PRIVACY POLICY

Last updated on: 02 February 2023.

Technogro Analytics LLP (operating under the brand name “Solution Theory ” or as appropriate in this context, “we”, “us”, “LLP” or “our”) are here to provide you with tools and services designed to help the hospitality industry and the corporate travel sector with the intervention of our products that simplify, enhance, and support various operations in these industries. (“Services”). The Services are including but not limited to approving/rejecting travel booking requests from corporate employees, facilitating folio uploads by corporate employees, trip expense management including approve/reject out-of policy booking requests from corporate employees, browse hotels, facilitating online room, group, and banquet bookings among hotels and corporates, check-in, check out, submit and view folios, create/modify your profile, role-wise access management, and create and manage reservations or request products and services such as concierge, valet, housekeeping or in-room dining and manage requests raised from guests at hotels, escalation mechanism for service request raised, and provide reports and analytics for users. 

We have provided this Privacy Policy (“Policy”) as an explanation of the information we collect, how we process and use it, and how the use of this information can benefit your experience on the websites, platforms, products and services we provide. It applies to the use of our website www.solutiontheory.in, including but not limited to our web platform, mobile platform, or applications or products, CorpCRS and Wytty Assist (collectively terms as “Platform”). The Platform is made available to our users (as defined below) on a limited license basis via the internet. 

Before you start, we’d like to ensure you that we respect the privacy of all our customers and business partners (referred to as “you” or “user”), and treat personal information (as defined below) provided by you as confidential. We recommend that you read our Terms of Use available on our website which also govern your use of the Service.

When you use the Service to access a reservation with, the website of, or in connection with your stay at any of the registered hotels, you will be subject to the terms and conditions and privacy policy of the applicable website you are visiting or otherwise accessing. Our Policy does not cover the privacy practices of these parties that we do not own or control.

This Policy is published in compliance with, inter alia, applicable provisions of the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “Rules”) and Information Technology (Intermediaries Guidelines) Rules, 2011.

Please note that the LLP is incorporated in India and operates its business in India and therefore we would process and store all information gathered on the Platform in accordance with the applicable Indian laws. In the event that you are located out of India, you authorize us to process your personal information in the light of providing Services to you. Kindly note that the data protection laws in India may vary from the relevant laws of your country. However, we will take appropriate steps to ensure your privacy continues to be protected..

APPLICABILITY OF THIS POLICY:

A.  This Policy applies to all the users of our Services provided on our Platform. Depending on the usage of the Services, the personal information that is collected from the users will vary.

• This Policy applies to all the users of the Platform. For the purpose of this Policy, the term “Users” shall mean Subscribers (as defined below), authorized users of the Subscribers, and visitors to the Platform. We can broadly classify our Users into four different categories:
• The subscriber to any of the tools/ software or Services belonging to us and made available to the user through our Platform. The subscribers are the corporate entities, hotels or any such authorized user of such corporate entities and hotels that are registered on our Platform to use the Services provided by us. (“Subscribers”).
• The Subscribers are thereby permitted to identify authorized users who would have an account through the subscription availed by the Subscriber on the Platform and avail the Services.
• Visitors to the Platform can be individuals who are simply browsing the Platform but who do not use our Platform. Visitors can be Subscribers who visit the Platform to seek additional information about our Services.

B.  It is hereby clarified that, though the Platform and the Services are owned, designed, developed and made available via the internet by the LLP, the Subscribers have procured the limited license of the Platform and the said Subscribers make available the Services to their authorized users, who are their employees/clients, subject to all the terms and conditions imposed by the LLP, including this Policy and the Terms of Use. In light thereof, it is the sole responsibility of the Subscriber to, (a) convey requisite/relevant information to the authorized users and vice versa, as may be required hereunder, (b) ensure completion of any compliances/obligations required to be fulfilled by the user hereunder, (c) ensure that back to back documentations are signed between the Subscribers and their respective user, to ensure enforceability of these provisions, (d) comply with all applicable laws and regulations in the jurisdiction where the users access the Services; (e) to the extent that the data contains personal data, Subscribers have obtained the necessary consents from their respective users, in order for the us to store, process, share, transfer or permit access to this data for the provisioning of the Services, in accordance with applicable privacy and data protection laws, and (f) accept, entertain, resolve and remedy any/all claims, complaints, responsibilities or liabilities that may arise between the Subscriber and their user and that the LLP hereby disclaims any/all such forgoing claims.

COLLECTION AND USE OF PERSONAL DATA:

In order for us to operate effectively and provide you with the best experiences of our Services, we may request and collect information about you, whether as a Subscriber, hotel guests, Platform visitors or you contact us for any other purposes, that includes personal information that can identify you as an individual. Such information includes:

• Hotel Information, such as registered address; branch office address; phone number; official email address; rooms, banquet and F&B outlet details; Room Tariffs; Group Tariffs and Banquet Tariffs; Cancellation Policies, Terms and Conditions; Room and Banquet Inventory; F&B menu; banquet menu; hotel departments and hierarchy details; list and cost of in-house services provided; social media and website handles; staff details; photo; and logos;
• Corporate Information such as registered address, branch office address, phone number, official email address, logos, billing details, negotiated tariffs and terms with hotels, travel policy, departments and hierarchy detail, travel expenses and invoices;
• List of existing hotel partners of corporates including hotel name, hotel address, and details of key contact person at hotel;
• List of existing corporate partner of hotels including corporate name, corporate
  address, and details of key contact person at corporate;
• Contact information, such as full name, email address, telephone or mobile
  number and address ;
• Username, password, profile picture/image and other security-related information used by you in relation to our Services;
• Professional or corporate details including Corporate Employee ID;
• Reservation information including but not limited to confirmation number, room, arrival date & time and departure date & time, terms and conditions of stay issued by hotel, cancellation policy of hotel;

• Information pertaining to any other traveler(s) for whom you make a booking through your registered account. In such a case, you must confirm and represent that each of the other traveler(s) for whom a booking has been made, has agreed to have the information shared by you disclosed to us and further be shared by us with the concerned service provider(s).

• Demographic information such as gender, PIN code, date of birth and details about your personal preference;
• Payment information such as credit card number, expiration date, and credit card security code, where needed to complete a transaction, GSTIN, PAN, Bank Account Details; and
• Requests and other correspondence you send to us.

Service Usage Information. As you use the Service, we collect information about how you use and interact with the Service (“Service Usage Information”). Such information includes:

a. Log files: when you use the Services, our servers automatically record information in server log files. These log files may include information such as your web request, IP address, MAC address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies and other such information.

b. Location information: we collect and process general information about the location of the device from which you are accessing the Services (e.g., approximate geographic location inferred from an IP address).

c. Device Information: we collect data from the device you use to access our Services, such as your IP address, MAC address operating system, browser details and time of visit. 

d. Other Information. You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms or email (e.g., support forms, sales forms, user research participation forms); information you provide in connection with contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”).

From the aforementioned information that is collected of you the same may constitute ‘Personal Information’ or ‘Sensitive Personal Data or Information’ under the Rules.

“Personal Information” is defined under the Rules to mean any information that relates to a natural 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 such person.

 The Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:

• passwords;
• financial information such as bank accounts, credit and debit card details 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 clauses as provided to body corporate for providing service;
• information received by body corporate under lawful contract or otherwise.

It is however brought to your attention that any information that is freely available or accessible in the public domain shall not be regarded as Sensitive Personal Data or Information for the purposes of these Rules.

USAGE:

A.  We process or use the information that is collected from the user in accordance with its business operations and in providing business services (the Business and Operations Services). Certain Data shared with us is based on a contractual agreement for Business and Operations. We may use the collected Personal Information and other information as provided by you, for the following reasons, including to:

• Deliver our Services to you: such as completing your reservations, sending you reservation confirmations, tracking and providing in-house services, escalation management, role management, communicating within the organisation, providing reports and analytics, track user operations on our software, fulfilling a request for information, customizing our Services to your preferences, earning and redeeming rewards, keeping proper records of your transactions with us;
• Communicate and provide marketing and promotional content to you – such as sending you information and updates on our products and Services and other products and services that we think may be of interests to you, including latest promotions, competitions, joint- and cross- promotions with our business partners, response to enquiries, to send you important information regarding our Platform, changes to our terms, conditions and policies
• Develop and improve our Services to you – such as performing market research, analytics and/or profiling, developing new products and services, improve the effectiveness of our website, your hotel experience, our various types of communications, advertising campaigns, and promotional activities;
• Work and cooperate with third party parties to deliver our products and services to you – such as hotels, travel agents, group travel organization, banquet travel organisation, or anyone involved in the process of making your travel arrangements, credit card companies, airline operators and third party loyalty programs;
• provide you with details about any policy adjustments, improvements and/or amendments to our policy, terms and conditions;
• Meet applicable legal and regulatory requirements
• Use it in other ways as required or permitted by law or with your consent.

B. Use of Demographic / Profile Data / Your Information

• We use Personal Information to provide the Services you request. To the extent we use your Personal Information to market to you, we will provide you the ability to opt-out of such uses. We use your Personal Information to resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our Services, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; and as otherwise described to you at the time of collection.
• In our efforts to continually improve our product and Service offerings, we collect and analyze demographic and profile data about our users’ activity on our Platform.
• We identify and use your IP address to help diagnose problems with our server, and to administer our Services. Your IP address is also used to help identify you and to gather broad demographic information.
• We may occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information. We use this data to tailor your experience at our Services, providing you with content that we think you might be interested in and to display content according to your preferences.

C. Tracking Technologies Used:

We may automatically collect information through tracking technologies. We may use tracking technologies when you visit or use our platform, to collect information about your browsing behavior. Type of information that we may collect include: 

• Click path data: The outcome of a visit to our Platform may result in data being transmitted from your computer to our server. Such data may be immediately processed and maintained by us. In particular, such details can contain the following:
  • Date and time of the visit to the Platform
  • IP address
  • Pages visited on our Platform
  • Clicks on our Platform
  • Browser information
•  Cookies: We use cookies, where a tiny data file is sent to your browser to store and display statistical details about you while you visit our Platform. The cookie is used for monitoring details such as the number of users and their consumption level, user profile and favored Platform. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Platform and you may be required to re-enter your password more frequently during a session. We may use third party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags to measure advertising effectiveness. We do not control the use of cookies by third parties.
• Web beacons: Online beacons contain icons that are not evident to the consumer. Tracking connections and/or related technology consist of a few lines of  computer programming and can be implemented on our Platform. They are mainly used for statistical research purposes in combination with cookies. The system will also be used to detect traffic trends on our Platform.
• Analytics: Web analytics is the concept used for the practice of capturing and analyzing the actions of visitors to Platform. It involves the study of user trends in
  order, for example, to assess the number of clicks to other sections of the website or to figure out what content and resources our users are more interested in. For such purposes, we use, in particular, the click-stream data and other techniques listed above.

DISCLOSURE OF THE INFORMATION WE COLLECT:

A.   Publicly shared information: Any information that you voluntarily choose to share in a public area of our Platform (e.g., by posting a comment to a blog post or leaving a review) will be available to anyone who has access to that content.

B.  We may disclose your information to the following recipients for the purpose of managing, operating, administering our business and for legal purposes:

• To our other group entities for security purposes;
• To our other group entities for the purpose of evaluating our products and Services;
• Our business partners and third parties involved in the delivery of the services that you request;
• To financial institutions for the purpose of payments and transactions related to the provision of our products and services provided by our vendors/service providers and consultants;
• For our service providers who have been retained to provide services on our behalf or on behalf of the organization including i) Service providers offering IT and outsourcing facilities such as data collection, electronic mail services and delivery of IT administration processes; ii) Professional, financial and legal advisors, tax advisors, auditors, insurers; iii) Vendors, service suppliers and contractors who have been contracted to help finance, run, administer and maintain our activities and business processes or to offer services that support the distribution of our goods and services;
• We and our affiliates will share / sell some or all of your personal and other information with another business entity should we (or our assets) plan to merge with,
  or be acquired by that business entity, or reorganization, amalgamation, restructuring of business. Should such a transaction occur, that another business entity (or the new combined entity) will be required to follow this Policy.
• When we hire companies to help us market our Platform and Services and provide you with information and offers related to our Services, including displaying ads to you across the internet.

C.  Law Enforcement, Legal Process and Compliance: We may disclose information about you (1) if we are required or permitted to do so by applicable law or legal process, (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.

YOUR CONSENT:

By using the Platform and/ or by providing your information, you consent to the collection, use and processing of the information you disclose on the Platform in
accordance with this Policy, including but not limited to your consent for sharing your information as per the terms of this Policy.

Kindly note this Platform is not intended for children and we do not collect data relating to children.

OPTING OUT AND UNSUBSCRIBE:

If you no longer prefer to receive our promotional emails or newsletter, please follow the instructions for unsubscribing/opting-out as indicated at the bottom of the email. Although the changes to your account will be processed as quickly as possible within a reasonable amount of time, please understand that you may receive emails and/or newsletters until these changes have been processed. Also, note that opting-out does not apply to any communications necessary for the processing of your order.

SECURITY: 

We implement reasonable administrative, technical, and physical security controls to prevent your information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. However, despite our efforts, no security controls are completely effective and we cannot ensure or warrant the security of your information.

THIRD PARTY WEBSITES: 

The Platform may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the platforms. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links or access are provided through the Platform. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

CONTACT INFORMATION:

If you, at any time, should you wish to:

• Enquire about this Policy or about how we may manage, protect and/or process your information; or
• Complain about the way we manage, protect and/or process your information, please reach out to our Grievance Officer, whose name and contact details are
  provided below as per the Information Technology Act 2000 and Rules made thereunder
  Name: Kavya Ramesh
  Email ID: grievances@solutiontheory.in

NO WAIVER:

The failure on our part to enforce any part of this Policy shall not constitute a waiver of any of our rights hereunder for past or future actions.

 GOVERNING LAW:

This Policy shall be governed in all respects by the laws of India. In case of any dispute with respect to this Policy, the courts at Bangalore, India shall have exclusive jurisdiction to settle any such dispute or claim.

DISCLAIMER

While every effort is made to ensure the accuracy of the information offered on these pages, we shall have no liability for errors, omissions or inadequacies in the information contained herein or for interpretations thereof. The Platform could include inaccuracies or out- dated information and is subject to change at any time without notice. Your use of the Platform is at your own risk.

THE INFORMATION, DOCUMENTATION, SOFTWARE, PRODUCTS, AND SERVICES CONTAINED ON THIS PLATFORM IS PROVIDED "AS IS" WITHOUT ANY WARRANTY OF ANY KIND. THE ENTITY AND ITS OFFICERS, EMPLOYEES AND AGENTS DISCLAIM ALL WARRANTIES RELATING TO THE INFORMATION, DOCUMENTATION, SOFTWARE, PRODUCTS, AND SERVICES CONTAINED ON THE PLATFORM, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES AGAINST INFRINGEMENT OF THIRD PARTY RIGHTS, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. SOME STATES OR JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES OR LIMITATIONS ON HOW LONG AN IMPLIED WARRANTY MAY LAST, SO THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU, TO THE EXTENT INAPPLICABLE. WE SHALL NOT BE LIABLE FOR DAMAGES, WHETHER DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL, AS A RESULT OF THE REPRODUCTION, MODIFICATION, DISTRIBUTION OR USE OF THE INFORMATION, DOCUMENTATION, SOFTWARE, PRODUCTS AND SERVICES.