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Privacy Policy

Introduction

  1. Mumbai Travel Retail Private Limited (“MTRPL” or “We” or “Our” or “Us”)” is engaged in the business of operating duty-free shops (“Stores”) at various international airports and seaports globally. Through our Stores, we allow visitors (“Customer” or “you” or “your”) to visit, access, and purchase (“Services”) a wide range of products, such as cosmetics, handicrafts, and souvenirs, amongst other goods (“Products”). Our Services can also be availed through the website and mobile application made available by our affiliate entity (both application and website collectively referred as “Adani Digital Platform”). 
  2. This Policy outlines our practices in relation to the Personal Information (defined below) that our Customers such as you, share with us and we collect from you, when you visit, access or transact at our Stores or kiosks placed within our Stores (“Kiosks”),  and the manner in which we collect, use, hold, transfer and process the Personal Information provided. We are committed to protecting your Personal Information and respecting your privacy.
  3. By availing our Services and/or giving your Personal Information to us, you confirm that you have the capacity to enter into a legally binding contract as per applicable laws, have read, understood, and agree with the privacy practices described in this Policy, and consent to the processing activities described hereunder.

Definitions

For the purposes of this Policy, the following capitalized terms shall have the meaning assigned to them below:

  • “Personal Information” with reference to any natural person, means any information that relates to such person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying that person. 
  • “Sensitive Personal Data or Information” or “SPDI” means Personal Information about a person relating to their:
    • password(s);
    • financial information (e.g., bank account, credit or debit card or other payment instrument details);
    • physical, physiological and mental health condition;
    • sexual orientation;
    • medical records and history;
    • biometric information;
    • any detail relating to the above as provided to us.

Any information that is freely available or accessible in the public domain or information which can be obtained by a governmental agency by exercise of its executive, legislative or judicial power is excluded from the definition of Personal Information.

What Data Do We Collect About You:

  • For various purposes as set out in this Policy, we may collect Personal Information (including information that qualifies as SPDI) from you, including, but not limited to:
    • Account Information: Your name, email address, date of birth, nationality, address, gender, phone number, loyalty membership information, boarding pass, passport, any frequent flyer or travel partner program affiliation, driving license, voter’s identity card issued by the Election Commission of India, or any other document recognized by the Government for identification, and other such contact information that you provide during registration, in response to surveys and questionnaires or otherwise.
    • Behavioral Information: Your purchase history such as the frequency of your visits or your spends in the Stores, and spending patterns.
    • Transactional Information: Your purchases, whether through our affiliate platforms or at the Stores, transaction status, your previous orders and transactions including incomplete or failed transactions, details of Products purchased, shipping details, your purchase preferences, and offers and discounts you have availed of. Transactional information gathered by us may be stored on servers, log files and any other storage system owned by any of us or by third parties.
    • Financial Information: Your payment instrument information, bank account details, transaction details, transaction history, preferences, method, mode and manner of payment, spending pattern and trends, and other similar data. It is clarified that we do not store any of your card details i.e., credit and debit card in our application or website. We may also collect your PAN card and GST details wherever such details are required as per legal compliance and obligations with your consent.
    • Other Information: Your Customer account membership number, registration information, program-specific information, telephonic conversations, and your reviews, feedback and opinions about our Products and Services. We also collect information from various surveillance mechanisms deployed at our Stores and the port premises, including through Closed-Circuit Televisions (“CCTVs”).  
  • We are entitled to and will rely upon the accuracy of the Personal Information furnished by you, as well as the accuracy of other data automatically collected or obtained when you access our Stores or avail of the Services.
  • We collect your SPDI directly from you. All SPDI provided by you to us is voluntary.
  • Your acceptance of this Policy constitutes your express consent to us for, inter alia, collecting, storing, recording, processing, using, disclosing, sharing or transferring to our affiliates and/or any third parties, whether located in India or in any other country, the Personal Information (including SPDI) for the purposes specified in this Policy. You agree that the Personal Information (including SPDI) may be shared with our affiliates, and government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment for offences.

You may choose to not provide us with any or all Personal Information, but in the event that you do so, we may be unable to provide you with some or all of our Services and/or access to the Stores.

Purposes for collection

We use the Personal Information collected from you through the Stores and otherwise, for various purposes including, inter alia:

  • Where necessary for us to comply with our legal/ regulatory obligations;
  • Where necessary for us to provide Services and to operate our business, including but limited to:
    • Improve our Services, applications, if any, and how we operate our business;
    • Understand and enhance your experience while using our Services;
    • Personalise Products or Services and make recommendations;
    • Provide and deliver Products and Services you request;
    • Process, manage, complete, and account for transactions;
    • Provide customer support and respond to your requests, comments, and enquiries; 
    • Internal training and quality control purposes; and
    • Create and manage customer accounts on our systems.
  • For invoicing, technical notices, updates, security alerts and support and administrative messages;
  • For analysing the use of our resources, troubleshooting problems and other internal business purposes and services, including without limitation, warehousing services, IT support services, and data analysis services;
  • For research, analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines and related purposes;
  • To process and fulfil your request for Services, respond to any queries or grievances that you may have and to communicate information to you including in relation to your inquiries about the Services offered;
  • To comply with health and safety obligations, and maintain security at the Stores;
  • For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research, determining footfall at the Stores;
  • For communicating with you about upcoming events, and news about products and Services by all modes of communication including but limited to message, SMS, WhatsApp messages (in consonance with the applicable privacy policies including this Policy), email, telecommunication services;
  • To communicate updates about the Services, details about new features and Products available in the Stores or on the Adani Digital Platform, transactional messages (such as subscription renewal reminders, payment failure triggers etc.), special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as refunds and returns, if applicable. These communications may be by various methods, such as email, push notifications, WhatsApp, or text messages.
  • We may process your Personal Information without your knowledge or consent where required by applicable law or regulation for the purposes of verification of identity or for prevention, detection, or investigation, including of cyber incidents, and prosecution for offences;
  • Protect, investigate, and deter against fraudulent, unauthorised, or illegal activity;
  • Protecting you, other Customers, employees and our business against, and preventing, harm of any kind, financial loss and other legal or information security risks;
  • In connection with loyalty programs owned and operated by us or by other affiliates; 
  • Creating a customer profile based on your usage of Adani Digital Platform;
  • Designing customized marketing and promotional campaigns for you based on your customer profile;
  • To create curated product-based collections such as top-rated or best-selling products basis your product reviews and purchase history;
  • To onboard you on one or more group-wide platforms or super-apps;
  • For enabling transactions across group entities; and
  • To share or transfer your Personal Information to an affiliate, our vendors or service providers or other third parties, for the purposes specified in this Policy including to, (i) perform any Services or processing on our behalf; (ii) market/ promote other services and products generally offered by us or affiliates through the Adani Digital Platform or any other platforms; (iii) give effect to any services that we avail from our affiliates or vendors.

How we collect information 

We collect Personal Information in the following ways:

  • Information you give us: We receive and store your Personal Information as provided by you in reference to your visit, access or any transaction at our Stores via EPOS or otherwise, any information you provide at our Kiosks and / or on Adani Digital Platform, or in any other manner.
  • E-mail communications: When you open e-mails from us or click on a link in the e-mails such as marketing emails, we collect information such as read-receipt, duration of visit to any web links therein. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
  • We may combine your Personal Information with information collected from tracking technologies and aggregate it with information collected from other Customers using our Service(s) to attempt to provide you with the Services and a better experience with the Service(s). You understand, agree and acknowledge that our collection, storage and processing of your Personal Information is for a lawful purpose connected with the functioning of the Service(s). You hereby consent to the collection, storage, use, disclosure, transfer, processing of the Personal Information for the purposes set out herein.
  • Information from other sources: We may obtain Personal Information from other sources. An example where we receive your Personal Information from our affiliates in relation to your use and/or access of our Services through the Adani Digital Platform, for the purposes of, inter alia, processing your orders. We may also receive and store certain types of Personal Information when you interact with third-party websites, which provide you access to our Services or with whom we have a specific arrangement for provision of certain services.
  • Information from affiliates: We may obtain Personal Information previously shared with any of our affiliates and if such information is Personal Information, the affiliate will only share such information with us with your consent.

Information shared by you 

We may collect your Personal Information in several ways from your use of our Services. For instance:

  • when you register with us to receive our Products and/or Services.
  • when you conduct a transaction or attempt a transaction on our website/app or Adani Digital Platform or any other Platform.
  • 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 website/app or Adani Digital Platform or any other Platform.
  • when you visit airports or seaports. 

We request you not to provide Personal Information about any other person unless you are authorized or required to do so under a contractual obligation or applicable law.

Permissible age 

The Services are not intended for Customers under the age of 18 (“Permissible Age”). We do not knowingly collect any Personal Information from Customers or market to or solicit information from anyone under the Permissible Age. If we become aware that a person submitting Personal Information is under the Permissible Age, we will delete the account and any related information as soon as possible. For Services involving the sale of alcohol or tobacco, the legal age as prescribed by the respective state where the sale is conducted will be considered as the Permissible Age for accessing such Services. 

If you are a parent or guardian and discover that your child under the Permissible Age, has accessed the Services and/or provided us with Personal Information, then you may contact the Grievance Redressal Officer as per Clause 15 below and request that we delete the relevant Personal Information from our systems.

Sharing or transfer of Information 

  • Subject to applicable law, we (or any person on our behalf) may at our sole discretion, transfer your Personal Information to any other body corporate (as defined under the IT Act) or a person in India, or located in any country. When your Personal Information is transferred, we will require that the transferee entity complies with the terms of this Policy and applicable data privacy laws.
  • You also acknowledge that, due to the interconnected nature of our business operations, we (MTRPL and affiliates including any successor entity) may require to share your Personal Information amongst each other, as required, for the purposes mentioned in this Policy, including for marketing and promotional communications from our affiliates.
  • Personal Information held by us may be disclosed, inter alia, to the following third parties for the purposes specified in this Policy or our other policies or as required or permitted under applicable law:
    • We share your Personal Information to complete any transaction or provide any product or service you have requested from third-party service providers/vendors in order to fulfill such transaction. We also share your Personal Information with vendors working on our behalf.
    • We may employ other companies and individuals to perform function(s) on our behalf. The functions include fulfilling orders for products or services, sending e-mail, removing repetitive information from customer lists, providing marketing and advertising assistance, processing payments, and providing customer service.
    • Our other branches or businesses, or our group companies or affiliates;
    • Any other person under a duty of confidentiality to us, which has undertaken to keep such information confidential, including with credit rating agencies, fraud prevention agencies, regulatory or governmental authorities and courts and law enforcement agencies.
  • Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. We may also transfer your Personal Information to a potential buyer, acquirer, transferee, assignee, merger partner or their advisors in connection with a sale, transfer, merger, consolidation or purchase of some or more of our assets or businesses or in exploration of such a transaction, as well as any restructuring or rearrangement of our operations and business.
  • Protecting MTRPL: We may share Personal Information when we believe that disclosure is reasonably necessary (a) to comply with a law, regulation or compulsory legal request; (b) to protect us or an affiliate’s intellectual property rights; (c) to protect us against harm or financial loss; (d) when we believe disclosure is necessary to protect individuals’ vital interests; (e) in connection with an investigation of suspected or actual fraudulent or illegal activity, and/or (f) to ensure safety of the aviation ecosystem, airport premises and/or connected operations. This may include exchanging Personal Information with other companies and organizations for fraud protection, risk management and dispute resolution.
  • Third Parties: We may also share your Personal Information with other third parties where you request or authorize us to do so.
  • We may transfer your Personal Information to recipients in India, where we are headquartered, and other countries. These countries may not have the same level of data protection laws as the country in which you initially provided the information. If we transfer your Personal Information to other countries, we will protect that information as described in this Policy, as disclosed to you at the time of data collection or as described in our program-specific privacy policy.
  • Analytics And Tailored Advertising
    • To better understand your use of our Services, we may use third-party web analytics tools. These tools collect and analyse information provided by you to evaluate your use of the Services, improve our offerings, and promote our Products and Services.

Data Security 

We will use technical and organizational measures to safeguard your Personal Information, including measures to deal with any suspected data breach. We store your Personal Information on secure servers. If you suspect any misuse, loss or unauthorised access to your Personal Information, please let us know immediately by contacting us vide the details mentioned in Clause 15.

Retention of information 

We retain your Personal Information for as long as necessary for the purposes laid out in this Policy, unless a longer period is permitted or necessary under law. Once the purpose is met or the applicable retention period expires, your Personal Information will be deleted or anonymized in accordance with our data retention policies.

However, in compliance with legal and regulatory requirements, certain data may be retained on backup or archival media for limited purposes such as audits, legal obligations, tax or regulatory compliance. This data will be securely handled and stored, and will only be used for these specific lawful purposes. 

Your rights and choices 

  • You may be entitled to the following rights in relation to your Personal Information:
    • Right to Confirmation and Access. You may ask us to confirm what Personal Information we hold about you at any time.
    • Right to Rectification. You have the right to request that we rectify any inaccurate or incomplete Personal Information that we hold about you and/or right to get the Personal Information updated or corrected, including by means of providing a supplementary statement. It is important that the information 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.
    • Right to Withdraw Consent. Where we have obtained your consent to process your Personal Information for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative and strong compelling legal basis to justify our continued processing of your Personal Information for this purpose.
    • Right to erasure. You have the right to request that we “erase” your Personal Information, in certain circumstances.
  • To get in touch with us about these rights, promotional communications or to request to review, update, or delete your Personal Information or to otherwise reach us, please submit a request by e-mailing us at Niraj.kumar-ospree@adani.com. We will respond to your request within 30 days.

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.

Services through third party site/apps 

To the extent you avail our Services through applications or websites of third parties, you acknowledge and agree that we are not responsible for any collection or disclosure of your Personal Information by them. Please note that such applications or websites may have their own privacy policies governing the collection, storage, retention and disclosure of your information that you may be subject to. We recommend that you exercise reasonable diligence, as you would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third-party website or application’s privacy policy.

Changes to this Policy

We reserve the right to change, modify, add or delete portions of this Policy, at our sole discretion, at any time. While we will periodically inform you of any material changes to the Policy, you are responsible to check for updates regularly to make note of any changes. If we make any changes to this Policy, we will change the “Last Updated” date above to reflect the date of the most recent update. 

You agree that your continued use of the Services means that you accept and agree to the changes in the Policy.

Grievance Redressal Officer

In order to address any discrepancies and/or grievances that you may have in relation to this Policy there is a designated “Grievance Redressal Officer”, whose name and contact details are as below:

Name: Niraj Kumar
Address: A Wing Unit Nos. G-A-08-09 & B Wing Unit Nos. G-B-14-15, Ground Floor, Art Guild House, Next to Phoenix Market City, Off L B S Marg, Kamani Junction, Kurla (W), Mumbai – 400070.
Tel: +91 8828839976
Email: Niraj.kumar-ospree@adani.com

Miscellaneous

  • Disclaimer: We cannot ensure that your Personal Information will never be disclosed in ways not described in this Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private. As a Customer of our Services, you understand and agree that you assume all responsibility and risk for your use of the Services, the internet generally, and the information you post or access and for your conduct on and off the premises of our Stores.
  • Governing Law and Jurisdiction: This Policy shall be governed by the laws of India as applicable between residents of India without regard to any principles of conflict of laws. Any and all disputes arising hereunder shall be subject to the exclusive jurisdiction of the courts at Mumbai, Maharashtra.

Consent

  • By consenting to this Policy, you hereby provide your express and explicit consent to the aforesaid collection, transmission, publication, storage, retention, and any other usage of Personal Information (including SPDI) by MTRPL as per this Policy and as may be notified to you, from time to time. In case you do not consent to any of the usage, transmission, processing, and/or publication of your Personal Information as detailed hereinabove, you may opt to not accept this Policy. 
  • In the event of any changes in applicable data protection laws in India, including the implementation of the Digital Personal Data Protection Act, 2023 and/or rules thereunder, you expressly consent to the MTRPL’s continued use, storage, collection and disclosure of your Personal Information. You agree to provide such additional consents and approvals, in the format and manner requested by us. If you choose not to provide such additional consents and approvals, we may be need to modify the terms of our Services or discontinue providing them to you.