Privacy Policy – True Wave Marketing (TWM)

A. Introduction

True Wave Marketing (hereinafter “TWM”) is committed to protecting the privacy of its users and maintaining the confidentiality of the personal information they provide. As a responsible data controller and processor, TWM adheres to strict privacy standards.

This Privacy Policy outlines the practices for handling and securing Personal Information provided by TWM’s users, subsidiaries, and affiliates.

Applicability of the Privacy Policy

This Privacy Policy applies to any individual ("User") who:

1. Purchases, intends to purchase, or inquires about any product(s) or service(s) made available by TWM.
2. Accesses TWM’s customer interface channels, collectively referred to as Sales Channels, including:
   1. Website: www.truewave.club
   2. Mobile site or app.
   3. Offline channels such as call centers and offices.

For the purposes of this Privacy Policy:

• “You” or “Your” refers to the User.
• “We”, “Us”, or “Our” refers to True Wave Marketing.
• “Website” refers to all digital platforms (websites, mobile sites, and apps) operated by TWM.

By accessing or using TWM’s Website or other Sales Channels, you consent to the terms of this Privacy Policy. If you do not agree, please refrain from using these platforms.

Exclusions

• This Privacy Policy does not apply to third-party websites, mobile sites, or apps, even if linked to TWM’s Website.
• TWM does not control the information and privacy practices of its business partners, advertisers, sponsors, or other third parties whose links may appear on its platforms.
• Recommendation: Review the privacy statements of third-party platforms before interacting with them.

Part of User Agreement

This Privacy Policy forms an integral part of the User Agreement with True Wave Marketing. Terms used in this Privacy Policy but not defined herein shall have the meanings ascribed to them in the User Agreement.

B. Users Outside the Geographical Limits of India

Please note the following regarding users outside India who interact with or share their data with True Wave Marketing (TWM):

1. Data Processing Location

• Personal data shared with TWM will primarily be processed in India and other jurisdictions where third parties engaged by TWM may process data on its behalf.
• By agreeing to this Privacy Policy, you explicitly consent to the processing of your personal information in accordance with this policy, regardless of your country of residence.
• Important Note: Data protection regulations in India and other jurisdictions may differ from those in your country of residence.

2. Withdrawing Consent

If you have concerns about how your data is processed or wish to withdraw your consent:

• Write to us at Twmarketing46@gmail.com.
• Upon withdrawing your consent, please note the following:
  1. If processing your data is essential for providing a service, we may be unable to proceed with or confirm your booking.
  2. For example, certain information (e.g., contact details, gender, dietary preferences) may be necessary for us to deliver services like arranging travel packages.

3. Impact of Withdrawal of Consent

Withdrawing your consent may:

1. Inhibit Our Ability to Serve You:
   1. We may be unable to confirm or process new bookings.
2. Affect Existing Bookings:
   1. In case of existing bookings, withdrawal of consent may lead to service interruptions, trip cancellations, or the inability to fulfill your booking requirements.

C. Type of Information We Collect and Its Legal Basis – True Wave Marketing (TWM)

To provide the services you select, fulfill legal obligations, and meet obligations towards third parties as per our User Agreement, True Wave Marketing (TWM) collects the following types of information:

1. Personal Information

This includes information shared by the User and collected by TWM for various purposes, such as registration, transaction processing, and account management:

A. Registration on the Website

Information provided by the User during subscription or registration, including:

• Personal Identity Information:
  1. Name, gender, marital status, religion, age, etc.
• Contact Details:
  1. Email address, postal address, telephone/mobile number, and fax number.
• Financial Information:
  1. Banking details (e.g., credit/debit card), income-related details, and payment history.
• Lifestyle Information:
  1. Details relating to your preferences and activities shared by you.

2. Other Information

A. Transactional History

B. Security and Login Details

C. User-Generated Data

• Data created by you or uploaded to TWM servers, including:
  1. Image files, documents, and any other files you wish to store with us.

D. Public Domain or Third-Party Data

• Information obtained from public sources or third parties, including social media platforms:
  1. Name, email address, friend list, profile picture, or any other data shared via account settings.

E. Traveller(s) Information

• Information about additional travellers for whom you make bookings via your TWM account.
  1. You must confirm that each traveller has consented to sharing their information with TWM and any relevant service providers.

F. Identity Documents for Auto-Check-In Facility

• If you use the auto-check-in feature at hotels, identity documents such as:
  1. PAN Card, Aadhaar Card, Driving License, Voter ID, or other permissible identification will need to be uploaded to facilitate this service.

Legal Basis for Collecting Information

The collection of the above information is based on the following legal justifications:

1. Performance of a Contract:
   1. To fulfill services you have requested and agreed to under the User Agreement.
2. Legal Compliance:
   1. To comply with laws and regulations applicable to TWM and its services.
3. Consent:
   1. For information voluntarily provided by you, including data shared via linked third-party accounts.

D. How We Use Your Personal Information – True Wave Marketing (TWM)

The Personal Information collected from users may be used in the following ways:

1. While Making a Booking

• Payment Details:
  1. To process bookings, we may use your payment details, including cardholder name, credit/debit card number (encrypted), expiration date, banking details, wallet details, etc.
• Traveler Information:
  1. Information about the travelers linked to your account may be used to expedite bookings.

2. Reasons for Using Personal Information

We may use your Personal Information for the following purposes:

• Confirm Reservations:
  1. Confirm your reservations with respective service providers.
• Transaction Updates:
  1. Keep you informed of your transaction status.
• Booking Confirmations:
  1. Send confirmations via SMS, WhatsApp, or other messaging services.
• Booking Changes:
  1. Notify you of updates or changes to your bookings.
• Customer Support:
  1. Allow our customer service team to contact you if necessary.
• Personalization:
  1. Customize the content of our website, mobile site, and app.
• Feedback & Improvements:
  1. Request reviews of products or services and gather suggestions for improvement.
• Verification:
  1. Validate/authenticate your account and prevent misuse or abuse.
• Special Occasions:
  1. Contact you on birthdays or anniversaries with special offers or gifts.

3. Surveys

• User Feedback:
  1. Conduct surveys (online and offline) to gather opinions and suggestions.
  2. Participation is optional, and data collected is typically aggregated and anonymized.
  3. Survey results help improve the website, services, and promotional offers.

4. Marketing Promotions, Research, and Programs

• Identify Preferences:
  1. Understand user preferences to create relevant programs and improve user experiences.
• Special Offers and Updates:
  1. Share updates on special offers, new services, and marketing programs, including airfare deals, hotel reservations, holiday packages, car rentals, and more.
• Periodic Communications:
  1. Send newsletters, exclusive promotions, and periodic marketing emails offering special deals.
• Reward Programs:
  1. Enroll users in reward programs and share necessary data with third parties responsible for fulfilling rewards.
  2. Users may opt-out of these programs by writing to us.

5. Service Enhancements

• New Services:
  1. If additional services are introduced, we will use your information to facilitate those services.
• Support Requests:
  1. For instance, if you email us with a question, your information (email address, name, etc.) will be used to respond.

6. Fraud Detection & Credit Verification

• Fraud Prevention:
  1. Verify customer information on a selective basis to detect fraud.
• Credit Services:
  1. Assess creditworthiness for offering bookings on credit.

7. Third-Party Data Sharing

In some cases, True Wave Marketing may share anonymized or aggregated personal information with third parties for specific purposes, including:

• Payment processing.
• Data hosting and processing.
• Fulfilling rewards.

Important Notes

• Users have the option to opt-out of reward programs by writing to us.
• Any third-party sharing of data will comply with this privacy policy and applicable laws.

For more details or to opt-out of specific programs, contact us:

• Website: www.truewave.club
• Email: Twmarketing46@gmail.com

E. How Long Do We Keep Your Personal Information? – True Wave Marketing (TWM)

True Wave Marketing (TWM) will retain your Personal Information on its servers for a period that is reasonably necessary to fulfill the purposes outlined in this Privacy Policy.

1. Retention Period

• Your data will be retained:
  1. As long as it is required to provide the services you have requested.
  2. To fulfill any legal, regulatory, tax, or accounting obligations.
  3. To resolve disputes, enforce agreements, and maintain business operations.

2. Extended Retention

In certain circumstances, we may retain your data for longer periods if:

• Required by applicable legal, regulatory, or tax laws.
• Necessary for accounting or auditing purposes.

3. Secure Deletion

Once your Personal Information is no longer required, True Wave Marketing will ensure:

• The data is securely deleted.
• Alternatively, it will be stored in a way that prevents it from being used by the business for any further purposes.

F. Cookies and Session Data – True Wave Marketing (TWM)

1. Cookies

True Wave Marketing (TWM) uses cookies to enhance your experience on our Website and personalize the advertisements displayed to you.

What Are Cookies?

• Cookies are small pieces of data stored by your browser on your device's hard drive.
• Cookies help us provide a better, more efficient user experience by:
  1. Allowing ease of access (e.g., logging you in without requiring your username each time).
  2. Displaying advertisements tailored to your interests.
  3. Sending you promotional offers, emails, or notifications (if you haven’t opted out).

Third-Party Cookies

• Cookies may also be placed by third-party advertising companies or advertising servers to:
  1. Track the effectiveness of advertisements displayed on our Website.
  2. Use aggregated statistics about your visits to show advertisements about services/products of potential interest to you.
• Pixel Tags: These companies may use pixel tags (a standard industry technology) to measure ad performance.
  1. Important Note: The data collected is anonymous and does not include any Personal Information.

Controlling Cookies

• Most web browsers automatically accept cookies, but you can:
  1. Change your browser settings to control or block cookies.
  2. Use software programs to block unwanted internet activity.
• Impact of Blocking Cookies:
  1. Blocking TWM cookies may disable certain features on the Website.
  2. This could hinder a seamless experience, including purchasing or using certain services.
• You can choose to block cookies from specific websites while allowing cookies from trusted sites.

2. Automatic Logging of Session Data

Each time you access the Website, your session data is logged automatically.

What Does Session Data Include?

• IP Address: Tracks the device accessing the Website.
• Operating System & Browser Type: Information about your device and software.
• User Activity: Browsing patterns, frequency of visits, and duration of login.

Why We Collect Session Data

• Helps us analyze user behavior, preferences, and browsing patterns.
• Diagnoses server issues and administers the system better.
• Assists in improving the overall user experience by tailoring the Website based on user behavior.

Important Notes on Session Data

• Anonymity: Session data does not personally identify users.
• However, it may reveal the Internet Service Provider (ISP) and approximate geographic location of your connection.

G. With Whom Your Personal Information is Shared – True Wave Marketing (TWM)

1. Service Providers and Suppliers

• Purpose of Sharing:
  1. Your Personal Information is shared with service providers (e.g., airlines, hotels, cab rentals, etc.) to fulfill your bookings.
• Authorization:
  1. By booking through TWM, you authorize us to share your data with these service providers.
• Limitations:
  1. TWM only shares data required to fulfill the services but does not authorize service providers to use your data for other purposes.
  2. Service providers act as independent data controllers, and TWM is not accountable for how they handle your data.
  3. Recommendation: Review the privacy policies of the respective service providers whose services you choose.

2. Companies in the Same Group

• Affiliates and Associates:
  1. Your data may be shared with TWM’s affiliate or associate entities to improve personalization and service efficiency.
  2. This helps in providing information about products or services that may interest you or addressing your booking-related queries.
• Acquisition or Restructuring:
  1. In case TWM’s assets are acquired or the business undergoes restructuring, your data may be transferred to the acquiring entity.

3. Business Partners and Third-Party Vendors

• Purpose of Sharing:
  1. Filtered Personal Information may be shared with business partners who offer co-branded services, such as credit cards, travel insurance, or other related benefits.
• Third-Party Tasks:
  1. TWM may engage third-party vendors for tasks such as:
     • Payment processing.
     • Data hosting and processing.
  2. These third parties are bound by confidentiality agreements and can only use the data for specific tasks assigned by TWM.

4. Anonymized and Aggregate Data

• Statistical Analysis:
  1. Non-identifiable Personal Information (e.g., aggregated data) is used for:
     • Enhancing services.
     • Understanding customer behavior.
     • Informing suppliers, advertisers, and affiliates about customer demographics and interests.
• Ownership:
  1. Such anonymized data remains TWM’s property and may be used for legitimate purposes, including commercial sale to third parties.

5. Market Research and Surveys

• Occasionally, TWM may hire third parties to conduct:
  1. Market research.
  2. Surveys.
• Any data provided to these third parties will:
  1. Be protected by confidentiality agreements.
  2. Be used solely for the specific project and in compliance with regulations.

6. Disclosure of Information

TWM may disclose Personal Information under the following circumstances:

• Legal Obligations:
  1. When required by law, enforcement authorities, or court orders.
• Business Operations:
  1. To conduct internal audits, regulatory compliance, or secure systems.
• Rights Protection:
  1. To enforce or protect the rights and properties of TWM, its affiliates, employees, or directors.
• Prevention of Harm:
  1. To take legal action against activities that harm TWM or others.

Important Note:

Such disclosures may occur without prior notice to you. TWM is not liable for damages arising from such disclosures.

H. User-Generated Content (UGC) – True Wave Marketing (TWM)

True Wave Marketing (TWM) encourages users to share their experiences and participate in interactive activities on its platform. By generating content, users contribute to improving the community experience for others.

1. User-Generated Content (UGC) Options

Users have the option to:

• Post Reviews and Ratings:
  1. Share experiences in text or video format.
  2. Reviews may also appear on other travel-related platforms.
• Questions and Answers (Q&A):
  1. Post questions about TWM services or answer questions from other users.
• Poll Participation (Crowd-Sourced Data Collection):
  1. Engage in polls or general feedback surveys.

2. Feedback Process

• Optional Participation:
  1. Participation in reviews, surveys, or feedback is voluntary.
• Notifications for Feedback:
  1. Users may still receive emails, app notifications, SMS, or WhatsApp messages encouraging them to:
     • Share reviews.
     • Answer questions posted by other users.

3. User Profiles

• Every user contributing UGC will have a public profile that may display:
  1. Number of trips completed.
  2. Reviews and ratings written.
  3. Questions asked and answered.
  4. Photographs posted (if applicable).
• Other users can view this profile to gauge contributions and interactions.

4. Third-Party Involvement

• TWM may hire third parties to collect feedback about your recent bookings.
• Such feedback helps improve services and address user concerns effectively.

Important Notes on UGC

• Reviews and ratings may be visible to other users within the TWM community and on external platforms.
• Participation in these activities helps improve the overall community experience by providing transparency and encouraging informed decisions.

I. How Can You Opt-Out of Receiving Our Promotional Emails? – True Wave Marketing (TWM)

 

1. Receiving Promotional Emails

As part of engaging with True Wave Marketing (TWM), you may occasionally receive promotional emails about:

• Special offers and deals.
• Fare sales in your area.
• New services or noteworthy updates from TWM.
• Other promotions designed to provide value to you.

We strive to make these updates interesting and informative for all our users.

2. How to Opt-Out

If you prefer not to receive promotional emails, you can opt-out at any time by:

• Clicking the "unsubscribe" link included in every promotional email.
• Following the unsubscribe instructions mentioned in the email.

3. Important Notes

• Opting out of promotional emails will not affect other necessary communications, such as booking confirmations, transaction-related emails, or updates about your services.
• You may re-subscribe to promotional emails at any time if you change your preferences.

J. Permissions Required for Using Our Mobile Applications – True Wave Marketing (TWM)

When the True Wave Marketing (TWM) app is installed on your mobile device (phone or tablet), certain permissions are required for the app to function effectively. The permissions, along with the data accessed and their purposes, are outlined below:

1. Device Permissions Required

A. Location Access

• Why:
  1. To offer location-specific deals, services, and recommendations.
  2. To assist in identifying nearby services, events, or offices.

B. Storage Access

• Why:
  1. To allow saving and retrieving invoices, booking receipts, and other documents.
  2. To enable uploading images or files during account setup or feedback submissions.

C. Camera Access

• Why:
  1. For uploading profile pictures or documents (e.g., ID proof for bookings).
  2. To facilitate QR code scanning for faster transactions or check-ins.

D. Contacts Access

• Why:
  1. To simplify referral processes by selecting contacts from your address book.
  2. To enable sharing app links or promotional offers with your contacts.

E. Phone Access

• Why:
  1. To allow direct calls to customer service or service providers through the app.
  2. To identify device-level authentication for secure access.

F. SMS Access

• Why:
  1. To automatically read and verify OTPs (One-Time Passwords) for seamless login and secure transactions.

G. Notifications

• Why:
  1. To send important updates, booking confirmations, reminders, and promotional offers.

 

2. Why These Permissions Are Important

The permissions enable the app to:

• Deliver personalized experiences.
• Provide seamless navigation and efficient service booking.
• Ensure secure transactions and data handling.

 

3. No Customization of Permissions

• The permissions listed are standard and required for the app to function optimally.
• There is no option to customize or selectively allow permissions.

4. Data Security and Privacy

• All data accessed through these permissions will be used strictly for the stated purposes.
• TWM follows strict data protection protocols to ensure your privacy and security.

K. How We Protect Your Personal Information – True Wave Marketing (TWM)

True Wave Marketing (TWM) is committed to safeguarding your Personal Information and employs advanced security measures to ensure your data remains protected at all times.

1. Secure Payments

• All payments made on the TWM Website are secured using TLS (Transport Layer Security) encryption.
• What is TLS?
  1. TLS is a reliable coding system that automatically encrypts (scrambles) your data before it is transmitted to us.
  2. This ensures that sensitive information, such as payment details, remains secure during transmission.

2. Stringent Security Measures

• The TWM Website has robust security protocols to protect your data from:
  1. Loss.
  2. Misuse.
  3. Unauthorized alteration.

3. Secure Server Access

4. Post-Storage Security

• Once your information is stored in our systems, we adhere to strict security guidelines to prevent:
  1. Unauthorized access.
  2. Breaches or misuse of your data.

Your Responsibility

While TWM ensures secure handling of your information, it is also essential for users to:

• Use strong passwords and keep them confidential.
• Avoid sharing account credentials with unauthorized persons.

L. Withdrawal of Consent and Permission – True Wave Marketing (TWM)

You have the right to withdraw your consent or decline to provide any permissions regarding your Personal Information at any time.

1. How to Withdraw Consent

• Twmarketing46@gmail.com.

2. Impact of Withdrawing Consent

• Limited Access:
  1. If you withdraw your consent, your access to the True Wave Marketing (TWM) Website or app may become limited.
• Services May Be Affected:
  1. We may not be able to provide certain services or features without the necessary permissions or information.
  2. For example, booking services or personalized recommendations may be impacted.

3. User Responsibility

M. Your Rights Regarding Personal Information – True Wave Marketing (TWM)

As a user of True Wave Marketing (TWM), you have specific rights regarding your Personal Information stored on our platform.

1. Access to Your Personal Information

2. Correction of Personal Information

• If you find any inaccuracies in your Personal Information, you can:
  1. Correct the information directly from your user account.
  2. Update fields (except mandatory fields required for our services).

3. Deletion of Personal Information

• You have the right to delete your Personal Information from your account (except for mandatory fields).
• If you do not have a user account or are unable to make changes directly, you can request assistance by writing to:
  1. Email: Twmarketing46@gmail.com

4. Mandatory Fields

N. Eligibility to Transact with True Wave Marketing (TWM)

To engage in transactions with True Wave Marketing (TWM) and consent to the processing of your Personal Information, you must meet the following criteria:

1. Minimum Age Requirement

2. Consent to Data Processing

O. Changes to the Privacy Policy – True Wave Marketing (TWM)

True Wave Marketing (TWM) reserves the right to revise and update its Privacy Policy as needed to comply with legal, business, or customer requirements.

1. Revisions to the Privacy Policy

• The Privacy Policy may be updated periodically to reflect:
  1. Changes in legal requirements.
  2. Adjustments to business operations.
  3. Evolving customer needs.

2. Notification of Changes

3. Submitting Concerns

• You may share any concerns or inquiries regarding this Privacy Policy by contacting us via email:
  1. Email: Twmarketing46@gmail.com

4. Response Commitment

• TWM will make every effort to address all reasonable concerns and inquiries promptly.
• For any updates or clarifications, stay informed through:
• Website: www.truewave.club
• Email: Twmarketing46@gmail.com