I. Introduction:

MAHINDRA & MAHINDRA LIMITED having its registered office at Gateway Building, Apollo Bunder, Colaba, Mumbai 400001, Maharashtra, India (“M&M”/“we”/“us/”our”/”Company”) understands the sensitivity of the personal or financial information shared or to be shared by you, the user or visitor of M&M’s Website or App (“You/you”/“Your/your”/“Customer/“User”), and is committed to protecting your privacy through our compliance with this Policy.

This privacy policy (“Policy”) describes the types of Information (as defined herein) we may collect from you or that you may provide when you visit M&M’s website at Mahindra Adventure | Off Roading Adventure Sports, Road Trips (our “Website”) or the mobile or desktop application that may be developed in future (“App”) and our practices for collecting, storing, handling, using, maintaining, protecting, and disclosing that Information for the purpose of your participation and consumption of Services offered by us and how you can exercise your privacy rights. The Website lets you book travel experiences, adventure expeditions, off-roading events, off-road driver training programs, and any other service that M&M may include and provide through the Website to its user (“Services”) as more fully defined in the Terms and Conditions for Services.

This Policy is also subject to the Terms of Use available at Terms of Use | Mahindra Adventure and the Terms and Conditions for Services available at Terms and Conditions | Mahindra Adventure..

This Policy applies to Information we collect:

• On this Website or App.
• In email, text, and other electronic messages between you and M&M or this Website or App.

It does not apply to Information collected by:

• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or App.

II. Consent To This Policy:

Please read this Policy carefully to understand our policies and practices regarding your Information and how we will treat it. By using the Website or App or by otherwise giving us your Information, you will be deemed to have read, understood and agreed to this Policy and agree to be bound by the Policy. You hereby consent to our collection, use and sharing, and disclosure of your Personal Information (as defined herein), Usage Information (as defined herein) and all other information as described in this Policy (collectively referred to as “Information”). If you do not agree with our policies and practices, you must not access the Website or App or purchase or use any Services available on the Website or App. If you use the Website or App on behalf of someone else (such as a child) or an entity (such as your employer), you represent that you are authorized by such individual or entity to (i) accept this Policy on such individual’s or entity’s behalf, and (ii) consent on behalf of such individual or entity to our collection, use and disclosure of such individual’s or entity’s Information as described in this Policy. We reserve the right to change, modify, add or delete portions of the terms of this Policy, at our sole discretion, at any time. Your continued use of the Website or App after the changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

III. Information We Collect About You and How We Collect and Process It:

We may collect various Information from and about users of the Website or App, including information:

• by which you may be personally identified, such as name, date of birth, gender, postal address, e-mail address, telephone/mobile number, login address / password, financial or banking information, medical information, insurance information, or any other identifier by which you may be contacted online or offline (“Personal Information”). The Personal Information shall also contain personal identifiers such as Aadhaar Card, Pan Card, Driving License, Passport etc., to provide you with the Services.
• that is about you but individually does not identify you, including but not limited to geo-location information when permitted by you on your device, and any other information provided by you on our Website or App; and/or about your searches on our Website or App, call data records, Services checked or verified on our Website or App, internet connection, the equipment you use to access our Website and usage details (“Usage Information”) Electronic information is generally non-identifying in nature, but to Process (as defined herein) such Usage Information and to make it feasible for our legitimate business interests like promoting system security and stability, allowing for error and performance analysis, and serving internal statistical needs, we may associate the Usage Information with other information collected from you and such combination may be treated as your Personal Data. This data also enables us to optimize our Services.
• Personal Information and Usage Information shall be collectively referred to as “Personal Data”.
• “Processing”, “Processed”, “Process” in relation to Personal Data, means a wholly or partly automated operation or set of operations performed on digital Personal Data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure, or destruction.
• We endeavor to Process only such Information that is reasonably necessary to provide the Service as availed by you through the Website or App or to respond to your inquiries.

We collect this Information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website or App. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• From third parties, for example, our business partners, who have received the Information from you with consent to further disclose to third parties.

IV. Information You Provide to Us:

The Information we collect on or through our Website or App may include:

• Information that you provide by filling in forms on our Website or App. This includes Information provided at the time of registering to use our Website or App, subscribing to any Services, or requesting further Services. We may also ask you for Information when you report a problem with our Website or App or the Services availed by you.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete or communication between us via WhatsApp or any other electronic means.
• Details of transactions you carry out through our Website or App and of the fulfillment of your orders, which includes your financial information before placing an order through our Website or App.
• Other information as described in this Policy.

You also may provide Information to be published or displayed (hereinafter, “posted”) on public areas of the Website or App or transmitted to other users of the Website or App or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Also, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website or App with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

V. Information We Collect Through Automatic Data Collection Technologies:

As you navigate through and interact with our Website or App, we may use automatic data collection technologies to collect certain Information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website or App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website or App
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• We also may use these technologies to collect Information about your online activities over time and across third-party websites or other online services (behavioral tracking). The Information we collect automatically helps us to improve our Website or App and to deliver a better and more personalized service, including by enabling us to
• Estimate our audience size and usage patterns.
• Store Information about your preferences, allowing us to customize our Website or App according to your individual interests
• Speed up your searches.
• Recognize you when you return to our Website or App.

We may use available technology for such automatic data collection, including but not limited to:

• Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website or App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or App.
• Flash Cookies: Certain features of our Website or App may use local stored objects (or flash cookies) to collect and store Information about your preferences and navigation to, from, and on our Website or App. Flash cookies are not managed by the same browser settings as are used for browser cookies and we advise you to keep yourself updated on how to manage your privacy and security settings for flash cookies on your device.
• Web Beacons: Pages of our Website or App and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit M&M, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may not collect Personal Information or Usage Information automatically, but we may tie this Information to Personal Information or Usage Information about you that you provide to us or that we collect from other sources.

VI. Third-Party Use of Cookies and Other Tracking Technologies:

Some content or applications, including any advertisements, on the Website or App may be served by third parties, including payment gateway service providers, advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or App. The information they collect may be associated with your Personal Information or Usage Information or they may collect Information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this Information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

VII. Links To Social Media And Third-Party Sites:

The Application contains some pages that are hosted and served by third parties. In this case, M&M is not responsible for the privacy policies/notices/statements or the content of such Third-Party/Software or Services even if you accessed the third-party website using links from our Website or App.

If you provide your Personal Data to any third-party website, then the use of your Personal Data is governed by their privacy policies. This Policy applies to our Website and App only. We encourage you to be aware when you leave our Website and App and to read the privacy policies of other Third-Party Software applications that may collect your Personal Data.

VIII.How We Use Your Information:

We use Information that we collect about you or that you provide to us, including any Personal Information or Usage Information:

• To present our Website or App and its contents to you.
• To provide you with information, products, or services that we or other third-party service providers may offer on our Website or App.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, subscription and orders, including payment Information, cancellations, or other notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or App or any products or services that we or other third-party service providers offer or provide though it.
• To allow you to participate in interactive features by way of User Contributions on our Website or App.
• In any other way we may describe when you provide the Information.
• Subject to receiving your consent, send newsletters/communications about our own or that of our affiliates’ current Services, new services, or promotions that we are developing, and opportunities that may be available to you.
• Subject to receiving your consent, send any video and audio advertisement to you.
• For any other purpose with your express consent.

We may also use your Information to contact you about our own products and Services that may be of interest to you. If you do not want us to use your information in this way, please inform us.

We may use the Information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We use your Personal Data only if we have a legal basis for doing so. In case, we wish to use your Personal Data for purposes other than the legitimate uses, we shall seek specific consent from you in a separate process prior to processing your Personal Data for such additional purposes.

We shall also use your Information for legal and regulatory purposes, such as:

(i) To ensure compliance with our legal obligations and to also comply with our obligations towards public authorities;
(ii) To enforce our terms and conditions;
(iii) To enforce any legal right or claim;
(iv) For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention or prevention of fraud;
(v) For our internal and external audit requirements and for information security purposes; (vi) As otherwise described to you at the time of collection of your Personal Data.

IX. Disclosure of Your Information:

We may disclose aggregated Information about our users, and Information that does not identify any individual, without restriction. We may disclose Personal Information or Usage Information that we collect or you provide as described in this Policy:

• To service providers and other third parties we use to support our business, provide products or services to you and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of M&M’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by M&M about our Website or App users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them and do not share your financial information with such third parties for marketing purposes.
• To fulfill the purpose for which you provide it or for any other purpose disclosed by us when you provide the information or with your consent.

X. Choices About How We Use and Disclose Your Information:

We strive to provide you with choices regarding your Personal Information or Usage Information. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website or App may then be inaccessible or not function properly.
• Promotional Offers from M&M: If you do not wish to have your email address/contact information used by M&M to promote our own or third parties’ products or services, you can opt-out by emailing your requirement to us at [email protected].
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

XI. Accuracy Of Your Information:

Notwithstanding the obligation on us to put in place all necessary means to maintain the accuracy of your Personal Information, you agree to provide us with accurate Personal Information at all times and you will notify us promptly upon any changes to your Personal Information.

XII. Accessing and Correcting Your Information:

You can review and change your personal information by logging into the Website or App and visiting your account profile page.

You may also send us an email to correct or delete any personal information that you have provided to us. Please note that we may not be able to delete your Personal Information or Usage Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website or App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website or App users.

In addition to your rights stated in this Policy or the Terms of Use, you also have the following basic rights regarding your Personal Information or Usage Information:

You have the right to:

• obtaining a copy of your Personal Data and receive information about the processing of your personal data;
• ask for incorrect, inaccurate or incomplete personal data to be corrected;
• request that personal data be erased when it is no longer needed or if processing it is unlawful;
• object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation;
• request the restriction of the processing of your personal data in specific cases;
• receive your personal data in a machine-readable format and send it to another controller identified by you (‘data portability’);
• request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision.
• right to nominate: In the event of death or incapacity to exercise these rights, you can nominate any other individual to exercise such rights.
• right to withdraw your consent to process your Personal Data: You can withdraw/revoke your consent at any time, to the processing of your Personal Data for which consent was sought earlier.

To exercise the above rights, you should contact and address your request to the DPO. M&M shall respond to your request within one (1) month from the date of your request. You may be asked to provide information to confirm your identity (such as, clicking a verification link, entering a username or password) in order to exercise your rights.

XIII. Data Security:

We have implemented reasonable measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted and processed through secure sites of approved payment gateways.

Safety and security of your information also depends on you. Where we have given you or where you have chosen a password for access to certain parts of our Website or App, you are responsible for keeping it confidential. We ask you not to share your password with anyone. Further, you have an option of not saving your banking or financial information, including details of your debit or credit card, on the Website or app, so that you may reduce the risk of such information being accessed by any third party.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Website or App. Any transmission of Personal or Usage Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or App.

It is important for you to protect against unauthorized access to your password and your electronic devices. You are responsible for logging off from the Website or App after use. M&M does not undertake any liability for any unauthorized use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify us by sending an email.

Further, part of the functionality of the Website and the App involves using service providers to create and maintain the Website or App, as well as execute the orders placed by the users. This may require M&M to disclose information pertaining to the user and their orders to other service providers. However, M&M is not responsible for the confidentiality, security or distribution of any Personal Information, Usage Information or other information by such third parties. M&M shall also not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of M&M, including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.

XIV. Changes to Our Policy:

It is our Policy to post any changes we make to our Policy on this page. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website or App and this Policy to check for any changes.

XV. Use by Minors:

The Website and the App are not meant to be used by or intended for minors. M&M strongly advises the parents or guardians to supervise the use of the Website or App by their minor children. Any use of the Website or the App and provision of Information to us by any minor is deemed to have been provided under due supervision and consent by such parents or guardians.

XVI. Account Closure and Contact Information:

If you wish to cancel your account or request that we no longer use your Information to provide you services, please let us know using the contact details below. We may retain your Information for as long as your account with us is active and as needed to provide you the Services to fulfil any order placed by you. We shall not retain such Information for longer than is required for the purposes for which the Information may lawfully be used or is otherwise required under law. After the account closure, your Information may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our services effectively, but our use of the anonymized Information will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in M&M being unable to provide you with its Services or to terminate any existing relationship M&M may have with you. To ask questions or comment about this Policy, write directly to us at:[email protected]