PRIVACY POLICY

Roamie Mobility LLP (“Roamie”, “we”, “our”, “us”) values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share and protect personal data when you access or use our website, mobile application, and related services (collectively, the “Platform”).

This Privacy Policy is issued in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), IT Act, 2000 and applicable laws in India. It forms an integral part of the Terms & Conditions and must be read together with them.

This Privacy Policy is also intended to comply with the Consumer Protection Act, 2019 and the Consumer Protection (E-Commerce) Rules, 2020.

Personal data collected through the Platform is processed in a fair and transparent manner and is not used to engage in unfair trade practices, manipulate consumer choices, distort pricing, or otherwise prejudice the rights of users as consumers. Personal data is used solely for lawful purposes connected with the services offered on the Platform and in accordance with applicable law.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

APPLICABILITY

1.This Privacy Policy applies to:

  • users who create an account on the Platform;
  • users who make bookings as guests without creating an account; and
  • parents or lawful guardians who make bookings for the benefit of a child.

This Policy applies only to digital personal data processed through the Platform.

PERSONAL DATA WE COLLECT

Depending on your interaction with the Platform, we may collect the following categories of personal data:

2.1 Identity and Contact Information

  • name
  • email address
  • mobile number

 

2.2 Booking and Transaction Information

  • booking details such as travel date, route, timing, seat and passenger information;
  • ticket and itinerary details;
  • payment transaction identifiers (we do not store complete debit/credit card numbers).

 

2.3 Communication Information

  • communications with customer support;
  • booking confirmations, updates and service-related notifications.

 

2.4 Technical and Usage Information

  • IP address;
  • device type, browser or application version;
  • basic usage and log information for security and fraud prevention.

 

2.5 Where required under applicable law, certain personal data such as passwords and financial information used for processing payments may constitute “Sensitive Personal Data or Information” as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Such information is collected and processed only for lawful purposes connected with the services offered on the Platform and is subject to enhanced security practices in accordance with applicable law.

We collect only such personal data as is necessary for the purposes described in this Privacy Policy.

HOW WE COLLECT PERSONAL DATA

3.We collect personal data:

  • directly from you when you register, make a booking, or contact customer support;
  • when you provide passenger or booking-related information;
  • automatically through technical means for security, fraud prevention and system integrity;
  • through service providers involved in processing bookings or payments.

 

PURPOSES OF PROCESSING

We process personal data only for specified, explicit and lawful purposes, including:

4.1 Registered Users

  • creating, maintaining and managing user accounts;
  • facilitating bookings of services offered through the Platform;
  • processing payments and completing transactions;
  • issuing tickets, confirmations, itineraries and service-related communications;
  • providing customer support, refunds, cancellations and dispute resolution;
  • preventing fraud and ensuring platform security;
  • complying with legal, regulatory, accounting and audit requirements.

 

4.2 Guest Users

  • completing the specific booking initiated by the guest user;
  • processing payments and transaction settlements;
  • issuing booking confirmations and updates;
  • handling refunds, disputes or booking-related queries;
  • complying with applicable laws and regulatory requirements.

Personal data collected from guest users is not used for unrelated, secondary or marketing purposes unless separate, explicit consent is obtained.

CONSENT

5.1 Personal data is primarily processed on the basis of free, specific, informed and unambiguous consent, obtained through a clear affirmative action at the time of:

  • account registration; or
  • guest booking confirmation.

Consent is tied to acceptance of the Terms & Conditions and this Privacy Policy and is limited to the purposes stated herein.

For the purposes of the Information Technology Act, 2000 and the rules made thereunder, such consent shall be deemed to be provided electronically through the user’s affirmative action on the Platform.

5.2 Where you voluntarily provide personal data for a clearly specified purpose and do not indicate non-consent, such data may be processed only to the extent strictly necessary to fulfil that purpose.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

BOOKINGS MADE FOR BENEFIT OF A CHILD

6.The Platform is intended for use by individuals who have completed eighteen (18) years of age.

Where a parent or lawful guardian makes a booking for the benefit of a child, the parent or lawful guardian acts as the data principal and provides the child’s personal data in a representative capacity. Such data is processed solely for completing the booking and complying with applicable law.

SHARING OF PERSONAL DATA

7. We may share personal data only to the extent necessary with:

  • transport operators or service providers for fulfilment of bookings;
  • payment gateways and financial institutions for transaction processing;
  • government or regulatory authorities where required by law;
  • auditors, consultants or advisors for compliance and legal purposes.

We do not sell personal data or share it for unrelated commercial purposes. Any disclosure of personal data to third parties shall be made only with the consent of the user, where such consent is required, or where such disclosure is necessary for performance of a lawful contract, or where such disclosure is required under applicable law.

DATA RETENTION

8. Personal data is retained only for as long as:

  • necessary to fulfil the purposes for which it was collected;

         required under applicable laws (including tax, accounting or audit obligations); or

  • necessary for dispute resolution, fraud prevention or enforcement of rights.

USER RIGHTS

9. In accordance with the DPDP Act, you have the right to:

  • access information relating to processing of your personal data;
  • request correction, completion or updating of personal data;
  • request erasure of personal data where applicable;
  • withdraw consent for processing; and
  • seek grievance redressal.

         Requests may be made through the contact details provided below.

WITHDRAWAL OF CONSENT

10. You may withdraw consent through available platform mechanisms or by contacting us.

Withdrawal of consent does not affect the legality of processing carried out prior to such withdrawal and may result in discontinuation of services where processing is necessary for transaction completion or legal compliance.

We implement reasonable security practices and procedures as required under the Information Technology Act, 2000 and the rules made thereunder, including administrative, technical and physical safeguards, to protect personal data against unauthorised access, loss, misuse or alteration.

Such practices are designed to be consistent with generally accepted information security standards and may be updated from time to time in accordance with law and technological developments. However, no digital system is entirely secure, and absolute security cannot be guaranteed.

GRIEVANCE REDRESSAL

11. If you have any questions, concerns or grievances relating to processing of personal data, you may contact:

Grievance Officer

Roamie Mobility LLP
Email: [ ____ ]