WAYW Retail Pvt Limited takes the privacy of your information seriously. This Privacy Notice describes the Data we collect from you through our website, including sub-domains and microsites. It also describes the purposes for which we collect that personal information, the other parties with whom we may share it and the measures we take to protect the security of your data. It also tells you about your rights and choices with respect to your personal information, and how you
can contact us about our privacy practices.

This Privacy Notice & Privacy Policy (“Policy”) is published in accordance with Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information or Data) Rules, 2011 read with Rule 3(1) of the provisions of Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.

You are advised to carefully read this Privacy Notice before using or availing any of the products and/or services offered on our Platforms.

1.DEFINITIONS
In this Privacy Notice, the following definitions are used:
Cookies
a small file placed on your device by our Platforms when you either visit or use certain features of our Platforms. A cookie generally allows a website to remember your actions or preference for a certain period of time.

Data
includes non-personal information, personal information and sensitive personal information about you, which either directly or indirectly in combination with other information, could allow you to be identified when you visit our Platforms.

Data Protection Laws
any applicable law for the time being in force relating to the processing of Data.

Service Providers
includes entities to whom we may disclose your Data in order to process information for a specific purpose pursuant to written contract.

TUL
WAYW Retail Pvt Limited, a company incorporated in India whose registered office is at 241 4th Floor, R Block 21 Garden Apartments Vittal Mallya Road  BANGALORE KARNATAKA 560001.

User or you
the natural person who accesses our Platforms.

2.WHAT DATA DO WE COLLECT ABOUT YOU

WRL collects Data for various purposes set out in this Privacy Notice.

This Data may include, without limitation, the following categories:

Contact information: first and last name, email address, postal address, country, employer, phone number and other similar contact data.

Financial information: payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data.

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.

Transaction information: the date of the transaction, total amount, transaction history and preferences and related details.

Product and service information: Your account membership number, registration and payment information, and program-specific information, when you request products and/or services directly from us, or participate in marketing programs.

Personal information: Age, sex, date of birth, marital status, nationality, details of government identification documents provided, thumb impression, occupation, or any other personal information provided in product reviews or responses to surveys or questionnaires.

Your reviews, feedback and opinions about our products, programmes and services.

Loyalty programme information: your loyalty membership information, account details, profile or password details and any frequent flyer or travel partner programme affiliation.

3. HOW WE COLLECT DATA

We collect Data in the following ways:

Information You Give Us: We receive and store any information you enter on our Platforms or give us in any other way (e.g., at outlets, stores, hotels, kiosks). Please see the section titled “Data Shared by You” for more information.

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: To help us make e-mail more relevant and interesting, 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. Because we process this information on behalf of the applicable website operators, collection, processing, and use of such information is subject to the applicable website operators’ specific privacy policies and is not covered by our Privacy Notice.

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 Platforms. When you are asked to provide Data, you may decline.

4.DATA SHARED BY YOU

WRL may collect your Data in several ways from your use of our Platforms. For instance:

when you register with us to purchase products and / or services, directly from us or from sellers listed on our Platforms;

when you conduct a transaction with us or attempt a transaction at on our Platforms;

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 Platforms;

If you provide Data on behalf of any corporation, company, institution,
association or other entity, you represent that you are providing the same under authority from such corporation, company, institution, association or other entity.

5.DATA THAT IS COLLECTED AUTOMATICALLY

We automatically collect some information when you visit our Platforms. 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. WRL uses this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of our Platforms.

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”.

6.OUR USE OF DATA

Any or all the above Data may be required by us from time to time to provide information relating to WRL and to work on the experience when using our Platforms. Specifically, Data may be used by us for the following reasons:

carry out our obligations arising from any contract entered into with WRL

provide products and/or services and communicate with you about products and/or services offered on our Platforms;

provide you with offers personalized services and recommendations and improve your experience on our Platforms;

operate, evaluate and improve our business

generate aggregated data to prepare insights to enable us to understand customer behaviour, patterns and trends with a view to learning more about your preferences or other characteristics;

provide privileges and benefits to you, marketing and promotional campaigns based on your profile;

We treat these inferences as personal information (or sensitive personal information, as the case may be), where required under applicable law. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

Where required under applicable law, we will only use your personal information with your consent; as necessary to provide you with products and/or services; to comply with a legal obligation; or when there is a legitimate interest that necessitates the use.

7.MINORS

Our Platform do not offer products or services for use by minors. If you are under 18, you may use our Platforms only with the involvement of a parent
or guardian.

8.SHARING OF DATA

We may share your Data with/ for:

Partners: We may make available to you services, products, or applications provided by Partners for use on or through our Platforms. If you choose to use such service, customer information related to those transactions may be share with such Partner.

Such Partners will be required to respect the security of your Data and to treat it in accordance with this privacy policy and applicable law.

These Service Providers will be required to only process Data in accordance with express instructions and as necessary to perform services for purposes set forth in this Privacy Notice. The Service Providers will also be required to safeguard the security and confidentiality of the Data they process by implementing appropriate technical and organizational security measures and confidentiality obligations binding employees accessing Data.

Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data (including in relation to loyalty programs) may be transferred as part of such transaction.

Third Parties: We may also share your Data with other third parties where:

We require these third parties by contract to only process sensitive personal data in accordance with our instructions and as necessary to perform services on our behalf or in compliance with applicable law. We also require them to safeguard the security and confidentiality of the sensitive personal data they process on our behalf by implementing appropriate confidentiality, technical and organizational security measures.

9.KEEPING DATA SECURE

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

10.RETENTION OF DATA
WRL retains Data for as long as necessary for the use of our Platforms or to provide access to and use of our Platforms, 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 1 below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

11.YOUR RIGHTS AND CHOICES
When we process Data about you, we do so with your consent and/or as necessary to operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of WRL as described in this Privacy Notice.

We may transfer Data we collect about you to recipients in India, where we are headquartered. India may not have the same Data Protection Laws as the country
in which you initially provided the information. When we transfer your Data to India, we will protect that information as described in this Privacy Notice, as disclosed to you at the time of data collection or as described in our program-specific privacy notice.

For processing your Data under this Policy we may transfer your Data to Partners outside India. Such transfer shall be in accordance with Data Protection Laws of India.

Depending on which Data Protection Laws are applicable to you, you may have the right or choice to:

opt out of some collection or uses of your Data, including the use of cookies, pixels and similar technologies and the use of your Data for marketing purposes.

access your Data, rectify it, restrict or object to its processing, or request its deletion or anonymization.

change or edit information submitted to us.

receive the Data you provided to us to transmit it to another company.

withdraw any consent provided or alter your preferences.

where applicable, lodge a complaint with your supervisory authority.

You may submit a request as described in the “Contact Us” section . We will not charge you for any request. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

You may write to us for the following rights in relation to your Data:

Right to Correction - the right to have your Data rectified if it is inaccurate or incomplete.

Right to request deletion- the right to request that we delete or remove your Data from our systems.

Right to Withdraw Consent – the right to withdraw your consent provided earlier.

For information about managing your Data and promotional communications, please connect with us by accessing this link https://www.thewayw.com/contactus

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.

12.WHERE WE STORE DATA
Data collected under this Privacy Notice is hosted on servers located in India.

13.PROCESSING YOUR DATA
We take steps to ensure that the Data we collect under this Privacy is processed according to the provisions of this Policy and the requirements of applicable law.

14.COOKIES, PIXELS AND SIMILAR TECHNOLOGIES
Our website and mobile application may place and access certain Cookies on your device. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device. We also use pixels and similar technologies to analyse traffic on our website and mobile application to improve your experience of using them.

When you first visit our website and mobile application, you will be presented with a pop-up screen informing you of our use of Cookies and asking you to provide your consent for such use. The pop-up screen may not reappear for all your subsequent visits to our website and mobile application, but you may adjust your web browser software if you do not wish to receive Cookies or web beacons, but this may prevent you from taking advantage of some of the features of our website and mobile application. Please refer to your browser instructions or help pages to learn more about these functions.

15.SECURITY
WRL implements standard measures to protect against unauthorized access to and unlawful interception of Data. However, no internet site can fully eliminate security risks. WRL endeavors to take all measures to protect the security, integrity and confidentiality of the Data against unauthorized breach and hacking. For the purpose of checking possible vulnerabilities and attacks, WRL may conduct periodical internal review of data and security measures on the
Platforms. However the internet is not absolutely a secure environment, and the Platforms cannot ensure or warrant a 100% security of the Platforms.

If you are provided with any identification code, password or any other piece of information as part of the Website’s security procedure, you should treat such information as confidential and not disclose it to any third party including to other users. You are solely responsible for the activities that occur under your account including the confidentiality of the your password and WRL is not
responsible for the same.

Notwithstanding anything contained in this Policy or elsewhere, WRL shall not be held responsible for any loss, damage or misuse of the Data, if such loss, damage or misuse is attributable to a Force Majeure Event. A "Force Majeure Event" means any event that is beyond the reasonable control of WRL and includes, without limitation, fire, flood, explosion, acts of God, civil commotion, strikes, lock outs or industrial action of any kind, riots, insurrection, war, acts of government, power failure, sabotage, computer hacking, unauthorised access to computer data and storage device, system failure, virus, attacks, bugs, computer crashes, breach of security and encryption.

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

17.CHANGES TO THIS POLICY
Our business changes constantly and our Policy will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our Platforms frequently to see recent changes. The updated version will be effective as soon as it is accessible. Any changes will be immediately posted on our Platforms and you are deemed to have accepted the terms of the updated Policy on your first use of our Platform or first purchase of the products and/or services following the alterations. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

18.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 reachus@thewayw.com. We will respond to your request within
30 days.