This Privacy Policy describes how RIGHTWAY INBOUND TOURISM LLC – registered company in Dubai, collects, uses, and shares information about you when you visit and interact on our website (mobile and desktop) and mobile app (collectively, "Site") or other means connected to the Sites (such as contacting our customer service team via chat or email).

*We may use your information to provide the requested services, maintain and improve the Site, and send you marketing communications

* We may collect information about you, such as your name, phone number, email address, and credit card details through your use of the Site.

* We may share your information with suppliers, service providers, and our affiliates

* With your consent, we may send you push notifications with information about your reservations and Rightway Inbound Tours programs of your choosing

* We may use cookies and similar technologies to help provide our Site, understand and customize your preferences, and display relevant advertising.

* We maintain appropriate protections for cross-border transfers as required by law for international data transfers.

* We maintain reasonable security measures to protect your information and require our service providers to do the same.

* We will notify you of any material changes by posting the updated version of this Privacy Policy and taking other steps as needed.

* We may provide links to Third Party Websites that are not owned or controlled by us, and are governed by separate user terms and privacy statements

Please contact us with any questions about this Privacy Policy or our privacy practices as detailed below.
1. Information We Collect

We collect information about you that you provide to us when using the Site, such as your name, address, phone number, credit card details, e-mail address, accommodation name, accommodation location and/or length of stay. In addition for flight reservations, we may also collect passenger name, date of birth, nationality and passport details including passport number, country of issue and expiry date.

By visiting our Site, we may also automatically collect certain usage information, such as your IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device's operating system, application version, language settings, and pages that have been shown to you. If you are using a mobile device to access our mobile app or mobile optimized Site, we might also collect information that identifies your mobile device, such as the device ID, location of the device (with your consent), and device-specific settings and characteristics.

If you need to get in touch with our customer support team, or reach out to us through other means (such as through social media, or communicating with your accommodation through us), we will collect information from you there too.

Where you submit reviews regarding your accommodation or other ancillary services available on our website through us, we will collect information from you included in your reviews, including your first name and country of residence.

Where you are making a booking with other guests whose details you provide to us as part of your reservation, or if you make a booking on behalf of someone else, it is your responsibility to ensure that the person or people you have provided personal information about are aware that you have done so, and have understood and accepted how Rightway Inbound Tourism uses their information (as described in this Privacy Policy).

Accommodation partners may share information about you with us too – this may happen if you have questions about your pending booking or if disputes arise regarding your booking.

Special categories of personal information

Certain types of personal data, such as religion or health-related information, are considered sensitive and may require additional protection under applicable laws. Although we do not ordinarily collect sensitive personal data as part of standard accommodation bookings, there may be a need to from time to time, collect such information e.g. as contained in a government-issued identification document or medical certificate if such information is supportive of a transaction or request that you ask us to perform on your behalf such as a cancellation or amendment of your booking. You may also elect to provide us with other information which may imply or suggest information like religion, health or other information, such as when specifying your dietary needs. Such collection and processing of such sensitive personal data will be in line with what is set out in this privacy statement.

Where required by law, we rely on the following legal bases to process personal information:-

• Necessity to Perform Contract with You - we need to process your information in order to provide our travel reservation services to you, answer questions and requests from you, and provide customer support;
• Our Legitimate Interests - we process your information for security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; to analyze, improve, customize and provide our reservation travel and related services to you; and to respond to lawful requests, court orders, and legal process;
• Compliance with Legal Obligations - we need to process your information to comply with relevant laws and regulatory requirements;
• Consent for Special Categories of Personal Data and Direct Marketing Communications - we rely on your consent to collect sensitive personal data and send direct marketing. You can unsubscribe from direct marketing at any time by following the instructions set out in this Privacy Policy; and
• Protect Vital Interest - we may need to process your information in case of emergency involving an individual's life or health.

2. How We Use the Information We Collect

We may use information collected through the Site to:

• Provide you with the requested services, such as creating a user account, processing and confirming your reservation, and communicating with you about services requested (e.g., pre-reservation or post booking chat support (excluding credit card number), special request, cancellations, rewards
• Send you email marketing communications about products and services that may be relevant to you
• Conduct surveys or provide you with information about our services on our Site or on other websites you may visit
• Maintain and improve the Site, tailor the user experience, and for internal training
• Protect the security of you and the Site
• Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands

When you make a reservation on one of our business partners’ websites or apps, we may also receive certain information such as your name and reservation information, including the accommodation reserved, in order to process your reservation and identify which channel your reservation has originated from.

During calls with our customer support team, live listening may be done or calls may be recorded for quality and reference purposes which includes the usage of the recordings for the handling of claims, training and fraud detection purposes. If you would prefer that your call was not recorded, you can opt out by stating this, or by hanging up. Call recordings are kept for a limited amount of time and automatically deleted thereafter, unless Rightway Inbound Tourism L.L.C has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.

If you have not finalized a reservation online, we may send you a reminder to continue with your reservation. We believe that this additional service is useful to you because it allows you to carry on with a reservation without having to search for the accommodation again or fill in all the reservation details from scratch.."

Please note that the confirmation emails and text messages sent after your booking are not marketing messages. These messages are part of your accommodation reservation process. Respectively, they contain information for you to check in at your booked accommodation and a separate invitation to complete the guest review form. You will continue to receive them, even if you have opted out of our marketing messages. Similarly, opting into receiving Price Alerts will not affect any other choices you have made regarding receiving communications from us. If you elect to receive Price Alerts, you will be able to opt out of receiving the same by clicking on the “turn off price alerts” or a similar message found in the Price Alert sent to you.

As mentioned above, if you are completing the booking for another person who will stay at the reserved accommodation, you also have the option to insert the guest’s email address for the purpose that the guest will receive the reservation confirmation and a separate invitation to complete a guest review.

Communications on the Site

We offer you and accommodation partners various means to communicate about accommodations and existing reservations, directing the communications through the Site. You can contact us with questions about your reservation or about your accommodation via the Site, and via other channels that we may make available.

We may access communications and may use automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you or, accommodation partners, us, or others. Note, all communications sent or received using the Site’s communication tools will be received and stored by us. Business partners through whose platform you made the reservation and accommodation partners may choose to communicate with you directly via email or other channels that we do not control.

3. Mobile Devices

With your consent, we may send you push notifications with information about your reservation, guest reviews, potential future stays, or as part of any RIGHTWAY INBOUND TOURISM LLC programs that you participate in, including coupons. You may grant us access to your location information or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such information or the receipt of (or opt out of receiving) push notifications. Different device operating systems may have different default settings, so please familiarize yourself with such settings governing push notifications.

4. Sharing Your Information

In connection with your visit to our Site and use of our services, we may share your information as follows:

• Travel Suppliers such as accommodation properties (e.g., the specific accommodation that you have requested us to reserve) and/or third party accommodation suppliers (e.g., Booking.com), airline, car rental, insurance, and, where available, activity providers, who fulfil your travel reservations. These suppliers may contact you as necessary to obtain additional information about you, facilitate your travel reservation including communicating with you prior to arrival about your upcoming stay, or respond to a review you may submit in accordance with their own independent privacy policies.
• Third Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process personal information for purposes such as credit card and payment processing, business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
• Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your personal information with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
• Our Affiliated Group Companies - our affiliated (group) companies who have access to this information with our permission and who need to know or have access to this information in order to: perform the service requested by you (including to make, administer, and manage reservations or handle payments, "single sign-on", and customer service); analyze how you use our independent and affiliated platforms, improve and provide new and personalized offers, products and services, and marketing; detect, prevent, and investigate fraudulent transactions and/or activities, other illegal activities, and data breaches; internal (audit/compliance) investigations; or as otherwise required or permitted by applicable law.
• Where Required or Permitted by Law - such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of Agoda, our users, or others.
• Business Reorganization - such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.

We provide appropriate protections for such sharing as required by applicable law to prohibit third parties from using your information for their own purposes, and to address the security and confidentiality of your information. Except as disclosed in this Privacy Policy or as required or permitted by applicable law, we will not disclose your information to third parties without your consent.

Disclosure / Transfer of Information

We will maintain the confidentiality of your information, but may provide or transfer your information to third parties as detailed above under "Sharing Your Information," which may include transferring your information to persons to whom we are required to make disclosures to under applicable law within or outside UAE.

5. Cookies

Our Site may use and allow third parties to place cookies (session and persistent), pixels/tags, SDKs, application program interfaces ("APIs"), and other technologies (collectively, "Cookies") on our Site that may collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the basic functions of the Site, such as to keep you logged in while your visit our Site (“Functional Cookies”), while other Cookies are used to provide you with a better user experience, such as:

• To personalize the Site by remembering information about your activities on the Site (e.g., the language you selected or your log-in details). We may also use Cookies together with other automatically collected usage information to recognize a user across different devices, sessions or browsers (including when they have not logged-in) so as to deliver tailored information;
• Perform non-essential website analytics, such as impression reporting, demographic reporting and interest reporting. This may include the recording of mouse clicks, movements, page scrolling and restricted text entered into our Site forms through selected third parties but we will take sufficient precautions to ensure that personal information will not be collected during such recordings e.g. through the adoption of irreversible masking. Website analytics is used to improve our Site and services; and
• To provide you advertising tailored to your interest (collectively, “Non-Functional Cookies”).

Our use of Functional Cookies and Non-Functional Cookies is subject to geographic implementation as detailed below.

6. International Transfers

In connection with the purposes described above, your information may be stored in locations outside of your home country, which may have different standards of data protection than your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers, including information transferred to third parties.

7. Protecting Your Information

We maintain reasonable physical, electronic, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. We use Secure Socket Layer technology to encrypt credit card information during transit. Through your personal account, you also have the ability to save credit card details for faster future bookings and payments. Your card details are encrypted and you can always log in to your personal account to delete, edit, or add certain credit card details. For security reasons, the number cannot be edited (but the card details can be deleted). When viewing card details, only the last 4 digits of the number will be visible. Please note that we will store the last 4 digits of your credit card securely upon any booking made (this is required to manage any refund requests for that booking).

We will retain your information for the period necessary to provide and secure our Sites and services, and to exercise our legal rights and comply with our legal or regulatory obligations. When RIGHTWAY INBOUND TOURISM LLC no longer needs to use your information, we will – unless we need to keep your information to comply with applicable legal or regulatory obligations or the information is required to carry out corporate tasks and conduct our business – remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.

8. How You Can Access or Change Your Information

You can easily correct your account name, the booking holder name (subject to the cancellation policy attached to the booking)

9. Updates to Privacy Policy

On occasion, RIGHTWAY INBOUND TOURISM LLC may revise this Privacy Policy to reflect changes in the law, our information collection and use practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect or use your information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. RIGHTWAY INBOUND TOURISM LLC will also prominently post such material changes prior to implementing the change, and ask for your consent if required by law.

10. Links to Third Party Websites

We may provide links to other websites that are not owned or operated by us ("Third Party Websites"). When you use a link online to visit a Third Party Website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third Party Website before providing any information on that website.

11. Additional Considerations

Our Site is not directed to minors under the age of 18. However, minors can normally accompany their parent(s) or legal custodian(s) who have booked an accommodation, unless prohibited by an accommodation property's policies.

Language This Privacy Policy has originally been drawn up in the English language Terms of Use