Ghoomakkad Travels ("we/ us/ our/ GT") values the trust which a customer ("you/ your") places in GT and our website, explorekkia.com ("Website"). Hence, we insist upon the highest standards of practices to ensure security of transactions and utmost privacy of customer information. We respect your need to understand how information furnished by you is being collected, used, disclosed, transferred and stored by us. In this regard, please read this privacy policy ("Policy") to get familiarized with our information gathering and dissemination practices.

We assure you of our firm commitment to your privacy and the protection of your valuable information. The Policy contains information about the Website and the 'Ghoomakkad Travels' android and iOS app (such applications are collectively referred to as the "App"). In order to provide you with uninterrupted use of our services, we may collect and, in some circumstances, disclose information about you. If you do not agree to the terms in this Policy, we kindly ask you to discontinue use of our Website and App.

If you have any questions or concerns regarding this privacy policy, you should contact us through our Contact Us section on the Website.

REGULATORY COMPLIANCE

General Data Protection Regulation (GDPR)

As you may know, the European privacy regulation called General Data Protection Regulation ("GDPR") came into effect on May 25, 2018. GDPR is designed to unify the current data protection privacy laws throughout the EU, and to enhance the rights of European residents to protect their personal information. The GDPR also applies to any business that offers its products or services to European residents.

Digital Personal Data Protection Act, 2023 (DPDP Act)

We are committed to complying with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), which governs the processing of digital personal data in India. Under the DPDP Act, we process your personal data lawfully, fairly, and transparently, and only for specified, explicit, and legitimate purposes.

We collect and use your personal information when you avail our services. For the purpose of the General Data Protection Regulation ("GDPR") and the DPDP Act, 2023, we are the 'data controller' or 'Data Fiduciary' as applicable. Our Data Protection Officer can be contacted through our Contact Us section.

By accessing our Website and utilizing our services, you acknowledge that you have read and understood this Privacy Policy and the information collection and handling practices outlined in it. If you are below 18 years of age, you must obtain verifiable consent from your parent or legal guardian before providing any personal data.

OVERVIEW

This Privacy Policy describes in detail our policy and practices regarding our collection, use, and disclosure of your personal data.

We understand that providing information online involves a great deal of trust on your part. We take this trust very seriously, and make it a high priority to ensure the security and confidentiality of the personal data you provide us when you visit our Website or use our services.

CONTENTS

1. Collection of your personal data
2. How we use your personal data
3. Use of Demographic and profile data
4. With whom we share your personal information
5. How long we keep your personal data
6. Cookies and similar technologies
7. How we protect your personal data
8. Notifications of modifications
9. Sharing of traveler's photos and videos
10. Security precautions
11. Your rights and choices
12. Advertisement on website
13. Transfer of information overseas
14. EU and UK data subject rights
15. Indian data principal rights (DPDP)
16. Children's privacy
17. Confidentiality
18. Disclaimer
19. Grievance redressal mechanism
20. Contact information

1. COLLECTION OF YOUR PERSONAL DATA

Personal data means any information about an individual from which that person can be identified, including but not limited to name, email addresses, date of birth, password, and payment information. It does not include data where the identity has been removed or otherwise anonymized (anonymous data).

Information We Collect

• Name
• Email address
• Contact number / Mobile number
• Residential address / Billing address
• Credit/debit/bank account details / Payment information
• Internet Protocol ("IP") address
• Date of birth / Age
• Gender
• Nationality and passport information
• Travel preferences and history
• Device information and identifiers
• Location data (with your consent)
• Photos and videos submitted by you
• Communication records with us
• Feedback, reviews, and survey responses

When We Collect Information

We collect your personal information in the following circumstances

1. When you make an inquiry, request a quotation, or book a tour package through our marketplace platform
2. When you register with us, make a requisition for information pertaining to holiday packages, subscribe to our newsletters, enter competitions, share with us your experience or provide any other details in relation to a holiday package
3. When you send us queries or register for promotions
4. When you set up a free account on our Website or App or participate in surveys or provide feedback
5. When you engage with us in any online or offline event or express interest on any page hosted by us on a third-party platform or location or voluntarily provide your details for our promotions

Mandatory and Optional Information

While you can browse certain sections of our Website or App without registration, certain activities (such as requesting quotations or booking tour packages) require mandatory registration and provision of personal information.

We may use your contact information for sending you:

• Offers based on your previous inquiries and your interests
• Payment reminder notices
• Travel vouchers
• Updates on the travel sector through our newsletters

In the event you do not wish to receive such information, you may unsubscribe through the facility in the email message you receive or contact us through our Contact Us section.

2. HOW WE USE PERSONAL DATA

We use personal information to provide the services that you request and to operate our marketplace platform effectively. To the extent we use your information including personal information to market our services to you, we will provide you the ability to opt-out of such uses.

Purposes of Processing

We may use your personal information for the following purposes, including but not limited to:

Service Delivery:

• Facilitate connections between you and tour operators on our marketplace platform
• Process your inquiries, quotation requests, and bookings
• Provide customer support and respond to your queries
• Send important service-related notifications and updates
• Platform Operations:
• Resolve disputes and troubleshoot problems
• Promote a safe service
• Collect fees owed to us (platform service fees)
• Cater to consumer interests while providing our services
• Customize and enhance your experience
• Legal and Security:
• Detect and protect us against error, fraud, and other criminal activity
• Enforce our terms and conditions
• Comply with legal obligations
• Conduct periodic audits
• Marketing and Communications:
• Inform you about online and offline offers, products, services, and updates
• Conduct marketing campaigns and promotions
• Send newsletters and travel information

Analytics and Improvement

• Conduct research and analysis to improve customer experience
• Understand user behavior and preferences
• Develop new features and services

Marketing Promotions

Marketing promotions, research, and programs help us identify your preferences, develop programs, and improve user experience. GT may conduct promotions, contests, or giveaways to provide users opportunities to win travel and travel-related prizes. Personal Information collected for such activities may include contact information and survey responses. We use such information to notify winners, analyze preferences, and improve our offerings.

You have the right to opt-out of marketing communications at any time by using the unsubscribe link in our emails or contacting us through our Contact Us section.

3. USE OF DEMOGRAPHIC AND PROFILE DATA

In our efforts to continually improve our product and service offerings, we may, from time to time, collect and analyze demographic and profile data about your activity on our Website and App.

Information We Analyze

• IP Address: We identify and use your IP address to help diagnose problems with our server, administer our Website and App, and gather broad demographic information
• Browsing Behavior: Pages visited, search queries, links clicked, and usage patterns
• Device Information: Type of device, operating system, browser type
• Demographic Data: Age range, gender, location, language preferences

Purpose of Analysis

We use this data to:

• Tailor your experience on our Website and App
• Provide you with content and offers that match your interests
• Display relevant tour packages according to your preferences
• Improve our platform functionality
• Optional Surveys

We may occasionally ask you to complete optional online surveys, which may require you to provide contact information and demographic information (such as zip code, age, or income level). We use this data to provide you with content that we think you might be interested in and to display relevant content according to your preferences.

4. WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

Important Note: As Ghoomakkad Travels operates solely as a marketplace platform connecting travelers with independent tour operators, we share personal information only where it is necessary to perform our contract with you, comply with legal obligations, protect our legitimate business interests, or where you have provided consent.

Sharing with Tour Operators

When you make an inquiry or booking through our platform, we share your relevant personal information with the tour operator(s) whose packages you have selected. Tour operators act as independent data controllers once they receive your information, and their use of your data will be governed by their own privacy policies.

Corporate Entities and Affiliates

We may share personal information with our parent company, subsidiaries, and affiliates to:

• Help detect and prevent identity theft, fraud, and other potentially illegal acts
• Correlate related or multiple accounts to prevent abuse of our services
• Facilitate joint or co-branded services that you request

Those entities and affiliates may not market to you as a result of such sharing unless you explicitly opt-in.

Service Providers and Business Partners

We may share your information with trusted third-party service providers who perform services on our behalf, including payment processors, technology service providers, customer service providers, and marketing partners.

Legal and Regulatory Authorities

We may disclose personal information when required or permitted by law, including:

• If required to do so by law or by law enforcement offices for investigating any civil or criminal offences
• If such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process
• To legal, financial, or other professional advisors of GT
• To enforce our terms of the Policy
• To respond to claims that content violates the rights of a third party
• To protect the rights, property, or personal safety of GT, our users, or the general public

Data Sharing Standards

We may share aggregated or anonymized data with business partners to improve site functionality and user experience. Personally identifiable information will only be shared where necessary to provide requested services or with your explicit consent.

To the extent that these entities have access to your information, they will treat it as protectively as they treat information they obtain from their other members. The entity with which such information is being shared will be required to follow this Policy with respect to your personal information.

5. HOW LONG WE KEEP YOUR PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, tax, or statutory reporting requirements.

Retention Criteria

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process your personal data
• Whether we can achieve those purposes through other means
• The applicable legal requirements

Post-Retention

We may retain certain information subsequent to the closing of your account, for example if it is necessary to fulfill our legal obligations, to maintain security, to prevent fraud and abuse, and to defend or enforce our rights. We require all third parties with whom we share personal information to implement appropriate technical and organizational measures to protect your data and to retain it only for as long as necessary to fulfill the purposes outlined above.

6. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on our Website and App.

What Are Cookies?

Cookies are small files stored on your device when you visit our Website. We use our own as well as third-party data collection devices such as cookies on certain pages of our Website and App. Cookies assist us in providing services customized to your requirements, interests, and preferences.

How We Use Cookies

We offer certain features which are only available through the use of a cookie. Cookies may be used whether you choose to register with us or not. We place both permanent and temporary cookies on your device. However, such cookies do not contain any of your personally identifiable information.

Third-Party Cookies

Third-party vendors such as Google may use cookies to serve advertisements based on your visits to this website. You may visit the website of the third party and choose to opt out of the use of cookies for interest-based advertising, if the third party offers such an option.

Managing Cookies

Most web browsers allow you to control cookies through settings. You can block or delete cookies, though this may limit functionality and affect your user experience.

7. HOW WE PROTECT YOUR PERSONAL DATA

GT takes the protection of your personal data seriously. Although we implement robust security measures to protect your information, unfortunately, the transmission of information via the internet is not completely secure.

Our Commitment

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any channel, such as the Website; any transmission is at your own risk.

Security Measures

We implement appropriate technical and organizational measures to safeguard your information against unauthorized access, alteration, disclosure, or destruction, including:

Encryption for data transmission

• Secure servers
• Access controls
• Regular security monitoring

8. NOTIFICATIONS OF MODIFICATIONS AND CHANGES TO THE POLICY

We reserve the right to change the terms of the Policy from time to time, as we deem fit, without any intimation to you, and your continued use of the Website or App will signify your acceptance of any amendment to these terms. You are therefore advised to re-read the terms of the Policy on a regular basis. Should it be that you do not accept any of the modifications or amendments to the terms of the Policy, you may terminate your use of our services immediately.

9. SHARING OF TRAVELERS' PHOTOS AND VIDEOS

We value the travel experiences and memories captured by our users. By sharing your travel photos or videos with Ghoomakkad Travels, you help inspire and inform other travelers.

License Grant

By voluntarily submitting your travel photos or videos to GT after availing our services, whether through our Website, App, email, or any other medium of communication, you grant to GT a non-exclusive, perpetual, worldwide, royalty-free, transferable, and sub-licensable license to edit, telecast, re-run, reproduce, use, syndicate, print, and distribute the materials you submit, or any portion thereof, in or in connection with GT and any of its affiliates' websites, programming, platforms and/or App (the manner, mode, and extent of which are subject to change without notice to you), in any manner, and in any medium or forum.

Your Representations and Warranties

You represent and warrant to GT that: You have the full legal right, power, and authority to grant the aforementioned license to GT. Your submission(s), and the exercise of the rights granted herein, do not and will not violate any applicable laws or regulations. Your submissions will not cause a breach of any agreement(s) entered by you with any third parties. None of the submission(s) will infringe any copyright, invade any right of privacy, right of publicity, contain any libelous or slanderous material, or infringe or violate any other intellectual property right or other right (including common law rights) of any other person or entity.

No Compensation

You acknowledge and agree that you will not be remunerated or compensated for any use of your submitted content by GT.

10. SECURITY PRECAUTIONS

Our Website and App have stringent security measures in place to protect against loss, misuse, and alteration of the information under our control.

Secure Access

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.

Payment Security

As soon as you declare the intent to book any tour package through our marketplace platform, the Website or App will transfer control to a specified and authentic payment gateway (such as PayU, Razorpay, Paytm, CCAvenue, or other PCI-DSS compliant gateways) that takes your credit card, debit card, or other banking information and processes the payment transaction. We do not store your complete credit/debit card information on our servers.

11. YOUR RIGHTS AND CHOICES

We respect your rights regarding your personal data.

Right to Opt-Out

If you so desire, you may opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us, in general, after setting up an account. You may also contact us through our Contact Us section to unsubscribe from our newsletters, publications, or any other material.

Voluntary Information

Please note that all information, including personal information provided by you, is voluntary in nature. You may, at any time, withdraw your consent, in accordance with this Policy. However, in the event you withdraw consent to provide information, including personal information, you agree that you will no longer be permitted to use our services.

Access and Modification

You can also access, modify, correct, and eliminate information provided by you which has been collected by us. We will not retain any personal information for a longer period than is required for the purposes for which the personal information may lawfully be used or is otherwise required under any other law for the time being in force.

Withdrawal Process

In the event you are not agreeable to the terms and conditions under this Policy and you are presently availing our services, we request you to kindly withdraw your consent or modify your information by contacting us through our Contact Us section, and uninstall our App through which you may be availing our services.

12. ADVERTISEMENT ON WEBSITE

We may use third-party advertising companies and networks to serve advertisements when you visit our Website and App.

Third-Party Advertising

Such companies may use information including your personal information in order to provide advertisements regarding goods and services that may be of interest to you.

Disclaimer

We cannot confirm or guarantee or take responsibility for the privacy practices or policies of such third-party advertising websites. We disclaim any liability towards any losses due to privacy infringement or other causes that you may suffer pursuant to access of such third-party advertising websites.

Recommendation

We encourage you to read the privacy policies of the relevant third-party advertising websites prior to accessing them.

13. TRANSFER OF INFORMATION OVERSEAS

GT's operations are based in Delhi, India. Accordingly, customer data will be accessible to GT's offices and appointed agents based in India.

Cross-Border Transfers

This means that customer data will be transferred to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA").

Legal Basis

If you are an EU resident, and we transfer customer data outside the EEA, this is done on the basis that it is necessary in discharge of the services rendered to you by GT or its agents.

Tour Operator Locations

As a marketplace platform connecting you with tour operators worldwide, when you book a tour, your information is shared with the relevant tour operator who may be located in various countries. Tour operators are responsible for their own data protection practices.

14. EU AND UK DATA SUBJECT RIGHTS

If you are a resident in the European Union (EU), European Economic Area (EEA), or the United Kingdom (UK), you have certain enhanced rights regarding your personal data under the General Data Protection Regulation (GDPR) and UK GDPR.

Your GDPR Rights

• Right to information - including contact details to our Data Protection Officer, the purposes for processing Personal Information, and the rights of the individual
• Right to access - the Personal Information that are processed
• Right to erasure ("Right to be forgotten")
• Right to rectification
• Right to restriction of processing
• Right to data portability - of the Personal Information supplied to GT by the EU resident
• Right to object (opt-out) to processing (unless GT otherwise has compelling legitimate grounds)
• Exercising Your Rights
• EU residents can exercise these rights by contacting us through our Contact Us section or by reaching out to our Data Protection Officer.
• Right to Complain

If you are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.

15. INDIAN DATA PRINCIPAL RIGHTS UNDER DPDP ACT

If you are a resident of India, you have specific rights under the Digital Personal Data Protection Act, 2023 ("DPDP Act").

Your Rights as a Data Principal

• Right to Access Information - obtain information about personal data being processed
• Right to Correction and Erasure - correct inaccurate data or request deletion
• Right to Grievance Redressal - file grievances and receive timely responses
• Right to Nominate - nominate another individual to exercise your rights in case of death or incapacity
• Right to Withdraw Consent - withdraw consent as easily as it was given
• Exercising Your Rights
• To exercise any of your rights under the DPDP Act, please contact us through our Contact Us section or reach out to our Grievance Officer.
• Children's Data

If you are under 18 years of age, you must obtain verifiable consent from your parent or legal guardian before providing any personal data to us.

16. CHILDREN'S PRIVACY

Our services are generally intended for individuals who are 18 years of age or older. If you are under 18 years of age, you must obtain verifiable consent from your parent or legal guardian before:

• Creating an account
• Providing any personal information
• Booking or inquiring about tour packages
• Special Protections

We apply enhanced security and privacy protections for children's data and will not use children's personal data for targeted advertising or behavioral marketing.

Parental Rights

Parents and legal guardians have the right to review, correct, or request deletion of their child's personal data by contacting us through our Contact Us section.

17. CONFIDENTIALITY

You further acknowledge that we may provide you certain information (apart from information available on the Website and App, which is in the public domain) which is designated confidential by us. You agree that you shall not disclose such confidential information without our prior written consent. Further, your information shall be regarded as confidential and therefore will not be divulged to any third party, unless legally required to do so to the appropriate authorities or otherwise permitted in terms of this Policy.

18. DISCLAIMER

As a user of the Website and App, you understand and agree that you assume all responsibility and risk for your use of the Website and App, the internet generally, and the documents you post or access and for your conduct on and off the Website and App.

Your use of the site is subject to our Policy. If you do not agree to this, we kindly request you not to use this portal.

19. GRIEVANCE REDRESSAL MECHANISM

In case you have any grievance related to:

Platform-related issues:

Contact us through our Contact Us section on the Website.

Tour package-related issues:

Such complaints must be directed to the respective tour operator who organized and executed the tour. However, in the interest of customer satisfaction, GT may, at its sole discretion and without any obligation, facilitate communication between clients and tour operators to help resolve disputes.

Contact

For all grievances and privacy-related concerns, please reach out through our Contact Us section available on the Website.

20. CONTACT INFORMATION

Ghoomakkad Travels
Corporate Office:Delhi, India
For Privacy and Data Protection Inquiries: Please use the Contact Us section on our Website
For General Support: Please use the Contact Us section on our Website
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Last Updated: January 2026

IMPORTANT NOTICE

By using the Ghoomakkad Travels platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. You further acknowledge and accept that Ghoomakkad Travels operates solely as a marketplace platform and bears no liability, whether direct or indirect, for any aspect of tour packages offered by independent tour operators listed on our platform.

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