Tata Neu account information with a third party, they will have access to your
account and your Data.

It is your responsibility to control access to your mobile device and Tata Neu
on your device, including keeping your password(s) and/or PIN confidential and
not sharing it with anyone. It is also your responsibility to alert us if you
believe that the security of your Data in Tata Neu has been compromised.

10. RETENTION OF DATA

Tata Digital retains Data for as long as necessary for the use of our products
and/or services or to provide access to and use of our website or Tata Neu, or
for other essential purposes such as complying with our legal obligations,
resolving disputes, enforcing our agreements and as long as processing and
retaining your Data is necessary for our legitimate interests. Because these
needs can vary for different data types and purposes, actual retention periods
can vary significantly.

Even if we delete your Data, including on account of exercise of your right
under Clause 12 below, it may persist on backup or archival media for audit,
legal, tax or regulatory purposes.

11. WHERE WE STORE DATA

We may transfer your Data to recipients in India, where we are headquartered,
and other countries. These countries may not have the same data protection laws
as the country in which you initially provided the information. If we transfer
your Data to other countries, we will protect that information as described in
this Privacy Notice, as disclosed to you at the time of data collection or as
described in our program-specific privacy notice.

If the GDPR/United Kingdom’s version of the GDPR applies to our processing of
your Data, we will only process and/or transfer Data outside of the European
Economic Area/United Kingdom where it is compliant with Data Protection Laws and
the means of transfer provides adequate safeguards in relation to your Data,
including for example: 

(a) by way of a data transfer agreement incorporating the current relevant
standard contractual clauses adopted in the European Economic Area/United
Kingdom; or

(b) by transferring your Data to a country where there has been a finding of
adequacy by the European Commission in respect of that country’s levels of data
protection via its legislation; or

(c) where it is necessary for the conclusion or performance of a contract
between us and a third party and the transfer is in your interests for the
purposes of that contract; or

(d) where you have consented to the data transfer.

12. YOUR RIGHTS AND CHOICES

Depending on which country’s laws are applicable to you, you may have various
rights in relation to the Data that we hold about you. To get in touch with us
about any of your rights under Data Protection Laws, please use the contact
details set in the section below, titled “How to Contact Us”.  We will seek to
deal with your request without undue delay, and in any event, within any time
limits provided for in Data Protection Laws (subject to any extensions to which
we are lawfully entitled). Please note that we may keep a record of your
communications to help us resolve any issues which you raise. Where we are
legally permitted to do so, we may refuse your request. 

You may be entitled to the following rights in relation to your Data:

a) Right to Confirmation and Access - you may ask us to confirm what Data we
hold about you at any time, and request us to modify, update or delete such
Data. You may also request a copy of the Data we hold about you.

b) Right to Rectification - you have the right to request that we rectify any
inaccurate or incomplete Data that we hold about you, including by means of
providing a supplementary statement.

c) Right to be Erasure - you have the right to request that we "erase" your Data
in certain circumstances.

d) Right to Restrict Our Use of your Data - you have the right to request that
we restrict our processing of your Data in certain circumstances, for example if
you dispute the accuracy of the Data that we hold about you or you object to our
processing of your Data (including where we process your Data for our legitimate
interests, where permitted under applicable law).

e) Right to Object – this right enables you to object to us processing your Data
where we do so for certain reasons.

f) Right to Data Portability - you have the right to request that we transfer
your Data to another third party. This right of data portability only applies to
certain types of Data.

g) Right to Withdraw Consent – where we have obtained your consent to process
your Data for certain activities, you may withdraw this consent at any time and
we will cease to carry out that particular activity that you previously
consented to unless we consider that there is an alternative legal basis to
justify our continued processing of your Data for this purpose.

h) Right to File Complaints – you have the right to lodge a complaint with the
relevant supervisory authority in your jurisdiction.

To get in touch with us about these rights, or for more information about
managing your Data and promotional communications, please use the contact
details set out in the section below, titled “How to Contact Us”.

It is important that the Data we hold about you is accurate and current. Please
keep us informed if your personal information changes during the period for
which we hold it.

13. PROCESSING YOUR DATA

We take steps to ensure that your Data is processed according to the provisions
of this Privacy Notice and the requirements of applicable law.

To ensure that your Data receives an adequate level of protection, we have put
in place appropriate written contracts with Tata Group Entities, Partners and
Service Providers that we share your Data with.

14. SEVERABILITY

If any court or competent authority finds that any provision of this Privacy
Notice (or part of any provision) is invalid, illegal or unenforceable, that
provision or part-provision will, to the extent required, be deemed to be
deleted, and the validity and enforceability of the other provisions of this
Privacy Notice will not be affected.

15. LINKS TO OTHER WEBSITES

Our website and Tata Neu may, from time to time, provide links to websites and
applications of Tata Group Entities and Partners whose privacy practices differ
from those of Tata Digital. We have no control over such websites and
applications and are not responsible for the content of those websites and
applications. If you provide Data to any of those websites or applications, then
the use your Data is governed by their privacy notices. This Privacy Notice
applies to our website and Tata Neu only.

16. COOKIES, PIXELS AND SIMILAR TECHNOLOGIES

Our website and Tata Neu may place and access certain Cookies on your device.
Cookies are unique identifiers that we transfer to your device to enable our
systems to recognize your device.  We also use pixels and similar technologies
to analyse traffic on our website and Tata Neu to improve your experience of
using them.

17. CHANGES TO THIS PRIVACY NOTICE

Our business changes constantly and our Privacy Notice will change also. We may
e-mail periodic reminders of our notices and conditions, unless you have
instructed us not to, but you should check our website and Tata Neu frequently
to see recent changes.  The updated version will be effective as soon as it is
accessible. We encourage you to review this Privacy Notice frequently to be
informed of how we are protecting your information.

18. HOW TO CONTACT US

To request to review, update, or delete your personal information or to
otherwise reach us, please submit a request by e-mailing us
at privacy@tatadigital.com. You may contact us for information on Service
Providers, Partners and Tata Group Entities with whom we may share your Data in
compliance with this Privacy Notice and applicable law. We will respond to your
request within 30 days.

19. GRIEVANCE OFFICER

Please see below the details of our grievance officer:

Name: Mr. Sridhar Samudrala

Email: grievances@tatadigital.com

Address: 1st Floor, Army & Navy Building, 148, M G Road, Opposite Kala Ghoda,
Fort, Mumbai, 400001, India

                                                                               
                                                                               
                                Last updated on March 8, 2022