The Cendant Group of Companies and the RCI Group of Companies, both to which
RCI India Pvt. Ltd. ("RCI" or "we") belongs, respect your
privacy. Accordingly, RCI has reviewed its policies and practices to ensure that
they meet all applicable legislation in relation to your privacy and will
continue to ensure that its policies and practices comply in all respects with
any future laws and regulations in relation to your privacy
The purpose of this document is to inform you of the policies that have been put
in place to protect your interests in this respect.
1. Fair and lawful information-handling
We will process all the data we collect and hold on you fairly and in accordance
with applicable law. As further explained in this policy statement, we will
ensure the quality and security of your data (even if the data are transferred
to other companies in India, Europe or elsewhere); and we will fully respect
your rights, interests and fundamental freedoms with regard to your data.
2. Legitimate purposes
We will only collect, record, process and store data which are needed to fulfil
our contractual obligations towards our customers, our partners, and the
customers of our partners; to serve other legitimate business interests such as
credit assessment or marketing; or to comply with legal requirements.
We may disclose to any other company or companies within the Cendant Group of
Companies, the RCI Group of Companies and to third parties authorised by us such
information as may be necessary to provide you with products and services you
have requested or for the purpose of verification of details relating to your
data held by us for legitimate purposes.
3. Data quality
We will employ effective procedures and safeguards to ensure that the data we
hold on you are adequate, relevant and not excessive in relation to the purposes
for which they were obtained, as well as accurate and up-to-date. Where we
become aware of any inaccuracies in the data we hold, we will correct and, where
appropriate, delete incorrect data.
Retention periods are in place to ensure that data are only stored whilst they
are required for the purposes in question or to meet legal and regulatory
requirements. Where data are no longer required, we will ensure that they are
disposed off in a secure manner.
4. Information to you
When we collect data from you, we will identify ourselves and inform you of the
purpose(s) for which we collect the data. If we are collecting data from you on
behalf of one of our sister or subsidiary companies, or affiliates, associates
or partners, we will identify that sister or subsidiary company or affiliate,
associate or partner (the "controller") and explain that we are acting
as the agent (or "processor") for that other company. If our
affiliate, associate or partner is a non-Indian company which has appointed a
representative in India, we will also inform you of the identity of that
representative (which may be RCI). If we have obtained data on you other than
directly from you, we will inform you of this as soon as practicable after we
have entered the data in our files or computers (unless you were already aware
of the fact).
We may also record or monitor telephone calls to and from any Cendant Group
Companies or RCI Group Companies (including RCI India Pvt. Ltd.), without
notification, for staff training and quality control purposes.
5. When will we seek your prior consent?
We will go further and ask for your prior consent in the following
circumstances:
- a credit check on you;
- before we pass on any of your data to other companies for direct marketing
purposes, by offering you the opportunity to object to such disclosures
either through a "tick-box" on your purchase order form or booking
form or membership application or enrolment form, or by asking you to notify
us by telephone, fax or e-mail. (If you use more than one e-mail address to
communicate with us, please notify us of each e-mail account you use.);
- if we process sensitive data on you under any contract with you (or under
a
contract between you and a company we represent).
6. Special restrictions on the use of sensitive data
- required to be kept by law
- needed for legal proceedings or to establish, exercise or defend legal
rights (including protection against fraud)
- clearly and strictly necessary to fulfil a contract between you and us (or
between you and a company we represent) or
- needed to protect your vital interests or the vital interests of another
person (for instance, if medical data are urgently required after an
accident and you cannot give your consent).
7. Your rights
You have the right to require us or our partners to cease the communication of
advertising or marketing material to you, and we will ensure that your request
is complied with. This includes the right to withdraw your consent to
third-party direct-marketing use of your data at any time.
You have the right to see all the data we hold on you. Should you wish to have
access to all or a particular part of your data, please contact the Data
Protection Co-ordinator at RCI India Pvt. Ltd., 208, Brigade Gardens, 19, Church
Street, Bangalore - 560 001, India. Such access will be granted in accordance
with the requirements of applicable legislation and subject to any discretionary
allowance for RCI to make a charge payable by you to cover RCI's administration
costs incurred in providing you with such data. Such payment to be made on
application for access to your data and to be no more than the maximum
stipulated by applicable legislation. The information will be forwarded to you
within an appropriate period of time in accordance with applicable legislation,
but in any event no more than 40 days from the date of such request for access.
Where any discrepancies are discovered following your enquiry, we will take
immediate steps to validate and, where appropriate, correct our records. We will
confirm the actions taken in writing to you within an appropriate period of time
in accordance with applicable legislation, but in any event no more than 40 days
after receiving your request to amend our records.
8. Security of information
We will only provide access to data on you to those of our employees who need
such access in order to carry out any necessary processing. We have taken
appropriate steps to ensure the security of data whether it is stored in
computer systems, paper files or other storage media. We expect the same high
standards of security and confidentiality of any sub-contractors we employ to
process data for us.
9. Transfer of information outside the area of operation of this Web site
Data on you may, on occasion, be transferred to RCI Group Companies' facilities
or any company within the RCI Group of Companies, or to any other company or
companies within the Cendant Group of Companies, or to its or their affiliates,
or to data processing agencies ("processors") or third parties,
outside the area of operation of this Web site for analysis, technical
processing or other legitimate purposes. The countries where such other
facilities or companies are situated may have no data protection legislation, or
laws which are less rigorous than the legislation applicable to the area of
operation of this Web site.
In such cases, we will ensure that your rights with regards to any such
processing and your data will still be adequately protected. Within the Cendant
Group of Companies we have agreed world-wide acceptance of the European
standards with regard to the processing of personal data from all our European
companies, including RCI. If we transfer your data to agencies or third parties
outside the area or operation of this Web site, we require similar, binding
contractual undertakings, and we monitor compliance. Our affiliates, associates
and partners have agreed to adopt equivalent measures.
10. Direct marketing
We, or any other company or companies within the RCI Group of Companies or the
Cendant Group of Companies or third parties authorised by us, may market to you
directly through any media to keep you informed of further offers from us, or
any other company or companies within the RCI Group of Companies or the Cendant
Group of Companies or third parties authorised by us, which may be of interest
to you (unless you write to us asking us to exclude you from such offers or
alternatively telephone, fax or e-mail us to that effect or you have done so
previously and such exclusion is still operative) and for our own
administration, market analyses and operational reviews. (If you use more than
one e-mail address to communicate with us, please notify us of each e-mail
account you use.)
We, or any other company or companies within the RCI Group of Companies or the
Cendant Group of Companies or third parties authorised by us, may make contact
with you by post, e-mail, telephone (including automated dialling equipment),
facsimile transmissions, and/or pre-recorded messages for the purposes set out
herein (unless you notify us either in writing or by telephone, fax or e-mail
that you object to being contacted in a particular stated way and/or by a
certain stated company or companies within the RCI Group of Companies or the
Cendant Group of Companies or by third parties authorised by us). (If you use
more than one e-mail address to communicate with us, please notify us of each
e-mail account you use.)
We, or any other company or companies within the RCI Group of Companies or the
Cendant Group of Companies or third parties authorised by us, will always act
according to your wishes and preferences. Whenever we, or any other company or
companies within the RCI Group of Companies or the Cendant Group of Companies or
third parties authorised by us, directly market to you by telephone or fax, we,
or any other company or companies within the RCI Group of Companies or the
Cendant Group of Companies or third parties authorised by us, will comply
beforehand with the requirements of applicable legislation under and by which
you have recorded your desire not to be contacted by telephone and/or fax, as
the case may be, for the purposes of direct marketing by any organisation. If
you have notified such desire according to the laws of your country of domicile,
then we will not call or fax you unless you subsequently notify us directly
(either in writing, or by telephone, fax or e-mail) that this no longer applies
or at least does not apply to any other company or companies within the RCI
Group of Companies or the Cendant Group of Companies or to third parties
authorised by us. (If you use more than one e-mail address to communicate with
us, please notify us of each e-mail account you use.)
11. Internet
At RCI, we are committed to protecting your privacy in the following ways:
- When you use this Web site for information or transactional purposes
on-line, we may need to know your name, e-mail address, mailing address and
contact telephone number, facsimile number, credit card
number and
expiration date, and other related information. This allows us to process
and fulfill your requirements and requests.
- When you use this Web site for transactional purposes on-line we use a
secure server. The secure server software ("SSL") encrypts all
credit card details you input before it is sent to us. We use Verisign as an
officially recognised trusted third party to authenticate and certify the
security of this Web site and to encrypt your credit card details.
- When you use this Web site, we may monitor customer traffic patterns and
site usage to help us develop its design and layout.
- When you use this Web site, we may also use the data we collect to
occasionally notify you about important functionality changes to it, and to
notify you of new products or services, and special offers we think you'll
find valuable and of interest.
- When you use this Web site, and enter a contest or other promotional
feature, we may ask for your name, address, contact telephone number, e-mail
address, and facsimile number so that we can administer the contest and
notify winners accordingly.
- When you use this Web site, we may provide aggregate statistics about
members of RCI entering into transactions on-line, sales, traffic patterns
and related Web site information to reputable third parties, but these
statistics will include no personally identifying data.
- RCI is the sole controller of all data held in relation to your use of
this Web site for information and transactional purposes on-line and all
processing of data relating to your requirements and requests is therefore
subject to the data protection laws and regulations of your country of
domicile. If no such laws and regulations exist in your country of domicile,
then all processing of data relating to your requirements and requests is
subject to Indian data protection laws and regulations only being the laws
applicable to the area of operation of this Web site.
- We will maintain records relating to your use of this Web site for
information and transactional purposes on-line (including information about
you provided by yourself or by third parties). We shall be entitled to
process those data for the purpose of providing your requirements and
requests and to keep you informed of further offers from us which may be of
interest (unless you write to us asking us to exclude you from such offers
or alternatively telephone, fax or e-mail us to that effect). (If you use
more than one e-mail address to communicate with us, please notify us of
each e-mail account you use.) We shall be entitled to disclose to any other
company or companies within the RCI Group of Companies or the Cendant Group
of Companies, or to third parties authorised by us, such information as may
be necessary to provide your requirements and requests or for the purpose of
verification of details relating to any requests for information or
transactions on-line you may make with RCI.
- We will not send you e-mails that you do not want, but we cannot guarantee
that third parties to whom your details are sent will not do so.
- You are entitled to receive a copy of any data held by us on you in
accordance with the requirements of applicable legislation and subject to
any discretionary allowance for RCI to make a charge payable by you to cover
RCI's administration costs incurred in providing you with such data. Such
payment to be made on application for access to your data and to be no more
than the maximum stipulated by applicable legislation. The information will
be forwarded to you within an appropriate period of time in accordance with
applicable legislation, but in any event no more than 40 days from the date
of such request for access.
- Where any discrepancies are discovered following your enquiry, we will
take immediate steps to validate and, where appropriate, correct our
records. We will confirm the actions taken in writing to you within an
appropriate period of time in accordance with applicable legislation, but in
any event no more than 40 days after receiving your request to amend our
records.
- We will always seek your consent before disclosing data relating to you
for the making of offers by third parties by informing you of an intention
to process your data for such purposes, and offering you a possibility to
opt out of such use of your data, in a form or document returned to us or by
notifying us by telephone, fax or e-mail. (If you use more than one e-mail
address to communicate with us, complete this form for each e-mail account
you use.)
- If at any time you feel that RCI has not adhered to these principles,
please either notify us in writing or by telephone, fax or e-mail and we
will use all commercially reasonable efforts to determine and correct the
problem promptly. RCI welcomes your questions and comments about privacy.
Bangalore +9180-41849100/66915555