This Privacy (“Policy”) applies to the securing and processing of personal data by FORAM WORLDWIDE HOSPITALITY (hereinafter “FORAM WORLDWIDE”) in connection with personal data provided by any person (“User”) who has purchased or intends to purchase or inquiries about any product(s) or service(s) made by FORAM WORLDWIDE through any of FORAM WORLDWIDE’s interface channels including website, mobile site and mobile app (collectively referred herein as “Sales Channels”).

For the purpose of Privacy Policy:

• References in this policy to “you” or “your” are references to ‘User’
• References to “we”, “us” or “our” are references to ‘FORAM WORLDWIDE’
• References to “website” mean a reference to ‘website(s)’, ‘mobile site(s)’ and mobile app(s)

By accessing or using the website or any other sales channel, the User agrees with the term of the Privacy Policy and the contents herein. If you disagree with the Privacy Policy please do not access or use our website or any other Sales Channels.

This privacy policy does not apply to any third-party website(s), mobile site(s) and mobile app(s). Users are requested to take note that information and privacy practices of FORAM WORLDWIDE’s business partners, advertisers, sponsors or other sites to which FORAM WORLDWIDE provides hyperlink(s), may be different from this privacy policy, Hence, it is recommended that you review the privacy policy of any such third parties before you interact.

Your privacy is important to us and we recognise that the use and disclosure of personal data has important implications for us and for the users whose personal data we process.

We respect your need to understand how and why information is being collected, used, disclosed, transferred and stored. Thus, we have developed this Policy to familiarize you with our practices. This policy sets out the way in which we process your information when you use our Website or other digital platforms in accordance with applicable data protection laws. It is important that you read this policy together with any other policies we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. This policy supplements the other notices and is not intended to override them.

A “Controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This notice is issued on behalf of FORAM WORLDWIDE as controller.

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

As the circumstances warrant FORAM WORLDWIDE may be Controller or Processor of your personal data.

Personal data includes any information about any user from which that person can be identified. It does not include personal data where the identity has been removed (anonymous data).

You may be asked for personal data anytime you are in contact with FORAM WORLDWIDE directly or indirectly through a third party.

We collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

We do not collect any special categories of personal data about you through our Website (this 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). Nor do we collect any information about criminal convictions and offences.

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this Notice:

“Contact Data”: including your residential address, work address, email address and telephone numbers;

“Identity Data”: including your first name, last name, username or similar identifier, title;

“Website User Data”: Usernames, Passwords and other security related information used by you in relation to our services

“Transaction Data: Transactional history about your e-commerce activities, buying behaviour. Information pertaining any other traveller(s) for whom you made a booking through your registered FORAM WORLDWIDE account. In such case, you must confirm and represent that each of the other traveller(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). “Marketing and Communications Data”: including your marketing and communication preferences. We also track when you receive and read marketing communications from us, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials. Additional information about the personal data we process in connection with marketing is included with the marketing communications we send you;

“Public Domain or Third Party Data”: Data available in public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per your account settings) as a part of your account information.

“Profile Data”: including information collected progressively when you visit our site including your referral website, pages you visit, actions you take, patterns of page visits and information from forms you fill in;

“Technical Data”: includes information collected when you access our website, mobile site or mobile app your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using; and

“Usage Data”: information about how you use our Website.

“Any other Personal Data”: If you request FORAM WORLDWIDE to provide visa related services, then copies of your passport, bank statements, originals of the filled in application forms, photographs, and any other information which may be required by the respective embassy to process your visa application. If you request FORAM WORLDWIDE to provide foreign exchange (forex) related services then passport copies, A2 form, air tickets or travel authentication document to verify confirmed travel or any other documents required to process your Forex transaction

The only way we will get any kind of personal data is if you choose to give it to us in the following circumstances:

(a) Direct interaction:

• When you make an enquiry or quotation request or make a reservation or purchase from our ‘Website’ or through our customer service team - by email(s), letter(s), fax, on the phone or in physical store
• When you register with us, subscribe to our newsletter, enter in lucky draws/competitions/surveys/feedback, send us queries or register for promotions
• When you engage with us in any online or offline event, promotions, page hosted by us on a third party platform or location
• Through cookies on our Website

(b) Cookies and other technologies :

• We receive Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see cookie policy for further details of the information collected.

(c) Third parties or publicly available sources:

• We receive Technical Data from analytics providers such as Google

When you use our Website we will use your personal data in the following circumstances:

• “performance of a contract”: where we need to perform a contract which we are about to enter into or have entered into with you as a party or to take steps at your request before entering into such a contract;
• “legal or regulatory obligation”: where we need to comply with a legal or regulatory obligation that we are subject to;
• “legitimate interests”: where necessary for our interests provided that your fundamental rights do not override such interests. This can mean, for instance, that it is in our interest, to monitor how you are using our Website or client portals to ensure that the security of our Website or client portals or systems is maintained. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; and
• “consent”: We rely on consent as a legal basis for processing your personal data in relation to sending direct marketing communications to you via email or text message.

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).