Privacy Policy

Wilson & Hughes India Private Limited ("Company" / "us" / "we" / "our") believes that customers/users ("you" / "your") who book or seek any services at www.coxandkings.com / ("Websites") have the right to know about the Privacy Policy that is followed by us.

We value your right to privacy. This Privacy Policy will elucidate our practices regarding the handling and securing of your Personal Data (defined hereunder) by us, our subsidiaries, and affiliates.

This Privacy Policy shall apply to any and all persons who:

• Purchase and/or intend to purchase and/or inquire about any products of the Company ("Products") and/or any services of the Company ("Services").
• Purchase any service(s) made available by us through any of our various customer interface channels including, without limitation, the Websites, mobile site, and mobile app (collectively referred to hereinafter as "Online Sales Channels"), and through our offline channels such as, but not limited to, call centers, offices, agents, and franchisees (collectively referred to hereinafter as "Offline Sales Channels").

We are Wilson & Hughes India Private Limited, an Indian Company, a company incorporated in India under the provisions of the Companies Act, 1956, having our registered office at A – 12, 4th Floor, Technology Park, Chandigarh G.P.O., Chandigarh – 160017, India. For the purposes of applicable data protection laws, we are the "Data Controller" of all Personal Data that we collect, use, and otherwise process about you, through:

• Online Sales Channels
• Offline Sales Channels
• Social media pages we control (hereinafter referred to as "Social Media Pages")
• Email messages, SMS, notifications, alerts, etc., that we send you from time to time
• Offline interactions

We have appointed a Data Protection Officer (hereinafter referred to as "DPO"), who is responsible for overseeing queries related to this Privacy Policy. In case of any queries, please contact:

This Privacy Policy is reviewed regularly by us to ensure transparency about how we use your Personal Data. Any updates/amendments will be reflected on our Websites.

The Online Sales Channels may include links to third-party websites, plug-ins, and applications. Clicking such links or enabling connections may allow third parties to collect or share your Personal Data. We do not control such third-party websites and disclaim responsibility for their privacy practices. You are advised to read the privacy policies of every third-party website you visit.

The types of information we collect about you include the following:

"Personal Data" refers to any information and/or data that identifies you as an individual or relates to a particular individual. Depending on the circumstances, we may collect any of the following:

• Details such as, but not limited to: your name, gender, address, contact number, email address, date and place of birth, nationality, religion, PAN card number, Aadhaar number, dietary preference (veg/non-veg), health-related information relevant to your ability to receive our services, your holiday itinerary, or to provide special assistance.
• Payment-related data: credit/debit card number, bank account details, net banking information, cheque details, or other relevant payment data.
• Financial and tax-related information in limited cases.
• Information related to your transactions on the Websites, including date and time, transaction amounts, and associated details.
• Language preference.
• Identification details such as your passport or other government-issued identification (passport number, issuing country, expiry date), visa information, etc.
• Special dates: birthdays, anniversaries, or similar dates of yourself or your family members.
• Membership or loyalty program details (including co-branded cards, affiliations with travel partners), and employer details.
• Travel data and preferences: itinerary, flight details, booking information, onward travel details, experiences or excursions, baggage and seat preferences, lounge visits, and any special services or assistance requested.
• Information about your interactions with our teams, including queries, comments, complaints, feedback, purchases, service requests, and amenities.
• Geographic location and IP address.
• Social media account ID, profile photos, and other publicly available or linked account data.

In certain limited situations, we may also collect:

• Data about your family members or companions (e.g., names, ages, birthdays).
• Biometric data (e.g., digital images).
• Audio/video recordings via: security cameras in public areas (hallways, lobbies, etc.), body-worn cameras by loss prevention or security officers, and guest preferences and personalized data ("Personal Preferences"), such as your interests, hobbies, food/beverage preferences, services, or other amenities disclosed to us or observed during your visit.

"Other Data" refers to information/data that does not identify you as an individual or relate to any specific person, including (but not limited to):

• Browser and device data
• App usage data
• Data from cookies, pixel tags, and other tracking technologies
• Demographic or aggregated data not tied to an individual

If any Other Data becomes capable of identifying you as an individual, it will be treated as Personal Data.

The lawful basis for processing your personal data includes your consent, the necessity of processing for the performance of a contract, compliance with a legal obligation, or our legitimate interest, such as fraud prevention and service improvement, where such interests are not overridden by your rights.

Sensitive Data includes Personal Data that reveals information such as:

• Health conditions
• Social security numbers or national IDs
• Racial or ethnic origin
• Political opinions or beliefs
• Religious or philosophical beliefs
• Trade union membership
• Sexual orientation
• Biometric/genetic data
• Criminal records or proceedings

Processing of Sensitive Data requires your explicit consent. For example, details related to disabilities, medical conditions, restricted mobility, or dietary restrictions revealing religious beliefs constitute Sensitive Data. We will seek your express consent before collecting or processing such data at the time of your booking or inquiry.

Depending on the context, we collect Personal and Other Data (collectively "Information") in various ways:

Online Sales Channels

We collect Information when you:

• Browse our websites or mobile apps.
• Book/search for Products or Services online.
• Partially or fully fill out booking forms (submitted or not).
• Interact with us on social media (e.g., Facebook, LinkedIn, Instagram, Twitter, YouTube, Pinterest).
• Subscribe to newsletters, participate in contests, surveys, or promotions.

Offline Sales Channels

We collect Information through:

• Online booking forms (partially or fully filled).
• Phone reservations, email, online chat, or customer service.

Note: Such communications may be recorded for quality assurance and training.

Third-party sources, such as:

• Public databases
• Marketing partners
• Vendors or data providers

Internet-connected devices in our offices or franchisee outlets.

Apps and location data:

If you use our App, we may collect your device's geolocation (via GPS, cell towers, WiFi) until the app is closed or you disable location services.

Device/browser data, such as:

• MAC address
• Device type and model
• Screen resolution
• OS and browser details
• Language settings
• App versions

App usage data, including:

• App access logs (date/time)
• Files/data downloaded using the App
• Linked to your contact number

Analytics and advertising partners (e.g., Google, Yahoo, Adobe):

They may collect data via cookies and technologies to analyse usage patterns.

IP address:

Automatically captured when you access Online Sales Channels and used to determine usage levels and geographic location.

We will use your Information for various purposes related to fulfilling our contractual obligations. The specific use of some Information depends on the services you have requested or engaged us for. If you fail to provide the required Information or object to its collection, we may not be able to provide the requested Products or Services.

The Information will be used for the following legitimate business purposes:

To provide you with booked Products/Services:

We use your Information to deliver the Products or Services you have booked with us. This includes, but is not limited to, flight tickets, rail tickets, cruises, accommodation, tours, transportation, and car hire. We may also use your Information to provide special assistance (e.g., visa, insurance) with your prior consent. This also covers reservation facilitation, payments, confirmations, pre-arrival messages, and destination information.

To support our electronic receipt and communication system:

If you provide an email ID at the time of booking, we may use it to send invoices, confirmations, or documents. If you book on behalf of a third party using your email address, the booking-related documentation will also be sent to you. We will also use your Information to process transactions, facilitate payments, and recover any outstanding dues.

To communicate with you and provide support:

We may use your Information to contact you via email, SMS, notifications, or other means about your booked Products or Services, itinerary changes, policy updates (e.g., Terms and Conditions, Privacy Policy), and to issue vouchers, tickets, etc. We may also use your Information to share marketing materials, offers, newsletters, or conduct satisfaction and market research surveys, subject to applicable laws.

Loyalty Programs:

We may use your Information to offer and manage participation in loyalty or rewards programs, whether global, property-specific, or interest-based.

To optimise Online Sales Channels:

We use your Information to enhance the accessibility, convenience, and functionality of our Online Sales Channels and to provide relevant content using analytics and research.

To protect our operations and prevent unlawful activity:

We process your Information to detect, investigate, and prevent fraud, unauthorised access, terrorism, and other criminal or unlawful activities. This includes enforcing our internal policies and securing our systems.

To comply with legal obligations and support business operations:

We may use your Information to comply with laws, respond to legal claims or investigations, and protect our employees, customers, and business interests. This includes sharing Information with legal counsel, technical advisors, regulatory authorities, and law enforcement agencies, where required. We also use your Information for audits, analytics, service improvement, and marketing effectiveness evaluation.

To effectively deliver services under contract, we may disclose your Information to the following categories of recipients:

Affiliate and Group Companies:

We may share your Information with group entities and affiliates for purposes including:

• Ensuring service fulfilment
• Customer communication
• Loyalty program management
• Business operations
• Statistical analysis and market research
• Outsourced service delivery (e.g., call centres)

Agents and Franchisees:

We may disclose your Information to our authorised agents or franchisees to administer services, conduct analysis or surveys, or for related purposes mentioned in this Privacy Policy.

Third-Party Service Providers and Authorities:

If your travel includes services from third-party providers (e.g., hotels, airlines, visa consultants), we will share the necessary Information to facilitate those services. Additionally, some countries legally require us to provide passenger Information to border or immigration authorities. Airlines and other providers may need to disclose travel data to comply with local and international regulations (e.g., APIS requirements).

Business Partners and Vendors:

We may share your Information, as required, with:

• Marketing and advertising agencies
• IT developers and software vendors
• Call centres and outsourced BPOs
• Companies managing promotions or events
• White-label service partners
• Destination management firms, ground handlers, and analytics providers
• Financial institutions and medical service providers

Regulatory/Government Authorities:

We may share your Information with government agencies, law enforcement, or regulators when required to comply with laws, respond to legal processes, fulfill public authority requests, enforce terms of use, or protect company rights and safety.

Successors in Business Transfers:

In the event of a merger, acquisition, reorganisation, or sale of assets, we may transfer your Information to third parties or successors, provided they use it in line with this Privacy Policy.

This Privacy Policy does not govern the practices of third-party individuals, organisations, or entities (collectively, "Third Party Entities"), including:

• Franchisees
• Owners
• Business Partners
• Service Providers
• App Developers or Platforms
• Social Media Platforms
• OS Providers
• Wireless or Internet Providers
• Device Manufacturers

Mentions or links to these Third Party Entities on our Online or Offline Channels are not endorsements. We do not control and are not liable for the data handling practices of such entities. You are encouraged to review the applicable privacy policies of any third party before engaging with them.

We implement appropriate technical and organisational safeguards to protect Personal Data from:

• Unauthorized access or use
• Accidental loss, destruction, or damage
• Unlawful processing

These measures are proportionate to the potential risks and are updated in line with technological advancements.

Our security protocols include, but are not limited to:

• Restricting access to Personal Data to employees, agents, franchisees, service providers, and contractors on a strict need-to-know basis.
• Ensuring physical security of offices and stores, as well as device/system security through encryption, password protection, and access controls.
• Technical measures such as password hashing, login auditing, idle session termination.
• Internal policies and employee training on confidentiality, data protection obligations, and enforcement mechanisms.

While we implement stringent measures to protect your Information, you are also responsible for taking reasonable precautions to safeguard your data. Recommended steps include:

• Use strong, unique passwords and update them regularly. Keep your booking reference numbers, login credentials, and passwords confidential. Avoid using the same password across multiple platforms.
• Always log out from your account after each session, especially when using shared or public devices.
• If you suspect that your password, booking reference, or account has been compromised or accessed without authorization, notify us immediately.
• Ensure your devices (e.g., phones, tablets, laptops) are protected using the latest operating systems, antivirus, or firewall software.
• Remain vigilant against phishing emails, suspicious links, or fraudulent messages impersonating our brand or representatives.

• We will only retain and use your Information for marketing purposes where you have specifically consented to this or where we are permitted to do so in accordance with data protection laws (including as set out below).
• We may send you email marketing where we comply with applicable laws, rules, and regulations. However, you will, of course, be given the opportunity to opt out of receiving such email marketing communications when you first provide us with your email address and whenever we send you any email marketing.
• Where you have previously requested or agreed to receive information about our travel services from us by post/courier/email/SMS, we may continue to send you such information in the same manner until you ask us not to (which you can do by telephone, email, post/courier, or SMS). Everything we send you will inform you of the process to follow if you no longer wish to hear from us. We will send you this information as it is necessary for the purposes of our legitimate interests in communicating with you, unless it is or becomes evident that your interests or fundamental rights and freedoms override our legitimate interests, in which case we will cease such communications.
• You may provide your consent to receiving marketing information from us by opting to receive marketing material either online or by telephone. You may also choose your preferred modes of communication. For example, you may be willing to receive information and offers via courier, SMS, and email, but not by telephone.

Yes, you may withdraw your consent to receiving marketing material or other communications from us, either generally or via specific modes, at any time by emailing us at holidays@coxandkings.com, or by contacting us via telephone.

Yes, you may request us to review, correct, update, suppress, restrict, or delete your Personal Data under certain circumstances — for example, where you have withdrawn your consent to marketing communications and the data is only being processed for that purpose. If you would like to request any of the above, or obtain a copy of your Personal Data, please contact the Data Protection Officer at holidays@coxandkings.com.

• You are entitled to ask us (by letter or email) what personal information of yours is being held or processed, for what purposes, and to whom it has been or may be disclosed. No fee will be charged for responding to your request unless it is manifestly unfounded, excessive, or repetitive, or where we have previously provided the same information.
• We promise to respond to your request without undue delay, and in any event within one (1) month, unless the request is complex or involves numerous requests. In such cases, we may extend the response time by a further two (2) months in accordance with applicable law.

If you believe your data is inaccurate, outdated, or incomplete, please notify us by email at the earliest. We will rectify the issue within one (1) month or, in complex cases, within three (3) months.

• Your information will be stored in secured locations and on servers controlled by us, located either at our offices or at those of our service providers.
• We will not process your information in a form that enables personal identification for longer than is necessary to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.
• Where your information has been provided for the purpose of holiday arrangements or other contracted services, we are entitled to retain it for a period of six (6) years after such services have been completed. In certain cases, we may retain it longer, such as (i) where there is an ongoing relationship (e.g., you are registered with us or continue using our services), (ii) to comply with applicable laws or regulations, or (iii) where retention is reasonably required for our legitimate interests and/or to establish, exercise, or defend legal claims.
• If you have consented to receive marketing communications from us, we may continue to use your information for this purpose until you withdraw your consent or until we reasonably consider your consent to have expired.

• We encourage you to register with us to book services on our Online Sales Channels and to enjoy customization features. However, if you choose not to register, you may still access parts of the site where registration is not required. In such cases, the information collected from you is limited.
• We log your IP address to help diagnose server problems, administer our website, and track usage statistics.
• Your IP address may vary depending on your type of internet connection. We do not attempt to identify users via IP addresses.
• If you accessed our website through a link or advertisement on another site, we may log that information. This helps us understand user interests and improve exposure. All data collected this way is anonymized and used in aggregate form only.
• We may place a cookie on your device to track website usage. Unless you register, this cookie contains no personally identifiable information. Cookies cannot read data off your hard drive or retrieve information from other cookies. You may refuse cookies through your browser settings, but this may affect website functionality.
• If you reached our website via a partner site and registered with them, some of your information may be transmitted to us. Review their privacy policy to understand what data was shared. We do not retain such data unless you register with us.

• Registered users on www.coxandkings.com can transact online and book services such as flights, hotels, car rentals, and holiday packages.
• We collect personal data at the time of registration (e.g., name, contact details, preferences, passport number, etc.). We may store this in a cookie to recognize you on return visits.
• Occasionally, we may supplement this data with verified third-party information.
• If you register through a partner site, certain data may be shared with us. We use such data in line with this Privacy Policy.
• If you register through a partner, we may share your registration data with that partner, subject to this Policy. We cannot control how such partners use that information. You may avoid this by registering directly on our website.