We, Treebo Hospitality Ventures Private Limited (formerly known as Ruptub Solutions Private Limited) , (hereinafter, "Treebo Hotels", "us", "we" or "our") are involved in the business of inter alia, facilitating your enquiries and bookings of our branded budget accommodation properties through our Website (as defined below) and App ( as defined below) (collectively,"Platform). We are fully committed to respecting your privacy and shall ensure that your personal information is processed in accordance with the Applicable Data Protection Law (as defined below). This privacy policy (hereinafter “Privacy Policy”) is an electronic record in terms of the Applicable Data Protection Law; and sets out our practices Appin relation to processing of information, including the type of information that is collected, how the information is collected, how the information is used and with whom it is shared. Reference to "you" or "your" in this Privacy Policy refers to the users of our Platform, whether or not you access the services offered by us ("Services") or consummate a transaction on the Platform.

By using our Platform and/or our Services and/or by otherwise giving us your information, you agree to the terms of this Privacy Policy. You also expressly consent to our use and disclosure of your Personal Information (as defined below) in the manner prescribed under this Privacy Policy and further signify your agreement to this Privacy Policy, the Stay Policy (Available here) and the Terms of Use (Available here). If you do not agree to this Privacy Policy, do not subscribe to the Services, do not access or use the Platform and do not give us any of your information.

1. DEFINITIONS

   • "App" shall mean the mobile software application in the name of 'Treebo Hotels' which can be downloaded from a public forum and installed and operated on a mobile device or other similar device.

   • Applicable Data Protection Law means, once fully in effect, the Digital Personal Data Protection Act, 2023; the Information Technology Act 2000 as amended by the Information Technology (Amendment) Act 2008; and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; and any other laws and regulations of the Republic of India applicable to the processing of Personal Data (as defined below).

   • "Force Majeure Event" shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action or any kind, riots, insurrection, war, acts of government, computer hacking, internet outage, network issues, computer crash, any issues with third-party software/ applications/ tools, or other such technical issues, unauthorized access to your mobile or storage device, crashes, breach of security and/ or encryption.

   • "Personal Information" or "Personal Data" refers to any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with us is capable of identifying such person.

   • "You" or “Data Principal” means the individual whose digital Personal Data is being processed or to whom the Personal Data relates and where such individual is:

   • a child, represented by the parents or lawful guardian of such a child;

   • a person with a disability, represented by his or her lawful guardian, acting on his or her behalf.

   • "Data Fiduciary" refers to Treebo Hotels when it determines the purpose and means of processing of Personal Data.

   • "DPO" or Data Protection Officer appointed by Treebo Hotels.

   • "Third Party" refers to any person or entity other than you or us.

   • "Website" shall mean www.treebo.com.

2. INFORMATION COLLECTION

   • Personal Information/ Personal Data

     • In order to provide you a safe, efficient, smooth and customized experience and in order to take advantage of certain features available on the Platform including, but not limited to, accessing or uploading reviews or taking part in surveys, you will be asked to complete an online registration form which will provide us with your Personal Information such as name, address, phone number and email address. In the event you register with us, you will also be asked to choose a user identity and password in order to identify yourself during future uses of the Platform.
     • You can also register on the Platform by logging into online accounts that you may have with Third Party service providers ("SNS") (e.g. Facebook); (each such account, a "Third Party Account"), in the manner described below. As part of the functionality of the Platform, you may link your account with Third Party Accounts, by either: (i) providing your Third Party Account login information to us through the Platform; or (ii) allowing us to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to us and/or grant us access to your Third Party Account (including, but not limited to, for use for the purposes described herein), without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating us to pay any fees or making us subject to any usage limitations imposed by the applicable SNS. If you decide to register by logging into a Third Party Account, we will obtain from your public profile the Personal Information you have provided to the applicable SNS (such as your name, email address, profile picture, names of SNS friends, names of SNS groups to which you belong, other information you make publicly available via the applicable SNS and/or other information you authorize us to access by authorizing the SNS to provide such information to us) from your Third Party Accounts and use that information to create your account and profile page and you will become a member on the Platform. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the public profile of your Third Party Account, we will access, make available and store (if applicable and as permitted by the SNS and authorized by you) the information in the public profile of your Third Party Account so that it is available on and through your account on the Platform. If there is information about your "friends" or people with whom you are associated in your Third Party Account, the information we obtain about those "friends" or people with whom you are associated, may also depend on the privacy settings such people have with the applicable SNS.
     • We also collect certain Sensitive Personal Data or Information to (i) facilitate your payment towards the booking of the desired hotel; and (ii) ensure that our hotels match the specifications provided by you at the time of booking. Further, we may collect certain other information that may not be categorized as Personal Information as part of the registration, administration and personalization of your account profile.
     • While we recommend that you register yourself with us to maximize your experience on the Platform, this feature is optional and you may opt out of registering on the Website and continue to use the Platform as a guest. However, if you choose to register on the Platform, you will have to provide certain Personal Information that is necessary for us to deliver our Services.
     • In addition to the collection of Personal Information and Sensitive Personal Data or Information for facilitating, we also collect information from representatives of Hotels who wish to register with us under the "Join our Network" platform. During the stage of registration, the "Join our Network" platform collects certain information including without limitation the name of the hotel, address of the hotel, phone number of the hotel, state and city in India in which the hotel is located, number of rooms at the hotel, average room rate of the hotel, current occupancy of the hotel in percentage, name of the contact person at the hotel, personal phone number of the contact person at the hotel and such other information as may be sought by us (such information, "Hotel Information"). We may associate your Hotel Information with any Personal Information you provide, and we treat the combined information as Personal Information.

   • Non-Personal Information

     • You agree that we may collect and use technical data and related information, including but not limited to, technical information such as health status and SIM card related data about the mobile device, the system and the App located on the mobile device (collectively, "Technical Information") that is gathered periodically to inter alia, facilitate the provision of Services and improve our Platform..
     • When you use the App on your mobile device, we may automatically collect some or all of the following information (collectively, "Mobile Device Information"), including without limitation:
       • The phone number or other unique device identifier assigned to your device - such as the International Mobile Equipment Identity or the Mobile Equipment ID Number;
       • The IP address of your device;
       • The manufacturer and model of your device;
       • The type of Internet browsers you are using;
       • Your geographic location;
       • The call record of the calls between you and our customer support centre; ("Treebo Centre");
       • Information which allows us to personalize the Services and the content available through the Platform.
     • We may use the Mobile Device Information for the following purposes:
       • To identify your location when the Platform is activated;
       • To prevent, discover and investigate violations of this Privacy Policy or the Terms and Conditions, or to investigate fraud or other matters; and
       • To provide uninterrupted Services to you

       We may associate your Technical Information and Mobile Device Information with any Personal Information you provide, and we treat the combined information as Personal Information.

     • In addition to the Technical Information and the Mobile Device Information, we also collect your booking history which is updated as and when you make a booking through the Platform. When you use the Platform, the information provided by you while booking the desired hotel is automatically transferred to us in order to enable us to confirm the booking.
     • In order to better facilitate your use of the Platform, you can also sync your email and contacts with the Platform to locate friends on the Platform, invite friends to join the Platform or to share your details with such friends.
     • If you choose to enable GPS on your device, we will have access to your location information and if you make a hotel booking through the Platform, the booking confirmation will also include your location details.
     • In order to provide uninterrupted Services to you, we also collect, and store certain information in relation to the customer support requests placed by you including, but not limited to, the subject of the request, the date and time of the request, the actions taken by the customer support agent and any follow-up or further action in relation to such request (collectively, "Audit Information").
     • You may choose to provide us with hotel feedback in relation to your stay at the hotel booked through the Platform, including, but not limited to, the experience in relation to the hotel and the Services provided to you in relation to such booking (also, "Hotel Information"). You agree that we may use such Hotel Information in an anonymized manner for data analytics, and other internal purposes and you hereby expressly consent to such usage.

   • Information collected by the Third Party Service Providers

     • In addition to the Personal Information and other information that is collected directly by us, you may provide certain information, including Personal Information to our Third Party service providers who collect such information on our behalf to help us provide Services. For example, you may provide certain information when you access the services provided by such Third Party service providers such as payment gateways, surveys and reviews, online polls, etc. The collection, usage, and disclosure of such information are subject to the respective privacy policies of such Third Party service providers. We are not responsible for the privacy practices of such Third Parties and therefore, you should read the privacy policies of such Third Party service providers prior to disclosing any information. We shall not be liable for any actions of Third Party service providers in relation to your information and Personal Information.

3. COOKIES

   • In addition to the Personal Information and other information collected by us, we also collect certain information in relation to your activities on the Platform through devices such as cookies, web beacons and other tracking devices to collect data in relation to your usage of the Platform and our other websites/ apps (collectively, "Cookies"). Cookies are small data files that are stored on the hard drive of your computer/ device. We use Cookies to recognize you if you visit multiple pages in our Platform during the same session, so that we do not need to ask you for your password on each page. Once you log out or close your browser, these session cookies expire. The Cookies will not provide us with Personal Information. We and our service providers may use the information provided by the Cookies to analyze trends, administer the Platform, track user movements and gather demographic information. You may control the use of Cookies at the individual browser level. If you reject Cookies, you may still use our Platform, but your ability to use some features or areas of our Platform may be limited.

4. USE OF YOUR INFORMATION

   • We use your information, including Personal Information, provided by you to ensure that we provide you with a better and more personalized experience on the Platform and for the purposes that are permissible under applicable laws. We may use your information, including Personal Information for the following purposes:
     • To provide you with the Services;
     • To facilitate better access to the Platform;
     • To help you make hotel bookings;
     • To address your queries and resolve any issues raised by you in relation to the Services;
     • To provide information in relation to the Services;
     • To send you information about our new services or other promotions that we think may be of interest to you;
     • To send you information about third parties who we think may be of interest to you;
     • To customize your experience on the Platform;
     • If you use the Platform to send information to another person, we may store your Personal Information, and the Personal Information of any recipient;
     • To prevent, discover and investigate violations of this Privacy Policy or the Terms of Use, and/ or to investigate fraud or other matters;
     • To meet legal and regulatory requirements;
     • For internal record keeping purposes;
     • To conduct data analysis in order to improve the Services provided to you;.
     • For the purpose of our legitimate business activities;
     • For internal operational purposes;
     • To provide customer services.

5. SHARING OF INFORMATION

   • We do not share your information, including Personal Information, except in the following limited circumstances:
     • With Third Parties who provide services to us, including, without limitation, those that help us provide the Services such as the website hosting services, the payment gateway services, and other Third Party service providers, subject to confidentiality obligations consistent with this Privacy Policy;
     • With law enforcement authorities or other governmental authorities to comply with the law or to protect our rights or the rights of others;
     • To enforce our terms and conditions;
     • For any other purposes that are permissible under applicable laws;.
     • To protect ourselves against third-party claims.
   • Specifically, please note that we do not and will not trade or sell your Personal Information in any manner.

6. LINKS TO/ FROM THIRD-PARTY WEBSITES

   • The Platform may contain links to third-party websites, products, and services. Information collected by third parties (which may include without limitation information such as contact details), is governed by the privacy practices undertaken by such third parties. We encourage you to learn about the privacy practices of those third parties. We expressly assert that we cannot be responsible for these practices.
   • We may have presence on social networking websites including but not limited to LinkedIn, Facebook, Twitter, Instagram, YouTube and blogs which are promotional and business initiatives to attract, engage and connect to a larger group of people. The domain links contained therein may either direct you to our Platform or request your participation by way of feedback, suggestions, etc. We, in this regard, fully disclaim any liability(ies) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking websites or blogs, by any third party whether or not known to us.

7. SECURITY OF YOUR INFORMATION

   • We take appropriate security measures to protect your information against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage, and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store your Personal Information.
   • Notwithstanding the above, the internet is not a 100% secure environment and we cannot ensure or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

8. RETENTION OF YOUR INFORMATION

   • We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
   • Non-personal information will be retained indefinitely, and we may however continue to use, share and/ or disclose your Non-personal information in furtherance of our policies.

9. YOUR RIGHTS

   • As a Data Principal under, you have the right to:
     • Access your Personal data that is being processed by us;
     • Request for correction, completion or updation of your Personal Data;
     • Withdraw consent for the processing of your Personal Data;
     • Request the deletion or erasure of your Personal Data in certain circumstances;
     • Request for restriction on the processing of your Personal Data in certain circumstances;
     • Request for data portability to another data fiduciary;
     • Lodge a complaint with the Data Protection Officer (DPO): Shilpi Ojha(Email address:shilpi.o@treebo.com) - if you believe that your data is not being processed in accordance with this Privacy Policy or Applicable Data Protection Laws.

10. FORCE MAJEURE

    We will not be liable for any failure to perform or any delays in performance, and we will not be deemed to be in breach or default of our obligations set forth in this Privacy Policy, if, to the extent and for so long as, such failure or delay is due to any causes that are beyond our reasonable control or Force Majeure Events.

11. GRIEVANCES

    • In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected Data Principals, which might include you.
    • In accordance with the legal requirements, the name and contact details of the DPO/ Grievance Officer who can be contacted with respect to any complaints or concerns including those pertaining to breach of this Privacy Policy and other polices are published as under: Data Privacy Officer/ Grievance Officer Name: Shilpi Ojha, Email address: shilpi.o@treebo.com

12. GOVERNING LAW

    • We are incorporated in, and based out of the Republic of India, and we are duty bound to abide by Indian laws. We may not have complied with some privacy laws of other countries and further represent to be unaware of such other legal requirements.
    • Further, any disputes regarding this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Bangalore, India.

13. QUESTIONS AND CONTACT INFORMATION

    • If you would like to access, correct, amend or delete any of your Information shared with us, please register a complaint, or if you want more Information about this Privacy Policy, please contact us at ge@treebohotels.com. We shall respond to and address all reasonable concerns or inquiries in a reasonable amount of time.

14. UPDATES TO THE PRIVACY POLICY

    Subject to applicable law, we reserve the right to modify, amend, suspend, terminate or replace this Privacy Policy from time to time within our sole discretion. We will post any changes made to the Privacy Policy on the Platform without prior notice to you. Such changes will take effect immediately upon their posting on the Platform. If we make material changes to this Privacy Policy, we may notify you that it has been updated to enable you to review the materially changed Privacy Policy. We encourage you to review the Privacy Policy frequently. By your continued use of the Platform and availing of our Services, you consent to the terms of the revised/ updated Privacy Policy.