Ibibo Group Pte. Limited (Company registration no: 201505177D) (hereinafter “redBus”) 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 processer.
(a)“Data Protection Officer” means our officer designated to manage and handles affairs relating to the protection of User’s Personal Information and redBus’s compliance with the Act, the Regulation, and such other relevant laws applicable in Singapore.
(b)“Personal Information” has the meaning ascribed to it in Part D hereof;
(c)The “Act” means the Personal Data Protection Act 2012 of Singapore, as may be amended or supplemented from time to time;
(d)The “Regulations” means the Personal Data Protection Regulations 2014 of Singapore, as may be amended or supplemented from time to time; and
(e)Website means the website(s), mobile site(s) and mobile app(s).
B.CONSENT TO COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION & TRANSFER OF DATA
C.TYPE OF PERSONAL INFORMATION THAT WE COLLECT
1.Information which you provide while subscribing to or registering on the Website, including but not limited to information regarding:
(a)your personal identity such as name, gender, age etc.;
(b)your contact details such as your email address, postal addresses, telephone (mobile or otherwise) and/or fax numbers;
(c)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).
2.We may also collect other information and documents including but not limited to:
(a)Transactional history about your e-commerce activities and buying behavior.
(b)Your usernames, passwords, email addresses and other security-related information used by you in relation to our services.
(c)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.
(d)Data that you provide when you contact us;
(e)Data available in 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.
(f)Information pertaining to any other traveler(s) for who you make a booking through your registered redBus account. In such case, 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 to us and further be shared by us with the concerned service provider(s) and for the purposes stated herein.
(g)Information collected by cookies. When you visit our Website, our company serves automatically records information that your browser sends whenever you visit a website including but not limited to the following:
(i)your computer or devices internet protocol address;
(iii)websites visited before our Website;
iv)pages visited within our Website (including time spent on those pages);
(v)other items and information searched for on our Website, access time and dates etc.
D.HOW WE USE YOUR PERSONAL INFORMATION
The Personal Information collected may be used in the following purposes:
1.While making a booking:
While making a booking, we may collect and use your Personal Information in order to enable us to:
(a)create an account with us;
(b)process your booking expeditiously; and/or
(c)populate your Personal Information in the future bookings.
2.We may also use your Personal Information for other purposes including but not limited to:
(a)process and confirm your reservations with respective service providers;
(b)keep you informed of the transaction status;
(c)send booking confirmations either via SMS or Whatsapp or any other messaging service;
(d)send any updates or changes to your booking(s);
(e)allow our customer service to contact you, if necessary;
(f)customize the content of our website, mobile site and mobile app;
(g)request for reviews of products or services or any other improvements;
(h)send verification message(s) or email(s);
(i)validate/authenticate your account and to prevent any misuse or abuse;
(j)Verify and carry out financial transactions in relation to payments made for purchases from us;
(k)Managing, investigating or responding to feedback, request, claims or complaints provided or made by you;
(l)Conduct market survey, research or data mining;
(m)Deliver marketing or promotional materials relating to our product(s) and/or services or special offer(s) (and other information which you have requested);
(n)Any other purposes as notified by us from time to time
4.USER GENERATED CONTENT (UGC)
redBus provides an option to its Users to post their experiences by way of review, ratings and general poll questions. The Users also have an option of posting questions with regard to a product or service offered by redBus or post answers to questions raised by other Users. redBus may also hire a third party to contact you and gather feedback about your recent booking with redBus. Though the participation in the feedback process is purely optional, you may still receive emails, notifications (SMS, Whatsapp or any other messaging service) for you to share your feedback. The reviews may be in writing or in a video format. The reviews may be visible on other travel or travel related platforms.
The UGC that redBus collect may be of the following kinds:
5.MARKETING PROMOTIONS, RESEARCH AND PROGRAMS:
Marketing promotions, research and programs help us to identify your preferences, develop programs and improve user experience. redBus frequently sponsors promotions to give its Users the opportunity to win great travel and travel related prizes. Personal Information collected by us from such activities may include contact information and survey questions. We use such Personal Information to notify contest winners and survey information to develop promotions and product improvements. As a registered User, you will also occasionally receive updates from us about fare sales in your area, special offers, new redBus services, other noteworthy items (like savings and benefits on bus tickets, hotel reservations, pilgrimage packages, car rentals and other travel services) and marketing programs.
In addition, you may look forward to receiving periodic marketing emails, newsletters and exclusive promotions offering special deals.
From time to time we may add or enhance services available on the Website. To the extent these services are provided, and used by you, we will use the Personal Information that you have provide to facilitate the service(s) requested. For example, if you email us with a question, we will use your email address, name, nature of the question, etc. to respond to your question. We may also store such Personal Information to assist us in making the Website the better and easier to use for our Users.
redBus may from time to time launch reward programs by way of which users may stand to win travel related rewards or other rewards. We may use your Personal Information to enroll you in the rewards program and status of the same will be visible each time you log in to the Website. Depending on the reward program, each time you win a reward, redBus may share your Personal Information with a third party that will be responsible for fulfilling the reward to you. You may however choose to opt out of such reward programs by writing to us.
E.DO NOT CALL REGISTRY
F.HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
Where your Personal Information is no longer required we will ensure that it is either securely deleted or stored in a way which render it non-usable.
For the avoidance of doubt, we will continue to retain your Personal Information, even after you have withdrawn your consent, if such retention is necessary for our business and legal purposes in accordance with Section 25 of the Act.
G.COOKIES AND SESSION DATA
Cookies are small pieces of information that are stored by your browser on your device's hard drive. Cookies allow us to serve you better and more efficiently. Cookies also allow ease of access, by logging you in without having to type your login name each time (only your password is needed); we may also use such cookies to display any advertisement(s) to you while you are on the Website or to send you offers (or similar emails – provided you have not opted out of receiving such emails) focusing on destinations which may be of your interest.
A cookie may also be placed by our advertising servers, or third party advertising companies. Such cookies are used for purposes of tracking the effectiveness of the advertisements served by us on any website, and also to use aggregated statistics about your visits to the Website in order to provide advertisements in the Website or any other website about services that may be of potential interest to you. The third party advertising companies or advertisement providers may also employ technology that is used to measure the effectiveness of the advertisements. All such information is anonymous. This anonymous information is collected through the use of a pixel tag, which is an industry standard technology and is used by all major websites. They may use this anonymous information about your visits to the Website in order to provide advertisements about goods and services of potential interest to you. No Personal Information is collected during this process. The information so collected during this process, is anonymous, and does not link online actions to a User.
Most web browsers automatically accept cookies. Of course, by changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. redBus supports your right to block any unwanted internet activity, especially that of unscrupulous websites. However, blocking redBus cookies may disable certain features on the Website, and may hinder an otherwise seamless experience to purchase or use certain services available on the Website. Please note that it is possible to block cookie activity from certain websites while permitting cookies from websites you trust.
Each time you access the Website your session data gets logged. Session data may consist of various aspects like the IP address, operating system and type of browser software being used and the activities conducted by the User while on the Website. We collect session data because it helps us analyze User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on. It also helps us diagnose problems with our servers and lets us better administer our systems. The aforesaid information cannot identify any User personally. However, it may be possible to determine a User's Internet Service Provider (ISP), and the approximate geographic location of User's point of connectivity through the above session data.
H.WITH WHOM YOUR PERSONAL INFORMATION IS SHARED
Your Personal Information may be shared with the end service providers like hotels, bus service providers, cab rental or any other suppliers who are responsible for fulfilling your booking. You may note that while making a booking with redBus you authorize us to share your Personal Information with the said service providers and suppliers. It is pertinent to note that redBus does not authorize the end service providers to use your Personal Information for any other purpose(s) except as may be for fulfilling their part of service. However, how the said service providers/suppliers use the information shared with them is beyond the purview and control of redBus as they process Personal Information as independent data controllers, and hence we cannot be made accountable for the same. You are therefore advised to review the privacy policies of the respective service provider or supplier whose services you choose to avail.
redBus does not sell or share names or other Personal Information of Users to third parties except sharing of such Personal Information under controlled and secured circumstances with our business / alliance partners or vendors who collaborate with us in providing various services (including but not limited to referral, promotional and other benefits to our Users).
In the interests of improving personalization and service efficiency, we may, under controlled and secured circumstances, share your Personal Information with our affiliate or associate entities.
If the assets of redBus are acquired, all Personal Information stored by us may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, as part of business expansion/development/restructuring or for any other reason whatsoever, if we decide to sell/transfer/assign our business, any part thereof, any of our subsidiaries or any business units, then as part of such restructuring exercise customer information including the Personal Information collected, stored and processed herein may be transferred accordingly.
We may also share certain filtered Personal Information to our corporate affiliates or business partners who may contact the Users to:
(a)offer certain products or services, which may be free or paid products / services, or
(b)avail certain benefits specially made for redBus customers.
redBus may share your Personal Information to third party that redBus may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, and data processing platforms.
We use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher quality, more useful online services by performing statistical analysis of the collective characteristics and behavior of our customers and visitors, and by measuring demographics and interests regarding specific areas of the Website. We may provide anonymous statistical information based on this data to suppliers, advertisers, affiliates and other current and potential business partners. We may also use such aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their websites. Ownership of anonymous statistical information which we generate using non-identifiable Personal Information shall belong to us. We may use it, in our sole discretion and without any compensation to you, for any legitimate purpose including without limitation the commercial sale thereof to third parties.
Occasionally, redBus will hire a third party for market research, surveys etc. and will provide information to these third parties specifically for use in connection with these projects. The information (including aggregate cookie and tracking information) we provide to such third parties, alliance partners, or vendors are protected by confidentiality agreements and such information is to be used solely for completing the specific project, and in compliance with the applicable regulations.
In addition to the circumstances described above, redBus may disclose User's Personal Information if required to do so:
(a)by law, required by any enforcement authority for investigation, by court order or in reference to any legal process;
(b)to conduct our business;
(c)for regulatory, internal compliance and audit exercise(s)
(d)to secure our systems;
(e)to enforce or protect our rights or properties of redBus or any or all of its affiliates, associates, employees, directors or officers or when we have reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities; or
(f)in such circumstances as provided in paragraph 1 of the Fourth Schedule of the Act.
Such disclosure and storage may take place without your knowledge. In that case, we shall not be liable to you or any third party for any damages howsoever arising from such disclosure and storage.
I.USER’S ACCESS TO PERSONAL INFORMATION
Pursuant to Section 21 of the Act, you shall be entitled to request us to provide you with the following information (“Access Request”):
(a)your Personal Information in our possession or under our control;
(b)information about the ways in which your Personal Information has been or may have been used or disclosed by us within one (1) year before the date of the request.
The Access Request can be made in writing to our Data Protection Officer at firstname.lastname@example.org . You are required under regulation 3 of the Regulations to include your particulars such as your username created for our Website and specify the information that you would like to retrieve in your Access Request. You agree that we may impose a modest charge to cover the costs of complying with your Access Request. Please understand that we will not however entertain any trivial, frivolous or vexatious requests, or any other unreasonable request of which the burden or expense of providing access would be unreasonable to us or disproportionate to our service.
J.CORRECTION OF PERSONAL INFORMATION
You may correct your Personal Information or delete such Personal Information (except some mandatory fields) from your user account directly by making a request to our Data Protection Officer at email@example.com (“Correction Request”). A Correction Request, in accordance with regulation 3 of the Regulations, shall contain your particulars such as your username created for our Website and specify the correction requested.
No fee will be charged on a Correction Request.
Pursuant to section 22(7) of the Act, we are not required to comply with your Correction Request if your request is made to correct any of your review, feedback or any other opinion data which are kept by us solely for an evaluative purpose.
K.HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?
You will occasionally receive e-mail updates from us about fare sales in your area, special offers, new redBus services, and other noteworthy items. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the "unsubscribe" link or follow the instructions in the e-mail message or SMS or other medium of communication.
L.PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS
When the redBus app is installed on your phone or tablet, a list of permissions is required for the app to function effectively. There is no option to customize the list. The permissions that redBus requires and the data that shall be accessed and used include but not limited to the following:
(a)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. based on these inputs, we intend to optimize your travel booking experience.
(b)Identity: This permission enables us to know about details of your account(s) on your mobile device. We use this information to auto-fill your email address and provide a typing free experience. It also helps us map email address 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.
(c)Location: This permission enables us to give you the benefit of location specific deals and provide you a personalized experience. When you launch redBus app to make a travel booking, we auto-detect your location so that your nearest city is auto-filled. We also require this permission to be able to help you track your bus with respect to your location.
(d)SMS: If you allow us to access your SMS, we read your SMS to autofill or prepopulate ‘One Time Password’ 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.
(e)Phone: The app requires access to make phone calls so that you can make phone calls to bus operators, hotels and our customer contact centres directly through the app.
(f)Contacts: If you allow us to access your contacts, it enables us to provide a lot of social features to you such as sharing tickets or location with your friends. This permission also allows you to select numbers from your contacts for mobile recharges done on the app.
(g)Photo/ Media/ Files: The libraries in the app use these permissions to allow users to to save and upload multimedia reviews.
(h)Wi-Fi connection information: When you allow us the permission to detect your Wi-Fi connection, we optimize your bandwidth usage for multimedia uploads.
(i)Device ID & Call information: This permission is used to detect your phone identity through which we can uniquely identify Users. It also lets us pre-populate specific fields to ensure a seamless booking experience.
(j)Camera: This permission is used to capture pictures of the boarding point or bus before the journey. These images can then be uploaded as part of multimedia reviews.
(k)Calendar: This permission enables us to put your travel plans on your calendar.
(l)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 booking confirmation, refund (in case of cancellation), etc. will be sent through SMS.
M.HOW WE PROTECT YOUR PERSONAL INFORMATION?
All payments on the Website are secured. This means all Personal Information you provide is transmitted using TLS (Transport Layer Security) encryption. TLS is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.
P.WITHDRAWAL OF CONSENT
If you have any concerns in the collection, use and disclosure of your Personal Information and wish to withdraw your consent, you may give a notice of your intention to withdraw your consent (“Withdrawal Notice”) to our Data Protection Officer at firstname.lastname@example.org. Once we receive your Withdrawal Notice, we will contact you within seven (7) days to acknowledge receipt of your Withdrawal Notice and within thirty (30) days to inform you of the likely consequences of your withdrawal of consent. We will cease to collect, use and disclose your Personal Information within thirty (30) days after our acknowledgement of receipt of your Withdrawal Notice.
Please note that the collection, use and disclosure of data is essential for us to be able to provide service to you. We may not be able to serve or confirm your bookings after your withdrawal of consent. For instance, if you want to book a bus journey, then certain personal information of yours like contact details, gender, location details etc. may have to be shared by us with our bus operators and they may further process this information for making suitable arrangements for your journey.
A withdrawal of consent by you for us to collect, use and disclose your information may:
(a)severely inhibit our ability to serve you properly and in such case, we may have to refuse the booking altogether; or
(b)unreasonably restrict us to service your booking (if a booking is already made) which may further affect your trip or may compel us to cancel your booking.
We shall not be responsible for any losses, damages, costs and expenses incurred arising from or in connection with our refusal or cancellation of any of your bookings as a result of your withdrawal of consent.
Your withdrawal of consent does not affect our right to continue to collect, use and disclose your Personal Information, where such collection, use and disclosure without consent is permitted or required under the Act or other applicable laws.
Q.DATA PROTECTION OFFICER
The contact details of our Data Protection Officer are as follows:
(a)Email – email@example.com
(b)Address – 70 Bendemeer Road #06-04 Luzerne Singapore 339940 (Attention to: Data Protection Officer);
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