Guesto Privacy Policy

What this policy covers?

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:

What information we collect about you
How we use information we collect
How we share information we collect
How we store and secure information we collect
How to access and control your information
How we transfer information we collect internationally
Other important privacy information

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with Guesto (for example, attending Guesto events, both online and offline), unless a different privacy policy is displayed. This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

When we refer to “Guesto,” “we,” “us” in this policy, we are referring to the company Guesto Travtech Pvt. Ltd., which stores and controls the information that is collected when you use Guesto’s products and services including our website located at www.guestoapp.com, or the Guesto mobile applications – Guesto App or web application for tour operators located at https://agents.guestoapp.com made available by Guesto Travtech Pvt. Ltd., an entity established under the laws of India having its registered office at 10, Nimbkar Society, Malabar Hill Road, Mulund Colony (West), Mumbai – 400 080, India. This policy applies to users of our website (“Website” or “Site”) or mobile application (“App”). Users include:

Travelers – who are availing the services of transportation for tours & sightseeing
Tour Operators – who are availing our services of mobile and web application to streamline and organize their operations and enhance and perfect their communication with their clients

Following “Data Controller”, “Data Processor”, “Data Subject”, and “processing” will have the same meaning as in the General Data Protection Regulation.

What information we collect about you?

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.Information you provide to us We collect information about you when you input it into the Services or otherwise provide it directly to us.

Account and Profile Information: Any information which is collected for the use of the Service for which we are the Data Controller will be held by us in accordance with the General Data Protection Regulation. For example we collect information about your contact information to create an account for you, for marketing and invoicing purposes along with any other communication activities.
Content you provide through our products: It is agreed that that for the purposes of the GDPR you are the Data Controller and we are the Data Processor with regards to information about you, or third parties that you may choose to include and which our Services process on your behalf. This is the information our Services do not exercise responsibility for, or control as per the General Data Protection Regulation. The Services include the various functions on your dashboard such as the Itinerary Builder, Voucher Builder,

Admin panel and mobile products you use, where we collect and store content that you post, send, receive and share. Example of such content may include the files and links you upload to the Services such as adding a profile photo, bio, website link, social media links and other details to your profile information to be displayed in our Services. Other examples of content we collect and store include: files you attach to an itinerary, the name of an Itinerary, your welcome message to your prospect client on the Itinerary, or as part of the email we enable you to send out from our Guesto dashboard, custom content you have added to your account, terms and conditions as part of attached documentation that you included in your admin panel and/or onto the itinerary.

Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels: The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, company name, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you register for certain paid Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the itineraries, content accumulated,itineraries viewed, company details added onto your admin panel, the type, size and filenames of attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services, whether you have logged into the Services and so forth. We also collect information about the teams and people you work with.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Cookies and Other Tracking Technologies: Guesto and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.

Information we receive from other sources

We receive information about you from other Service users, from third party services, related companies, and from our business and channel partners.

Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by someone else on an itinerary, or a team member with administrator rights may upload content about you to the admin panel. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as another administrator for a trial or enterprise account.
Guesto Partners: We work with various partners who provide consulting, payment and other services around our products. Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We may receive information from some of these partners, such as contact information, company name, and what country you are in.
Other partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in, and engagement with, our Services and online advertisements.

How we use information we collect

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, we use the username and password you provide in your account to identify you and enable you access to your account. Our Services also include tailored features that personalize your experience, enhance your productivity, and improve your ability to collaborate effectively with others by automatically analyzing the activities of your team to provide search results, activity feeds that are most relevant for you and your team. For example your team member may have have created an itinerary for a particular passenger. You will be able to search itineraries by passenger names, and your team member’s itinerary will appear in your search. We may use your email domain to infer your affiliation with a particular organization or industry to personalize the communication sent to you.
For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of payment dues, to update you on product developments, share knowledge on industry trends, give advice on how to optimize your use of the Services, provide customer support, and send you technical notices, security alerts, and administrative messages.
To market, promote, and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying Guesto ads on other platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you give us permission to do so, we share your information with a Guesto Expert for the purpose of responding to support-related requests.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- - We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  - It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  - You give us consent to do so for a specific purpose; or
  - We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services. In which case please email our Privacy team contact to ask to be removed from our database.

How we share information we collect

We make collaboration tools, and we want them to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.

Sharing with other Service users

When you use the Services, we share certain information about you with other Service users.

For collaboration: You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content. Please be aware that the itineraries you share are sharable by any recipient of the itinerary link you have shared.

Common accounts: If you register or access the Guesto Services using an email address that is common for all users in your organization, certain information about you including your name, contact info, content, and account use will become accessible to all the users of that organization.

Sharing with third parties

We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.

Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.These service providers are otherwise named as “ third party processors” in our Terms of Use, available on our website.
Guesto Partners: We work with third parties who provide consulting and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing, like when you agree to us sharing your information with a Guesto Expert for support-related questions.
Links to Third-Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
Third-Party Widgets: Some of our Services contain widgets and social media features, such as the Twitter “tweet” button. These widgets and features collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.
Guesto uses YouTube’s API Services to provide enhanced functionality within our services. By using our services, you acknowledge and agree that YouTube’s API Services are implemented, and YouTube’s terms of service and Google’s privacy policy apply to you. Furthermore, any data received from the use of YouTube’s API Services will adhere to Google’s Limited Use as referred to in Google API Services User Data Policy.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to:
1. 1. comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements,
  2. enforce our agreements, policies and terms of service,
  3. protect the security or integrity of our products and services,
  4. protect Guesto, our customers or the public from harm or illegal activities, or
  5. respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person

How we store and secure information we collect

Information storage and security

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) that may not be subject to equivalent Data Protection Law. Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

We may transfer your personal information outside the EEA:

In order to store it.
In order to enable us to provide services to you and fulfil our contract with you. This includes delivery of services that you have purchased (for example, if you are registered for the service in a country in the EEA but are using the App to book a service outside the EEA), processing of payment details, and the provision of support services.

where we are legally required to do so.
in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

We may transfer your personal information to the following countries outside the EEA such as India, Singapore, Indonesia, Ireland, the Philippines and the United States of America.

How long we keep information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account information: We retain your account information until you ask us to delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow to make full use of the Services in the future. For example, we continue to store the itineraries you have created should you reactivate your account.
Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as your organization’s account is not deleted. Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

How to access and control your information

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.
Your Choices:
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling

legitimate interests to keep. Where you have asked us to share data with third parties, for example, by enabling an integration, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Access and update your information: For Tour operators, our Services and related documentation available in our Guesto web application give you the ability to access and update certain information about you from within the Service. For example, you can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate membership to an account: You can change/add the user names in the enterprise account but you cannot remove the actual user licence. For such action please contact our support team who will perform the user licence removal for you. Please be aware that deactivating access to an account does not delete your information from that team or enterprise; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.
Delete your information: Our Services and related documentation give you the ability to delete certain information about you from within the Service. For example, you can remove your phone number. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you may continue to receive transactional messages from us regarding our Services. Please note, you may continue to receive generic ads.
Turn off Cookie Controls: Relevant browser-based cookie controls are described in our Cookies & Tracking Notice.
You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To make such a request, please contact us at the information provided in CONTACT US section.

EU Privacy/ Data Protection Rights

EU General Data Protection Regulation (GDPR) has provided the below rights to the EU residents:

Right to information – including contact details to the DPO, the purposes for processing Personal Information and the rights of the individual.
Right to access the Personal Information that are processed
Right to erasure(“Right to be forgotten”)
Right to rectification
Right to restriction of processing
Right to data portability of the Personal Information supplied to Guesto by the EU resident
Right to object (opt-out) to processing (unless Guesto otherwise has compelling legitimate grounds)

EU residents can exercise these rights by raising a request directly at support@guestoapp.com or contact us at the information provided in CONTACT US section.

Other important privacy information

Notice to End Users

Our products are intended for both personal use and use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator/ decision-maker of the Services and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.

If you are a user, your administrator asserts control over your account or use of the Services, you may not be able to withdraw membership or change the email address associated with your account without administrator approval.

Please contact your organization or refer to your administrator’s organizational policies for more information.

Our policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

Contact Us

Your information is controlled by Guesto Travtech Pvt Ltd. If you have questions or concerns about how your information is handled, please direct your inquiry to Guesto and as set forth below;

Address: 10, Nimbkar Society, Malabar Hill Road, Mulund Colony (west). Mumbai 400080
E-Mail: support@guestoapp.com