Privacy Policy

This Privacy Policy applies to Personal Data collected, received or processed by GMW in connection with:

• (a) domestic and international holiday packages;
• (b) honeymoon packages, family holidays, luxury travel, group tours, corporate travel and MICE travel;
• (c) flights, hotels, resorts, villas, apartments and cruises;
• (d) airport transfers, transportation, sightseeing, tours and activities;
• (e) visa assistance, travel documentation and immigration-related support;
• (f) travel insurance assistance;
• (g) foreign exchange assistance, where offered;
• (h) customer enquiries, quotations and itinerary planning;
• (i) confirmed bookings, reservations, cancellations and refunds;
• (j) payments, invoices, tax records and billing;
• (k) website access, online forms, digital campaigns and user interactions;
• (l) customer support, complaints, disputes and grievance handling;
• (m) marketing, promotional offers and customer engagement; and
• (n) any other travel-related, ancillary or allied service offered, arranged or facilitated by GMW.

This Privacy Policy applies irrespective of whether the interaction takes place through the Website, office, email, WhatsApp, telephone, SMS, social media, payment links, online forms, authorised representatives or any other official communication channel of GMW.

Unless the context otherwise requires:

"GMW", "we", "us" or "our" means Goin' My Way Travels, the trading name under which Saket Malhotra operates as a sole proprietor, including its proprietor, employees, authorised representatives, consultants, agents, affiliates, successors and permitted assigns. Goin' My Way Travels is not an incorporated company.

"User" means any person who accesses, browses or uses the Website or otherwise interacts with GMW.

"Traveller" means any person who makes, requests, confirms or benefits from any travel booking or travel-related service arranged, facilitated or provided by GMW.

"Personal Data" means any data about an individual who is identifiable by or in relation to such data.

"Processing" means any operation performed on Personal Data, including collection, recording, organisation, structuring, storage, retrieval, use, sharing, disclosure, transmission, restriction, deletion, erasure or any other handling of such data.

"Data Principal" means the individual to whom the Personal Data relates.

"Supplier" means any independent third-party travel service provider, including airlines, hotels, resorts, cruise operators, Destination Management Companies (DMCs), transport providers, sightseeing operators, activity providers, visa processing centres, embassies, consulates, insurance providers, payment processors, technology service providers or other travel vendors.

"Website" means the official website, landing pages, booking interfaces, enquiry forms and digital platforms owned, controlled or operated by Goin' My Way Travels.

GMW may collect, receive, verify, store and process Personal Data required for travel-related services, including but not limited to:

• (a) full name;
• (b) date of birth;
• (c) age;
• (d) gender;
• (e) nationality;
• (f) marital status, where relevant to honeymoon, family or visa-related travel arrangements;
• (g) residential address;
• (h) email address;
• (i) mobile number;
• (j) alternate contact number;
• (k) emergency contact details;
• (l) passport details;
• (m) visa details;
• (n) government-issued identification details;
• (o) travel dates;
• (p) destination details;
• (q) flight, hotel, meal, seating, room, transfer and travel preferences;
• (r) frequent flyer, loyalty programme or membership details;
• (s) payment and transaction details;
• (t) billing and invoice information;
• (u) GST, PAN, tax or business details, where applicable;
• (v) travel insurance details;
• (w) special assistance requests;
• (x) health, mobility, pregnancy, dietary, allergy or medical information voluntarily disclosed by the Traveller for travel arrangements;
• (y) children’s details where a minor traveller is included in the booking;
• (z) photographs, videos, testimonials, feedback, reviews or other content voluntarily shared with GMW;
• (aa) communication records, including emails, WhatsApp messages, telephone calls, online chats, social media messages and other official communication records; and
• (ab) any other information reasonably required to provide, process, confirm, support or improve the requested travel service.

For the purpose of processing travel bookings, visa assistance, immigration-related support, airline reservations, accommodation bookings, cruise bookings, travel insurance or other travel-related services, GMW may collect and process copies or details of:

• (a) passports;
• (b) visas;
• (c) residence permits;
• (d) re-entry permits;
• (e) government-issued identity documents;
• (f) vaccination certificates;
• (g) health declarations;
• (h) travel insurance documents;
• (i) photographs required for visa or travel documentation;
• (j) bank statements, employment records, business documents or financial information required by embassies, visa centres, consulates or authorities;
• (k) invitation letters, hotel confirmations, flight reservations or travel plans; and
• (l) any other document required by airlines, hotels, embassies, consulates, visa centres, immigration authorities, insurance providers or Suppliers.

Such information and documents shall be used only for legitimate travel-related, contractual, regulatory, legal, accounting, visa, immigration or compliance purposes.

GMW may collect and process payment-related information for booking confirmation, billing, invoicing, accounting, refund processing, reconciliation and fraud prevention.

Such information may include:

• (a) amount paid;
• (b) mode of payment;
• (c) transaction reference number;
• (d) payment date;
• (e) bank or payment gateway confirmation details;
• (f) billing name;
• (g) invoice details;
• (h) GST or tax information, where applicable;
• (i) refund details; and
• (j) any other payment-related record necessary for verification, accounting or compliance.

GMW does not intentionally store complete card numbers, CVV details, net banking passwords, UPI PINs or other sensitive payment authentication credentials. Such information is processed directly by banks, payment gateways or authorised payment processors, where applicable.

When a User accesses or uses the Website, online forms, advertisements, landing pages or digital platforms of GMW, we may collect certain technical and usage-related information, including:

• (a) IP address;
• (b) device type;
• (c) browser type;
• (d) operating system;
• (e) approximate location derived from IP address or device settings;
• (f) pages visited;
• (g) time spent on the Website;
• (h) referral source;
• (i) enquiry form activity;
• (j) interaction with advertisements, campaigns or website features;
• (k) cookies, pixels and similar tracking technologies; and
• (l) other analytics or technical information relating to Website usage.

Such information may be used for website functionality, security, analytics, performance improvement, fraud prevention, customer experience, advertising measurement and marketing optimisation.

GMW may process Personal Data for purposes including but not limited to:

• (a) responding to enquiries and requests;
• (b) preparing quotations, itineraries and travel proposals;
• (c) confirming bookings and reservations;
• (d) arranging flights, hotels, resorts, villas, cruises, transfers, sightseeing and activities;
• (e) processing visa applications and travel documentation;
• (f) arranging travel insurance assistance;
• (g) issuing invoices, receipts, payment confirmations and travel documents;
• (h) processing payments, cancellations, refunds and adjustments;
• (i) sharing required information with Suppliers;
• (j) communicating booking updates, travel advisories, schedule changes or operational information;
• (k) providing customer support;
• (l) handling complaints, grievances, disputes and claims;
• (m) verifying identity, documents and payment authenticity;
• (n) detecting, preventing and investigating fraud, misuse, unauthorised payments or unlawful activity;
• (o) complying with legal, regulatory, tax, accounting, immigration, audit and governmental requirements;
• (p) maintaining business, accounting and statutory records;
• (q) improving services, customer experience and internal processes;
• (r) conducting internal training, quality assurance and service monitoring;
• (s) sending promotional offers, newsletters, travel updates or marketing communications, where permitted by law;
• (t) protecting the legal, contractual, commercial and intellectual property rights of GMW; and
• (u) any other purpose reasonably connected with the provision, management or improvement of travel-related services.

GMW processes Personal Data where such processing is necessary for lawful purposes, including:

• (a) providing travel-related services requested by the Traveller;
• (b) preparing, confirming or performing a booking, quotation, travel arrangement or contract;
• (c) complying with legal, regulatory, tax, accounting, immigration or governmental obligations;
• (d) processing visa, travel, insurance, payment or documentation requirements;
• (e) preventing fraud, misuse, identity theft, unauthorised payments or unlawful activity;
• (f) protecting the legal rights and commercial interests of GMW;
• (g) responding to customer requests, grievances or disputes; or
• (h) any other purpose permitted under applicable law.

Where consent is required, the User or Traveller consents to the collection, use, processing and sharing of Personal Data in accordance with this Privacy Policy.

The User or Traveller may withdraw consent where permitted under applicable law. However, withdrawal of consent may affect GMW’s ability to provide or continue providing the requested travel services, process bookings, obtain visas, issue travel documents, process payments or refunds, communicate with Suppliers or comply with legal obligations.

Where one person submits an enquiry, quotation request, booking, payment or document on behalf of family members, employees, guests, group members or other travellers, such person represents and warrants that they are duly authorised to provide the Personal Data of all such travellers to GMW.

The person making the booking shall be responsible for ensuring that all travellers are informed of this Privacy Policy and have consented to the processing of their Personal Data for the relevant travel-related purposes.

GMW shall be entitled to rely upon such representation unless notified otherwise in writing.

GMW may collect and process Personal Data of children or minors where such data is necessary for family travel bookings, airline reservations, hotel bookings, visa applications, travel insurance, immigration requirements or other travel-related services.

Where a traveller is a minor, the parent, legal guardian or person making the booking confirms that they are lawfully authorised to provide the minor’s Personal Data and consent to its processing for travel-related purposes.

GMW does not knowingly offer services directly to children without the involvement or consent of a parent or legal guardian.

GMW shall not knowingly process children’s Personal Data for behavioural monitoring, targeted advertising or any purpose not reasonably connected with the requested travel service, unless permitted by applicable law.

In certain cases, GMW may receive health, medical, dietary, mobility, pregnancy, disability, wheelchair assistance, allergy, religious meal preference or other special assistance-related information voluntarily disclosed by the Traveller.

Such information shall be processed only where necessary to communicate the Traveller’s requirements to the relevant airline, hotel, resort, cruise operator, transport provider, activity operator, insurer or other Supplier.

GMW shall use reasonable care while handling such information. However, fulfilment of any special assistance request shall remain subject to the policies, procedures, operational requirements and service availability of the relevant Supplier.

The Traveller acknowledges that travel services are performed by independent Suppliers. In order to arrange, facilitate, confirm or support travel services, GMW may share relevant Personal Data with:

• (a) airlines;
• (b) hotels;
• (c) resorts;
• (d) villas and accommodation providers;
• (e) cruise operators;
• (f) Destination Management Companies;
• (g) airport transfer providers;
• (h) transport operators;
• (i) sightseeing and activity providers;
• (j) visa processing centres;
• (k) embassies and consulates;
• (l) immigration authorities;
• (m) travel insurance providers;
• (n) payment gateways, banks and financial institutions;
• (o) courier and logistics providers;
• (p) technology, CRM, hosting, analytics and communication service providers;
• (q) marketing, advertising and customer engagement platforms, where permitted by law;
• (r) legal, accounting, audit or compliance professionals;
• (s) governmental, regulatory or law enforcement authorities; and
• (t) any other party reasonably required for processing, confirming, supporting or protecting the booking.

GMW shall endeavour to share only such Personal Data as is reasonably necessary for the relevant purpose.

Since travel services often involve international bookings and overseas Suppliers, Personal Data may be transferred, shared, stored or processed outside India where necessary for:

• (a) international flight bookings;
• (b) hotel, resort, villa or cruise reservations;
• (c) visa processing;
• (d) immigration or border control requirements;
• (e) travel insurance;
• (f) overseas destination services;
• (g) transfers, sightseeing or ground arrangements;
• (h) emergency assistance; and
• (i) communication with international Suppliers.

By requesting international travel services, the Traveller acknowledges that such transfer or sharing of Personal Data may be necessary for arranging and performing the requested services.

GMW shall undertake such transfer in accordance with applicable law and reasonable business requirements.

GMW may disclose Personal Data where required or permitted by:

• (a) applicable law;
• (b) court order;
• (c) government authority;
• (d) regulatory body;
• (e) law enforcement agency;
• (f) tax authority;
• (g) immigration authority;
• (h) embassy or consulate;
• (i) payment investigation;
• (j) fraud prevention requirement;
• (k) legal notice, dispute or claim; or
• (l) any lawful request or legal process.

Where permitted by applicable law, GMW may use the User’s or Traveller’s contact details to send:

• (a) promotional offers;
• (b) travel deals;
• (c) destination updates;
• (d) newsletters;
• (e) festive offers;
• (f) package recommendations;
• (g) loyalty or repeat-customer offers;
• (h) remarketing communications; and
• (i) service-related updates.

The User or Traveller may opt out of promotional communications at any time by contacting GMW through its official communication channels or by using any unsubscribe mechanism provided, where available.

Even after opting out of promotional communications, GMW may continue to send service-related communications relating to bookings, payments, travel updates, refunds, cancellations, documents, complaints, legal matters or other transactional purposes.

GMW may use cookies, pixels, tags, scripts and similar technologies on its Website, landing pages, advertisements and digital platforms.

Such technologies may be used for:

• (a) website functionality;
• (b) security and fraud prevention;
• (c) remembering user preferences;
• (d) analytics and performance measurement;
• (e) improving Website experience;
• (f) measuring advertising campaign effectiveness;
• (g) remarketing and audience creation;
• (h) understanding user behaviour; and
• (i) improving products, services and customer engagement.

Users may manage or disable cookies through their browser settings. However, disabling cookies may affect the availability, functionality or performance of certain Website features.

Where required, further details may be provided in a separate Cookies Policy / Cookie Notice.

The Website, quotations, itineraries, emails, advertisements or communications issued by GMW may contain links to third-party websites, payment gateways, airline portals, hotel websites, visa portals, insurance platforms, social media platforms or other external resources.

GMW is not responsible for the privacy practices, security standards, content, cookies, terms or data handling practices of third-party websites or platforms.

Users are advised to review the privacy policies and terms of such third-party platforms before submitting any Personal Data.

GMW shall implement reasonable administrative, organisational and technical safeguards designed to protect Personal Data against unauthorised access, misuse, alteration, disclosure, destruction or loss.

Such safeguards may include internal access controls, restricted document sharing, secure storage practices, password protection, staff awareness, device-level security, verification practices and reasonable monitoring of official communication systems.

However, no method of electronic transmission, internet communication, cloud storage, email, WhatsApp communication, payment gateway transmission or digital storage can be guaranteed to be completely secure.

GMW shall not be liable for any unauthorised access, cyberattack, hacking incident, malware, ransomware, system failure, phishing incident, impersonation, unauthorised third-party access or security breach occurring despite the implementation of reasonable security measures, except to the extent such liability cannot lawfully be excluded.

In the event GMW becomes aware of a Personal Data breach affecting Personal Data processed by GMW, GMW shall take reasonable steps to assess, contain, mitigate and address the breach.

Where required under applicable law, GMW shall notify the relevant authority and/or affected Data Principal in the manner and within the timelines prescribed by applicable law.

GMW shall retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including:

• (a) providing travel-related services;
• (b) completing bookings and travel arrangements;
• (c) processing payments, refunds and cancellations;
• (d) complying with legal, regulatory, tax, audit and accounting requirements;
• (e) resolving complaints, disputes or claims;
• (f) enforcing contractual rights;
• (g) preventing fraud or misuse;
• (h) maintaining legitimate business records; and
• (i) fulfilling statutory or operational requirements.

Upon expiry of the applicable retention period, GMW may securely delete, anonymise or archive Personal Data in accordance with its internal policies and applicable law.

Certain records may be retained for longer periods where required for tax, accounting, audit, legal, immigration, visa, payment, dispute resolution, regulatory or statutory purposes.

Subject to applicable law, a User or Traveller may have the right to:

• (a) request access to information regarding their Personal Data processed by GMW;
• (b) request correction of inaccurate or misleading Personal Data;
• (c) request completion of incomplete Personal Data;
• (d) request updating of outdated Personal Data;
• (e) request deletion or erasure of Personal Data, where legally permissible;
• (f) withdraw consent, where processing is based on consent;
• (g) raise a grievance regarding processing of Personal Data;
• (h) nominate another individual to exercise rights in the event of death or incapacity, where applicable under law; and
• (i) exercise any other right available under applicable data protection law.

Any request may be submitted through GMW’s official communication channels.

GMW may require reasonable verification of identity before processing any such request.

GMW may be unable to fulfil a request for deletion, withdrawal, correction, restriction or non-processing where retention or processing is necessary for:

• (a) completion of an existing booking;
• (b) visa, immigration or travel documentation;
• (c) payment, refund, billing or accounting purposes;
• (d) compliance with legal or regulatory obligations;
• (e) fraud prevention;
• (f) security monitoring;
• (g) exercise or defence of legal claims;
• (h) audit, tax or statutory record keeping; or
• (i) any other purpose permitted under applicable law.

Where a request cannot be fulfilled, GMW shall provide a reasonable explanation where required by applicable law.

The Traveller shall ensure that all Personal Data, documents and declarations submitted to GMW are true, accurate, complete and current.

GMW shall not be responsible for any delay, cancellation, denied boarding, visa refusal, immigration issue, financial loss, booking error, payment issue, refund delay or service disruption arising from inaccurate, incomplete, outdated, false or misleading Personal Data provided by the Traveller.

The Traveller shall promptly notify GMW of any change or correction required in their Personal Data.

GMW shall use reasonable care in protecting the confidentiality of Personal Data.

However, confidentiality obligations shall not restrict GMW from disclosing Personal Data where such disclosure is necessary for providing travel services, communicating with Suppliers, complying with applicable law, preventing fraud, enforcing legal rights, processing payments, responding to lawful requests from authorities or protecting the legitimate interests of GMW.

For quality assurance, customer service, staff training, fraud prevention, regulatory compliance, payment verification, grievance handling, dispute resolution and business administration, GMW may monitor, record and retain communications conducted through its official communication channels, including:

• (a) telephone calls;
• (b) emails;
• (c) WhatsApp Business communications;
• (d) SMS;
• (e) online chats;
• (f) video meetings;
• (g) social media messages; and
• (h) other official electronic communication platforms.

Such communications may be relied upon by GMW in connection with customer service matters, complaints, payment disputes, contractual claims, legal proceedings, regulatory investigations or fraud prevention, to the extent permitted by applicable law.

Where a Traveller voluntarily shares reviews, testimonials, photographs, videos, feedback or other content with GMW, the Traveller confirms that they possess the necessary rights and permissions to share such content.

Subject to applicable law and the Traveller’s consent where required, GMW may use such content for lawful business, promotional, marketing, social media, website, advertising, customer engagement or brand communication purposes.

The Traveller may request removal of such content by contacting GMW through its official communication channels. Removal may be subject to reasonable processing time, technical limitations and prior lawful use already made by GMW.

GMW does not sell Personal Data of Travellers or Users.

Personal Data may be shared only where reasonably necessary for travel-related services, legal compliance, business operations, payment processing, fraud prevention, customer support, marketing where permitted by law, dispute resolution or other lawful purposes described in this Privacy Policy.

GMW does not ordinarily use Personal Data for fully automated decision-making that produces legal or similarly significant effects on the Traveller.

However, third-party platforms such as airlines, hotels, payment gateways, visa platforms, fraud detection systems, CRM tools, analytics tools, advertising platforms or communication tools may use automated systems in accordance with their own policies.

GMW shall not be responsible for independent automated processing undertaken by third-party platforms outside its reasonable control.

Access to Personal Data within GMW shall be limited to employees, consultants, representatives, service providers or authorised persons who reasonably require such access for booking, documentation, payment, customer service, operations, compliance, grievance handling, accounting, marketing or administrative purposes.

Such persons are expected to handle Personal Data responsibly and in accordance with internal procedures and applicable law.

In the event of any restructuring, merger, transfer, sale, acquisition, succession, business reorganisation, investment, partnership or transfer of ownership or assets of GMW, Personal Data may be transferred to the relevant successor, purchaser, affiliate, partner, investor or authorised entity, subject to applicable law.

GMW reserves the right to amend, revise, update or replace this Privacy Policy from time to time in order to reflect changes in law, regulatory requirements, business practices, technology, Supplier requirements, security practices or operational needs.

The updated Privacy Policy shall be published on the Website or otherwise made available through official communication channels.

Continued use of the Website, continued communication with GMW or continued availing of GMW’s services after publication of the updated Privacy Policy shall constitute acknowledgement of the revised Privacy Policy.

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of India.

Subject to any mandatory rights available under applicable law, the Courts at New Delhi, India shall have jurisdiction over matters arising out of or relating to this Privacy Policy.

Depending on your enquiry or booking, the personal information you provide may be processed in India, in the United Arab Emirates, or in other countries where the service providers or travel partners relevant to that enquiry or booking operate.

Which countries are involved therefore depends on what you have asked for. A Maldives booking involves the resort and the transfer operator in the Maldives. An enquiry made in the United Arab Emirates may be handled using providers operating there. GMW operates from India, so your information is in every case processed in India as well.

Information shared with any resort, hotel, transfer operator, airline, payment provider or other travel partner is limited to what is reasonably needed for the enquiry, quotation, travel arrangement, booking or customer support in question. A resort receives what it needs to hold and service your room. A transfer operator receives what it needs to carry you. Neither receives more than that.

This section describes where your information goes and why. It does not assert any particular security certification, transfer mechanism or contractual arrangement, because GMW will not claim a safeguard it has not verified. If you want to know which categories of recipient have received your information in connection with your own enquiry or booking, write to the Grievance Officer named in this policy and we will tell you.

Where a child is travelling, GMW may need information about that child in order to match the party to a resort's room occupancy rules, to plan the itinerary, and to price the booking correctly. Resorts set their own age rules, and those rules decide both whether a room may be used by a particular party and what the stay costs.

How much detail is requested depends on which form you use, and the two forms differ deliberately:

Get Quote enquiry form. This form asks only how many children fall into each age band: under 2, 2 to 11, and 12 to 17. It does not ask for a child's exact age. A band is enough for an advisor to begin scoping a room.

AI Itinerary form. This form may ask for a child's exact age, because the itinerary is priced against a specific resort's own age rules, and the boundaries of those rules differ from one resort to another. An exact age is requested here only where it is needed to determine room occupancy eligibility or the correct price.

If an exact age is needed later for a booking that began as a Get Quote enquiry, your advisor will ask you for it at that point.

No other information about a child is requested by either form.

For privacy-related communication, the User or Traveller shall contact Goin' My Way Travels only through its officially published communication channels.

GMW shall not be responsible for privacy-related requests, instructions or communications sent to unauthorised persons, unofficial email addresses, personal mobile numbers, unofficial social media accounts or any communication channel not officially recognised by GMW.

By accessing the Website, submitting an enquiry, requesting a quotation, making a booking, providing documents, making payment, communicating with GMW or availing any travel-related service, the User or Traveller acknowledges that they have read, understood and accepted this Privacy Policy.

© Goin' My Way Travels. All Rights Reserved.

This Privacy Policy constitutes proprietary legal and commercial documentation of Goin' My Way Travels. No part of this document may be reproduced, distributed or commercially exploited without the prior written consent of Goin' My Way Travels, except as permitted by applicable law.