This Privacy Policy describes how Finley Holidays (hereinafter referred to as "Finley Holidays," "we," "us," or "our") collects, uses, and discloses your information when you use our website finleyholidays.com and services (the "Service"). Our Service is primarily designed for Business-to-Business (B2B) use, specifically facilitating the purchase and management of airline credits for travel agencies and corporate entities.

We are committed to protecting your privacy in compliance with applicable Indian laws, particularly the **Digital Personal Data Protection Act, 2023 (DPDP Act)**.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Definitions

• Account: A unique account created for You to access our Service.
• Data Principal: The individual to whom the personal data relates (e.g., you, the individual using our Service on behalf of a travel agency).
• Personal Data (or Personal Information): Any information that relates to a Data Principal and by which the Data Principal can be identified, as defined under the DPDP Act, 2023.
• Data Fiduciary: The Company, which determines the purpose and means of processing personal data.
• Service: The website and services provided by Finley Holidays.
• Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).

2. Principles of Data Processing (as per DPDP Act, 2023)

We adhere to the following principles when processing your personal data:

• Lawful, Fair, and Transparent Processing: We process personal data in a manner that is lawful, fair, and transparent to the Data Principal.
• Purpose Limitation: We collect and process personal data for specific, clear, and lawful purposes.
• Data Minimisation: We collect only personal data that is necessary for the specified purposes.
• Accuracy: We take reasonable steps to ensure the accuracy and completeness of personal data.
• Storage Limitation: We retain personal data only for as long as necessary to fulfil the purposes for which it was collected.
• Integrity and Confidentiality: We protect personal data from unauthorised access, alteration, disclosure, or destruction.

3. Information We Collect

We collect several different types of information for various purposes to provide and improve our Service.

3.1. Personal Data:

When you register for an Account, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you or your representatives. This may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Company Name and Business Registration details (e.g., GSTIN, PAN)
• Billing Address
• Bank account details or other payment information.
• Any other information you choose to provide that is necessary for the use of our B2B services.

3.2. Usage Data:

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device. This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

4. How We Use Your Information

Finley Holidays uses the collected data for various purposes:

• To provide and maintain our Service.
• To manage your Account.
• For the performance of a contract.
• To contact you.
• To provide you with news, special offers and general information about other goods, services and events.
• To manage your requests.
• For business transfers.
• For other purposes: such as data analysis, identifying usage trends, and improving our Service.

5. Disclosure of Your Information

We may share your Personal Data in the following situations:

• With Service Providers: To monitor and analyse the use of our Service, or to process payments.
• For Business Transfers: In connection with or during negotiations of any merger, sale of Company assets, or acquisition.
• With Affiliates: We may share your information with our affiliates, who are required to honor this Privacy Policy.
• With Business Partners: To offer you certain products, services, or promotions.
• With Your Consent: We may disclose your personal data for any other purpose with your explicit consent.

6. Retention of Your Personal Data

Finley Holidays will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. Usage Data is generally retained for a shorter period.

7. Transfer of Your Personal Data

Your information may be processed at our operating offices and in any other places where the parties involved in the processing are located. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this policy.

8. Your Rights as a Data Principal (as per DPDP Act, 2023)

As a Data Principal, you have specific rights concerning your personal data:

• Right to Access: The right to request access to your personal data.
• Right to Correction/Grievance Redressal: The right to request correction of inaccurate data and to seek redressal for any issues.
• Right to Erasure (Right to be Forgotten): The right to request the erasure of your personal data under certain circumstances.
• Right to Nominate: The right to nominate another individual to exercise your rights in the event of your death or incapacity.

To exercise any of these rights, please contact us using the details provided below.

9. Links to Other Websites

Our Service may contain links to other websites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes are effective when they are posted on this page.

11. Grievance Redressal Mechanism & Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact our Grievance Officer:

• Grievance Officer Name: [To be filled by The Company - e.g., Head of Compliance / Data Protection Officer]
• Email: [To be filled by The Company - dedicated privacy/grievance email, e.g., privacy@finleyholidays.com]
• Address: [To be filled by The Company - e.g., Delhi Address]