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Privacy Policy

Welcome to Adani International School Privacy Policy (“Privacy Policy”, “Policy” or Privacy Notice).

Adani International School (collectively, “School” or “we” or “us” or “our”) is creating a state-of-the-art school infrastructure with globally acclaimed facilities, anchored by core values of honesty, courage, kindness, compassion, and self-discipline. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or otherwise interact with our website available at   https://www.adaniinternationalschool.org   or mobile application’ Edusprint+ (collectively, “Platform”) or avail products or services that we offers you on or through the Platform (collectively, the “Services”).

We are committed to protecting your personal data and respecting your privacy. To provide you with services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you. Please note that unless specifically defined in this Policy, capitalized terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://www.adaniinternationalschool.org/terms (“Terms”).

We do collect your personal information and process your personal data in accordance with the IT Act, 2000 (21 of 2000) and other national and state laws which relate the processing of personal data.

Please read this Policy in consonance with the Terms. By using the Services, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.

  1. DEFINITIONS AND KEY CONCEPTS

    In this Privacy Policy, 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/App and/or the Platform.

    Cookies

    a small file placed on your device by our website/App or the Platform when you either visit or use certain features of our website/App or the Platform. 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 Adani Group Entities) with whom we have contracts for the businesses described in this Privacy Notice.

    Service Providers

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

    Adani Group Entity

    Adani Enterprises Limited, and its subsidiaries, affiliates, associate companies and joint venture companies

    User or you

    the natural person who accesses or use the Services through our website/App or the Platform.

    Our status as controller or processor:

    We are creating a state-of-the-art school infrastructure with globally acclaimed facilities, anchored by core values of honesty, courage, kindness, compassion, and self-discipline.

    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 Group Entity and other participating entities.

    This Privacy Policy 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 an Adani Group Entity or other participating entity (i.e. the “controller”).

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  2. WHAT DATA DO WE COLLECT ABOUT YOU

    We collect Data for various purposes set out in this Privacy Notice.

    Schools collect the following types of information.

    • Information about students and their families provided by students, their families and others – for example, contact and enrolment details, health information, and parenting and access arrangements.
    • Information about job applicants, staff, volunteers and visitors provided by job applicants, staff members, volunteers, visitors and others – for example, qualifications, working with children checks, teacher registration and banking details.
    • Information about the activities of students, staff and families if they are on school grounds (for example captured through CCTV) or using school or departmental systems (such as school networks or school-acquired software).
    • 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.
    • Product and service information: Your website/App or Platform account membership number, registration information, and program-specific information, when you request products and/or services directly from us or participate in marketing programs.
    • Your reviews, feedback and opinions about our products, programmes, and services.
    • Other information: Age, sex, date of birth, marital status, nationality, occupation or any other personal information provided by you.

  3. HOW WE COLLECT DATA

    We collect Data in the following ways:

    Schools collect the following types of information.

    • Information about students and their families provided by students, their families and others – for example, contact and enrolment details, health information, and parenting and access arrangements.
    • Information about job applicants, staff, volunteers and visitors provided by job applicants, staff members, volunteers, visitors and others {' '} – for example, qualifications, working with children checks, teacher registration and banking details.
    • Information about the activities of students, staff and families if they are on school grounds (for example captured through CCTV) or using school or departmental systems (such as school networks or school-acquired software).
    • 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 where we receive your Data from Adani Group Entities in connection with the Platform for the purposes of enrolment, offering you products, services and benefits on the Platform.
    • Information Previously Provided to Adani Group Entities: Where you have shared any information previously with any of the Group Entities and such 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 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 Group Entity, you acknowledge that: (a) we will collect such information from such Group Entity for the purposes set out in this Privacy Notice; (b) the 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 Group Entity in relation to any such compliance obligations under the Data Protection Laws.
    • The information about usage of the Website/App, including crash logs and usage statistics.
    • Information about the location of your device, including geolocation information.
    • Information such as your location is collected upon availing service which require processing of such data to provide the requisite service to you.
    • By using our App, you are agreeing that We may advertise your feedback on the App/ website and marketing materials.
    • We will retain your information as long as we require this to provide you with the goods and services and for such period as mandated by the concerned 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/App or the Platform. When you are asked to provide Data, you may decline. For more information, please see the section below, titled “Your Rights and Choices”.

    4.  

  4. DATA SHARED BY YOU:

    We may collect your Data in several ways from your use of our website/App or the Platform. For instance:

    • when you register with us to receive our products and/or services.
    • when you conduct a transaction or attempt a transaction on our website/App or Platform;
    • when you complete surveys conducted by or for us;
    • when you elect to receive any communications (including promotional offers) from us.
    • from the information gathered by your visit to our website or the Our Platform.
    • Do not provide personal data about others unless you are authorized or required to do so by contract or applicable law.

  5. DATA WE RECEIVED FORM OTHER SOURCES:

    We may receive personal data about you from other sources including but not limited to the information provided by you to us for availing any product or service available at the Platform, Our affiliate, a person, or company/organization authorized by you to submit an application on your behalf, and/or publicly available sources. We’ll contact you to let you know we are processing your personal information.

    6.  

  6. DATA THAT IS COLLECTED AUTOMATICALLY:

    • We automatically collect some information when you visit our website/App or the Platform. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
    • 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. We use this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of our website/App or the Platform.
    • 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”.

  7. OUR USE OF DATA

    We use the information collected through this Website/App, as described in this policy and we may use your information to:

    • Primary purposes of collecting information about students and their families to:

      • educate students
      • support students’ social and emotional wellbeing, and health

      • fulfil legal requirements, including to:

        • take reasonable steps to reduce the risk of reasonably foreseeable harm to students, staff and visitors (duty of care)
        • make reasonable adjustments for students with disabilities (anti-discrimination law)
        • ensure, as far as is reasonably practicable, the health and safety of people in school workplaces (occupational health and safety law)

      • enable schools to:

        • communicate with parents about students’ schooling matters and celebrate the efforts and achievements of students
        • maintain the good order and management of schools

      • enable the Department to:

        • ensure the effective management, resourcing and administration of schools
        • fulfil statutory functions and duties
        • plan, fund, monitor, regulate and evaluate the Department’s policies, services and functions
        • comply with reporting requirements
        • investigate incidents in schools and/or respond to any legal claims against the Department, including any of its schools.
    • Improve our services, App and how we operate our businesses.
    • Understand and enhance your experience using our Website/App, products and services.
    • Process, manage, complete, and account for transactions.
    • Provide customer support and respond to your requests, comments, and enquiries.
    • Send you related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages.
    • Communicate with you about promotions, upcoming events, and news about products and services.
    • We may process your personal information without your knowledge or consent where required by applicable law or regulation for the purposes of verification of identity or for prevention, detection, or investigation, including of cyber incidents, prosecution, and punishment of offences.
    • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
    • protecting against, and preventing, fraud, illegal activity, harm, financial loss and other legal or information security risks.
    • providing marketing and promotional campaigns to you based on your profile;
    • Create a user profile based on data provided by you on using of the application.

    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 the Platform, 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.

    8. 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 Group Entity or other participating entity (i.e., the controller) for the purposes of offering you access to Third Party Applications on the Platform 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).

  8. PERMISSIBLE AGE:

    • The Services are not intended for users under the age of 18, unless permitted under applicable local laws (Permissible Age) or under the involvement of a parent or guardian. We do not knowingly collect any personal information from users or market to or solicit information from anyone under the Permissible Age. If we become aware that a person submitting personal information is under the Permissible Age, we will delete the account and any related information as soon as possible. If you believe we might have any information from or about a user under the Permissible Age, please contact us at pranay.modi@adani.com
    • This Website is not directed at children under the age of 18 and We cannot distinguish the age of persons who access and use our website. If a minor (according to applicable laws) has provided us with Customer Data without parental or guardian consent, the parent or guardian should contact us (see Section 20) to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account.

  9. 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):

    • We share your data with your consent for the activities as mentioned above under clause 7. We also share data with our affiliates and subsidiaries, with vendors working on our behalf for completion of the activities mentioned above at clause 7.
    • We may employ other companies and individuals to perform functions on our behalf. The functions include activities mentioned at clause 7 above.
    • Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units.
    • Protecting Us: 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 our or an Adani Group Entity's intellectual property rights; (c) to protect our 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.
    • Third Parties: We may also share your Data with other third parties where:
      • You request or authorize us to do so;
      • We need to comply with applicable law or respond to valid legal process; or
      • We need to operate and maintain the security of our website/App or Platform, 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 Policy.
    • We reserve our right to share the information collected within the Adani Group Entities and internal departments for promotional and marketing activities and communications only after obtaining prior consent from you.

  10. DATA SECURITY:

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

    The security of your Platform account depends on you keeping your account password(s), PINs and other access information confidential. If you share your Platform 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 the Platform 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 the Platform has been compromised.

  11. ANALYTICS AND TAILORED ADVERTISIN

    To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics etc. These service providers use the sort of technology described in the "Automatically-Collected Information" Section above. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate our users' use of the Services. We also use Google Analytics as described in the following section. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser add-on.

    Tailored Advertising

    Third parties whose products or services are accessible or advertised via the Services may also use cookies or similar technologies to collect information about your use of the Services. This is done in order to help them-

    • Inform, optimize, and serve ads based on past visits to our website and other sites and

    • Report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, and other progamatic/adtech players) to serve tailored ads to you on the Services, and to access their own cookies or similar technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed by such third parties. These parties may permit you to opt out of ad targeting. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising (i.e., not just for the Services), you may visit the Network Advertising Initiative's Consumer Opt-Out Link, and/or the Digital Advertising Alliance's Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive ads even if you opt-out of tailored advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. When accessing the Services from a mobile application you may also receive tailored in-application advertisements. Each operating system: iOS, Android and Windows Phone provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.

  12. RETENTION OF DATA

    We retain 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/App or the Platform, 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 13 below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

  13. 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 Policy, 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:

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

  14. 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:

    • Right to Confirmation and Access - You may ask us to confirm what Data we hold about you at any time. You may also request a copy of the Data we hold about you by following the process as provided under clause 20 below. Additionally, data subject can seek other information related to the processing of their data.
    • 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.
    • Right to be Erasure - you have the right to request that we “erase” your Data in certain circumstances.
    • 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)
    • Right to Object – this right enables you to object to us processing your Data where we do so for certain reasons.
    • 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.
    • 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.
    • 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.

  15. 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.

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  16. SEVERABILITY

    If any court or competent authority finds that any provision of this Privacy Policy (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 Policy will not be affected.

    17.  

  17. LINKS TO THIRD PARTY SITE/APPS

    Our App may, from time to time, contain links to and from other Apps/websites of third parties. Please note that if you follow a link to any of these Apps/websites, such Apps/websites will apply different terms to the collection and privacy of your personal data, and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy policy of every App/Website you visit.

    18.  

  18. COOKIES

    • To optimize our App presence, we use cookies. These are small text files stored on your device. These cookies are deleted after you close the App. Other cookies remain on your device (long-term cookies) and permit its recognition on your next visit. This allows us to improve your access to our site. This helps us to learn more about your interests, and provide you with essential features and services and for additional purposes, including:

      • Conducting research and diagnostics to improve the content, products, and services.
      • Preventing fraudulent activity.
      • Improving security.
    • Our cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you will not be able to add items to your shopping basket, proceed to checkout, or use any products or services that require you to sign in.
    • Approved third parties also may set cookies when you interact with Our services.
    • Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies.
    • Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on behalf of Us
    • You can prevent the storage of cookies by choosing a "disable cookies" option in your device settings. But this can limit the functionality of our services.

  19. CHANGES TO THIS POLICY

    We may change this policy from time to time. If we make any changes to this policy, we will change the “Last Updated” date below. You agree that your continued use of our services after such changes have been published to our services will constitute your acceptance of such revised policy. we will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.

    20.  

  20. 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 pranay.modi@adani.com You may contact us for information on Service Providers, Partners and Group Entities with whom we may share your Data in compliance with this Privacy Policy and applicable law. We will respond to your request within 30 days.

    21.  

  21. GRIEVANCE OFFICER:

    Please find below the details of the grievance officer:

     

    The grievance officer is identified above pursuant to the provisions of applicable laws including but not limited to the information Technology Act, 2000 and the Consumer Protection Act,2019 and the rules enacted under those laws.

    This Privacy Policy was last updated on 01st March, 2023.

PRIVACY POLICY APPLICABLE TO THE EUROPEAN ECONOMIC AREA (EEA) AND THE UNITED KINGDOM (UK)

  1. We (us/our) is committed to safeguarding the privacy of our customers (you/your). This privacy policy (the Privacy Policy) applies to our customers, potential customers who are in the European Economic Area (EEA) and the United Kingdom (UK). It sets out our personal data collection and sharing practices and informs you of the ways in which we collect personal data, the uses of that personal data and the ways in which we will share any personal data you choose to provide to us. To ensure that you can make informed decisions and feel confident about sharing certain personal data with us, please read this Privacy Policy to understand who we share your Personal Data with and for what purposes and the choices you have concerning how your Personal Data is collected and used by us.
  2. If you are an existing customer of ours, further details about how we use your personal data are set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided when we collect personal data from you.
  3. Our websites/ Platform may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

  4. This Privacy Policy is intended to explain our privacy practices and covers the following areas

    • What personal data about you we may collect?
    • How may we use your personal data?
    • Who may we share your personal data with?
    • How we protect your personal data?
    • Contacting us & your rights to prevent marketing and to access and update your personal data?
    • How changes to this Privacy Policy and the Cookies Policy will be made.

  1. Information we may collect about you

    • We will collect and process all or some of the following personal data about you:

      • Information you provide to us : Personal data that you provide to us, such as when using the contact form on our website or mobile app, including your name, email address etc.
      • Our correspondence: If you contact us, we will typically keep a record of that correspondence;
      • Survey information: We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
      • Your transactions: If you have purchased any services through our website or platform, details of related transaction details and of the fulfilment of the services we provide.
      • Website and communication usage: Details of your visits to the websites and information collected our website including cookies and other tracking technologies including, but not limited to, your IP address and domain name, geographical location, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
    • Certain personal data are required in order for us to supply our products and services and if you fail to supply such personal data as requested for specific services, we may be unable to deliver you the products and services in full.
    • Where you have provided us, personal data relating to another person, please ensure that you have that person’s knowledge and permission to use their data. Please provide that person with a copy of (or a link to) this privacy policy so they understand how we process personal data.
    • The data received from these organizations will be limited to that described at section 2.1 above and we will not use it for any other purpose other than those described.

  2. USES MADE OF YOUR PERSONAL DATA

    • In this section, we set out the purposes for which we use your personal data and, in compliance with our obligations under European law, identify the lawful bases we rely on in order to process the information.
    • These “legal grounds” are set out in the relevant data protection law applicable to the EEA and the UK, which allows companies to process personal data only when the processing is permitted by the specific “legal grounds” set out in law.
    • Please note that in addition to the disclosures we have identified below, we may disclose personal data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of ADL that perform activities on our behalf, as well as other members of the Adani Group.
      • To communicate effectively with you and conduct our business : To conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us; Legal bases : Contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you)
      • To provide you with marketing materials : To provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by post, email, SMS, phone and fax and private messages through other digital platforms and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” section below. Legal bases : Consent, legitimate interest (to keep you updated with news in relation to our products and services).
      • For research and development purposes : To analyse your personal data in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services; Legal bases : Legitimate interests (to allow us to improve our services)
      • To monitor certain activities : To monitor queries and transactions to ensure service quality, compliance with procedures and to combat criminal activity; Legal bases : Legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services
      • To inform you of changes : To notify you about changes to our services and products; Legal bases : Legitimate interests (to notify you about changes to our service)
      • To ensure website content is relevant : To ensure that content from our websites/Platform is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers; Legal bases : Legitimate interests (to allow us to provide you with the content and services on the websites)
      • To reorganize or make changes to our business : Strong in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your personal data to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy; Legal bases : Legitimate interests (in order to allow us to change our business)
      • In connection with legal or regulatory obligations : We may process your personal data to comply with our regulatory requirements or discourse with regulators as applicable which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. Legal bases : Legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)

  3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

    • We may disclose information about you to any of our, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy. This will include customs and immigrations authorities, airports at which we operate, credit card fraud companies (to detect and prevent fraud), payment operating services, notification channels to notify customers regarding their bookings, flight schedule changes by sending SMS and emails, the departure control system (DCS), the baggage reconciliation system (BRS), advance passenger processing (APP) and customer and border protection (CBP), travel processing system.
    • In addition, we may disclose information about you to counterparties, customs and immigration authorities, other government bodies, regulators and law enforcement agencies where required by law, in connection with any legal proceedings or prospective legal proceedings, or to establish, exercise or defend our legal rights including providing information to others for the purposes of crime detection and prevention.
    • Except as provided in this Privacy Policy, we will not otherwise provide your information to third parties.

  4. STORAGE AND SECURITY OF YOUR PERSONAL DATA

    • No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements.
    • All information you provide to us is stored on our or our subcontractors’ secure servers in on outside of the EEA or the UK (i.e. India only) and accessed and used subject to our security policies and standards.
    • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
    • Protecting Adani Digital: We may share your Data when we believe that disclosure is reasonably necessary (a) To comply with a law, regulation or compulsory legal request; (b) To protect Adani Digital or a Adani Group Entity's intellectual property rights; (c) To protect Adani 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.

  5. PROCESSING OUTSIDE THE EEA AND THE UK

    • We will sometimes transfer personal data to other jurisdictions, including destinations outside the country in which you are located, whose data protection laws may not be adequate or of the same level as in your country . We will, in all circumstances, safeguard personal data as set out in this Privacy Policy
    • Where your personal data is transferred from an entity inside the European Economic Area (the EEA) or the UK (as the case may be) to outside the EEA or the UK (as the case may be), we may be required to take specific additional measures to safeguard the relevant personal data. Where we transfer your personal data, we will establish legal grounds justifying such transfer, or otherwise to ensure the appropriate security of your personal data
    • Storage limits : Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data.

  6. YOUR RIGHTS & CONTACTING US

    Marketing

    You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. Where you do not wish to receive marketing from us, you can decline or withdraw your consent at any time, either by choosing not to select the relevant check boxes on our subscription form, by clicking the unsubscribe link in any marketing message received from us, or by contacting us here.

    Updating Information

    We will use reasonable endeavors to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by contacting us as set out in the “Contacting Us” section below. Please note that it is your responsibility to ensure that your booking information or flight itinerary is accurate.

    Your rights

    If you have any questions in relation to our use of your personal data, you should first contact us as per the “Contacting Us” section below. Under certain conditions, you may have the right to require us to:

    • Provide you with further details on the use we make of your information.
    • Provide you with a copy of information that you have provided to us;
    • Update any inaccuracies in the personal data we hold
    • Delete any personal data thatwe no longer have a lawful ground to use;
    • Where processing is based on consent, to withdraw your consent so that we stop that particular processing. Please note that in relation to health information, this will prevent us from reacting to any health condition you may have;
    • To ask us to transmit the personal data you have provided to us and we still hold about you to a third party electronically;
    • Object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
    • Restrict how we use your information whilst a complaint is being investigated

    Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within 90 days from the date of receipt of any such request.

    If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the relevant data protection authority.

    Contacting us

    If you have any questions in relation to this policy, please contact us at pranay.modi@adani.com

    7.  

  7. Changes to our Privacy Policy and/or Cookies Policy

    • We may change the content of our websites and how we use cookies and consequently our Privacy Policy and our Cookie Policy may change from time to time in the future. If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our website.
    This Privacy Policy was last updated on 01st March, 2023.