Privacy Policy

Your privacy, and the security and integrity of your personal information is very important to Travel Life Freedom! This Privacy Policy (this “Policy”) provides you with details of how we collect and process your information and personal data through your use of our site www.roughguides.com (“Site”). This includes any information you may provide through our site when you purchase a product or service, sign up to our newsletter or use other services, for example to download information.

This privacy policy was last updated on October 6th 2021.

© Travel Life Freedom® is a trademark owned by Apa Group with its headquarters at 7 Bell Yard, London WC2A 2JR, United Kingdom and this site is owned & operated by Apa Digital AG, Bahnhofplatz 6, 8854 Siebnen, Switzerland, registered in the Commercial Register of the Canton of Schwyz, registration number CH-020.3.033.676-6). Apa Digital AG is the data controller and responsible for your personal data (referred to as “Travel Life Freedom,” or “we” or “us” or a similar construction).

This Privacy Policy (this “Policy”) together with the Travel Life Freedom Terms & Conditions (as applicable) apply to your use of: our website at roughguides.com (the "Website"); and any of the services accessible through the Website (the "Services").

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

Complaints

You have the right to make a complaint at any time to the supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance at info@travellifefreedom.com.

Scope & Limitations

So that there's no misunderstanding about how we handle your personal data, we will:

Always keep your data safe and private.

Never sell your data.

Allow you to manage and review your marketing choices at any time.

We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website from EEA/UK/California regions. By using our website, providing a consent and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

By viewing, using, or otherwise interacting with the Website, you agree to be bound by the rules applicable of this Policy. If you do not agree to it and/or any part of this Privacy Policy, please do not use the Website or any other service offered electronically by Travel Life Freedom.

Please note that there are some areas of the Website which you may use without any required login credentials and without the requirement that you establish an account or otherwise reveal your identity.

If you provide the Information of any other person to us, you hereby represent and warrant that you are authorized by such person (or his or her parent or legal guardian) to provide such Information for our purposes as provided herein.

By providing us with your data, you warrant to us that you are over 13 years of age. Minors may not submit booking requests and should not provide any Information to the Website without the preceding consent of their parents or their guardian. Should a minor submit a booking request it is assumed that either his parents or guardian have not supervised him or her properly and that they become liable as set forth in the Terms and Conditions and Art 333 Swiss Civil Code.

This Privacy Policy does not cover any ideas or suggestions you may submit for the Website; any information you submit in the form of social media, blogs, responses to comments, reviews or user opinion, and any other content you submit with the apparent intention that such information be published or displayed on the Website, each of which we may use for any purposes in our sole discretion without limitation. We recommend that you do not include any personal, financial, health, or other sensitive information in any such user reviews, comments, or other social media posting or content, as that information may be published and publicly available; any anonymized data.

The limits of liability and disclaimers set forth in our Terms and Conditions also apply to our liability and responsibility under this Privacy Policy.

Subject to the disclosures made in this Privacy Policy, we will not collect any Information without your knowledge and without proper legal basis, including your consent.

In order to use many of the features on the Website, including without limitation to make a booking request, you are required to create a user profile and provide secure login credentials (including username/email and password). By creating your user profile, you are aware that we are processing your personal data and the information you provide for the purposes described in this Privacy Policy and as may otherwise be permitted by applicable law.

We may store certain Information pertaining to your travel package requests, including Information pertaining to other participants for whom you are arranging travel, in order to allow you to complete requested information without having to re-input information for future trips or services.

In addition, from time to time Travel Life Freedom may request information via surveys or contests. Participation in these surveys or contests is completely voluntary, and you have a choice whether or not to disclose this information. In addition to any use of information described in this Privacy Policy, information collected during surveys and contests will be used for the purposes specified on the forms on which it is collected.

Except as described herein, we will not sell your Information to third parties for their promotional activities unrelated to the purposes for which your information was submitted.

This is information you give us about you by filling in forms on the Website, or by corresponding with us (for example, by e-mail or via the chat functions on the Website). It includes information you provide when you register to use our services, subscribe to any of our services, enter into any transaction on the Website, participate in discussion boards or other social media functions on the Website, enter a competition, promotion or survey and when you report a problem with the Website or the Services. If you contact us, we will keep a record of that correspondence.

Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

The information you give us may include

Identity Data may include your first name, last name, username, title and gender.

Contact Data may include your billing address, email address and telephone numbers.

Financial Data may include your payment card details including the long number and country of billing

Profile Data may include your username, password and other registration information, purchases or orders, your interests, preferences, feedback and survey responses

Marketing and Communications Data may include your preferences in receiving marketing communications from us (including your email address) and our third parties and your communication preferences.

Information that you post to our website for publication on the internet (including your user name and the content of your posts)

Information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication)

Specific Information Required to Process a Booking Request to enable us to submit a booking request and to process booking confirmations. We may require information such as each travel participant’s name, birthdate, postal address, telephone number, age, loyalty or rewards program information, visa or other travel/work/resident permit information, driver’s license information, and the like. We may require additional information related to your travel itineraries or preferences, such as meal preferences (possibly including related allergy/health or religious information), requirements for travel or boarding assistance, flight origin, flight destination, flight time, duration of flight, seat number, and any other travel agency your tour providers may be required to coordinate with.

All information discussed in this section may be shared, in addition to the other uses described in this Policy, with the travel provider from whom you have requested bookings or other services, as necessary or appropriate to properly confirm and assemble your tour package or other services.

2) Information we collect about you and your devices “Device information”

Each time you visit our Website we may automatically collect the following information after the consent is given:

technical information, including the anonymized internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information

information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page

Transaction Data may include details about payments between you and us such as date, time, amount, currencies used, exchange rate, and other details of purchases made by you

Usage Data may include details of your visits to our Website including details relating to your use of our services.

We may also process Aggregated Data from your personal data, but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of my site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data

Sensitive data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we ARE required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have requested but if we do, we will notify you at the time.

We want to make it clear how we use your data for marketing purposes and how you can 'opt-out' from receiving any marketing communications from us whenever you want.

Promotional offers from us

We may use your personal data (such as your Submitted Information or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have signed up to receive them and, in each case, you have not opted out of receiving marketing notifications.

Third-Party Marketing

We will obtain your explicit opt-in consent before we share your personal data with any company outside APA Digital AG for marketing or promotional purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the “unsubscribe link” at the bottom of any marketing message sent to you.

Except as provided herein, we will not disclose your Information to third parties. We do share your personal Information as necessary to fulfil your requests or to enable certain functions or features on the Website, as follows:

If you request a travel booking or otherwise use the features or functions of the Website to investigate or purchase travel services, we will share relevant portions of your Information (including state issued identification information, such as passport numbers) with the third party who provides the applicable services in order to confirm and complete bookings and perform related functions. This includes providing your Information as necessary to deliver tickets, ship items, and submit email communications to you on our behalf. Generally, this will not include your payment card information to the extent we process your payments through the Website (however, see below regarding our payment processing providers). See below for additional detail related to Information necessary to process bookings.

If you use the Website to process deposits or payments for travel or other tourism or travel related services, we will provide your payment card information to our payment card processing provider(s) for the purposes of screening for fraud, processing payments, and handling any payment card related queries and other issues (and related purposes). We do not store your payment card information ourselves at any time and you should not provide us your payment card or national identification information outside of the secure areas of the Website which expressly request such information.

We may be required to share your Information with government or regulatory agencies in order to comply with relevant requirements, including but not limited to border control agencies. This may include, without limitation, mandatory circumstances, such as those which involve national security, where Insight Guides is required to disclose your Information even without your consent. For example, to ensure travel security, governments may require access to passengers’ names and related records (typically name, flight origin, flight destination, flight time, duration of flight, seat location, travel agent, form of payment, credit card numbers, travel itinerary, address, telephone number).

We may share your contact information`s with service provider who is sending the newsletter on our behalf.

We may share your non-financial Information with other partners to fulfil your requests or our obligations to you and for the purposes of responding to your questions, but only to the extent permitted by applicable law.

We may disclose your personal information to any of our employees, officers, insurers or professional advisers, insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

- to the extent that we are required to do so by law;

- in connection with any ongoing or prospective legal proceedings;

- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Travel Life Freedom employs appropriate physical, administrative and technical safeguards to protect the confidentiality and integrity of Information and to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of Information. Our contracts with our service providers require them to use appropriate safeguards and to operate consistently with this Policy.

We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

All electronic financial transactions entered into through our website will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure, and that we cannot guarantee the security of data sent over the internet. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Notwithstanding the other provisions of this Section on Retaining your personal data, we will retain documents (including electronic documents) containing personal data:

to the extent that we are required to do so by law;

if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

You have the right to:

Request access to your personal data (known as "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, please reach out to our support team via the email info@travellifefreedom.com.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please review your submitted information in your insightguides.com account by signing in or reach out to our support team via the email info@travellifefreedom.com.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you require this, please reach out to our support team via the email info@travellifefreedom.com.

Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. If you object to the processing of certain data then we may not be able to provide our Services and it is likely we will have to terminate your account. If you require this, please reach out to our support team via the email info@travellifefreedom.com.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you . In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time. If you require this, please reach out to our support team via the email info@travellifefreedom.com.

Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this, please reach out to our support team via the email info@travellifefreedom.com.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our Services to you. We will advise you if this is the case at the time you withdraw your consent. If you require this, please reach out to our support team via the email info@travellifefreedom.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Additional information we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time.

The Website uses a feature of your web browser called a "cookie" -- a file that your browser places on your computer's hard drive to uniquely identify your computer.

The Website creates and then uses cookies to make log-in more convenient, to tell us whether you have previously visited the Website, to track your clicks through the Website, and to help us determine whether you came to the Website from a particular Internet link or advertisement.

Cookies can also be used to save and retrieve passwords and to save information on past usage of features and other preferences. We do not and cannot use cookies to retrieve personal information about you from your computer unless such information was knowingly and willingly provided by you.

Some of our business partners, sponsors, and advertisers also use cookies through the Website (for example, advertisers) to track the success of their advertising and marketing efforts, which is standard practice for many of the websites you may visit.

By your using this website, we imply that you have read this policy and agree to us sending you cookies.

Third Party cookies

Some features used on this website may involve a cookie being sent to your computer by a third party. For example, if you view or listen to any embedded audio or video content you may be sent cookies from the site where the embedded content is hosted. Likewise, if you share any content on this website through social networks (for example by clicking a Facebook “like” button or a “Tweet” button) you may be sent cookies from these websites. We do not control the setting of these cookies so please check the websites of these third-parties for more information about their cookies and how to manage them.

Why do we use cookies

Cookies make sure that during your visit to our website the website keeps running smoothly and safely. The cookies also ensure that we can see how our website is used and how we can improve it. Furthermore, depending on your preferences our own cookies may be used to present you with targeted advertisements that match your personal interests.

What type of cookies do we use?

Necessary cookies

These cookies are necessary for the website to function properly. Some of the following actions can be performed by using these cookies. - Store articles in a shopping cart for online purchases - Save your cookie preferences for this website - Saving language preferences - Log in to our portal. We need to check whether you are logged in.

Performance cookies

These cookies are used to gather statistical information about the use of our website, also called analytics cookies. We use this data for performance and website optimization.

Functional cookies

These cookies enable more functionality for our website visitors. These cookies can be set by our external service providers or our own website. The following functionalities may or may not be activated when you accept this category. - Live chat services - Watch online videos - Social media sharing buttons - Login to our website with social media

Advertising / tracking cookies

These cookies are set by external advertising partners and are used for profiling and tracking data across multiple websites. If you accept these cookies, we may show our advertisements on other websites based on your user profile and preferences. These cookies also save data about how many visitors have seen or clicked on our advertisements in order to optimize advertising campaigns.

Unclassified

These cookies are still in the classification process. They will show up in one on the following categories; Necessary, Performance, Functional or Advertising.

The Website may be, in whole or in part, an advertising supported Website, and when responding to a third party advertisement or offer, you may submit your information to such third party outside of our control.

We may also include social-media plugins like Facebook and Twitter buttons. We are in no way responsible for any of your activities in respect of your use of third party social media.

The Website may contain links to other websites that are not controlled by Travel Life Freedom and are marked with a special character nearby. We are not responsible for the privacy practices of such other websites.

We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every website that collects personally identifiable information.

This Privacy Policy applies solely to information collected by Travel Life Freedom and the Website.

All information collected or provided may be transferred or assigned by Travel Life Freedom in conjunction with a merger or the sale of all or a portion of Travel Life Freedom (or similar event).

We may update this policy from time to time by publishing a new version on our website. You should check this page from time to time to ensure you agree with any changes to this policy.

We may notify you of changes to this policy by email.

Should you have an queries on our Privacy Policy please contact us:

Email: info@travellifefreedom.com

Mobile: +91 9819878761