Privacy Policy
1. Introduction
This Privacy Policy ("Policy") is issued by LuLu Holidays ("LuLu Holidays", "Company", "we", "us", or "our").
This Policy explains how we collect, use, process, store, disclose, transfer, and protect personal information and travel-related data of users who access or use our website, business-to-business corporate travel portal, mobile applications, APIs, customer support systems, or related services (collectively referred to as the "Platform").
By accessing or using the Platform and/or availing any travel-related services offered by LuLu Holidays, the User acknowledges that they have read, understood, and agreed to the practices described in this Privacy Policy.
2. Scope & Applicability
This Policy applies to:
- Corporate clients registered with the Platform;
- Employees, travelers, representatives, and authorized users of corporate clients;
- Website visitors and users;
- Customers availing travel, booking, visa, hotel, transportation, or related services through LuLu Holidays.
This Policy applies to all services offered through the Platform, including but not limited to:
- Flight bookings,
- Hotel reservations,
- Transfers,
- Visa assistance,
- Tour packages,
- Corporate travel management,
- Customer support services,
- And related travel facilitation services.
3. Definitions
"Corporate Client"
Means any company, institution, organization, or business entity registered with the Platform for managing official travel requirements.
"User"
Means any traveler, employee, representative, customer, corporate client, or authorized person accessing or using the Platform.
"Personal Data"
Means any information relating to an identified or identifiable natural person, including travel-related information.
"Platform"
Means the website, B2B portal, applications, APIs, communication systems, and associated digital infrastructure operated by LuLu Holidays.
4. Information We Collect
4.1 Personal Information
- Full name,
- Gender,
- Date of birth,
- Nationality,
- Passport details,
- Visa details,
- Government-issued identification details,
- Travel preferences,
- Billing and invoicing information,
- GST information,
- Emergency contact information,
- Employment or company-related information where applicable.
4.2 Contact Information
- Email address,
- Mobile number,
- Residential or office address,
- Communication preferences.
4.3 Booking & Travel Information
- Flight details,
- Hotel bookings,
- Transportation details,
- Itineraries,
- Traveler history,
- Loyalty program information,
- Refund and cancellation history,
- Supplier-related booking information.
4.4 Payment Information
Payments are processed through authorized and secure payment gateways.
LuLu Holidays may collect limited payment-related information such as:
- Billing name,
- Transaction references,
- Payment status,
- Invoicing details.
However, LuLu Holidays does not store debit card, credit card, CVV, banking passwords, or sensitive payment credentials.
4.5 Technical & Usage Information
The Platform may automatically collect:
- IP address,
- Browser type,
- Device information,
- Operating system,
- Login activity,
- Cookies,
- Usage patterns,
- Access timestamps,
- Geolocation data where permitted,
- Analytics and diagnostic information.
5. Mode of Collection
Information may be collected through online booking forms, registration forms, customer onboarding, mobile applications, corporate account setup, customer support interactions, emails, phone calls, WhatsApp, chat support, newsletter subscriptions, cookies and analytics tools, travel documentation submissions, supplier integrations, and APIs.
6. Purpose of Data Collection & Processing
LuLu Holidays may process information for processing bookings, issuing tickets and vouchers, managing cancellations and refunds, providing support, verifying traveller identity and documents, facilitating visa and regulatory compliance, fraud prevention, reporting and analytics, improving the Platform, corporate travel management, operational communications, marketing subject to applicable consent, and compliance with legal, accounting, taxation, and regulatory obligations.
6.1 Legal Basis of Processing
- User consent
- Contractual necessity
- Legitimate business purposes
- Compliance obligations
- Fraud prevention/security
7. Sharing & Disclosure of Information
User information may be shared with airlines, hotels, transport operators, visa processing agencies, insurance providers, payment gateway providers, financial institutions, technology vendors, cloud hosting providers, customer support partners, government authorities, immigration authorities, embassies, regulatory agencies, or any other entity legally required for travel processing or compliance.
Users acknowledge and consent that travel-related information may be shared with relevant suppliers and authorities for fulfilment of travel services.
LuLu Holidays does not sell or rent personal information to third parties.
8. Data Retention
Information may be retained for booking management, accounting and invoicing, supplier reconciliation, audit requirements, fraud prevention, legal and regulatory compliance, dispute resolution, enforcement of contractual rights, taxation obligations, and business continuity purposes.
Certain information may continue to be retained even after termination of services where required by law or operational necessity.
9. Data Privacy & Employee Consent
Corporate Clients acknowledge and confirm that necessary consent has been obtained from employees or travelers for processing travel-related data; shared information is lawful and authorized; and employee data provided to LuLu Holidays is accurate and necessary for travel operations.
LuLu Holidays processes employee and traveller information solely for legitimate business and travel-related purposes.
10. Confidentiality
Users agree not to disclose, reproduce, distribute, misuse, or commercially exploit confidential information obtained through the Platform, including negotiated pricing, supplier information, employee travel information, corporate travel policies, login credentials, Platform data, proprietary systems, or operational information.
Disclosure may only occur where legally required or with prior written authorization.
11. Data Security
LuLu Holidays shall use commercially reasonable efforts to maintain the security, integrity, and availability of the Platform and personal information processed through it, including secure servers, encryption technologies, firewall protection, access controls, authentication systems, monitoring systems, and internal security protocols.
Despite reasonable safeguards, Users acknowledge that internet transmission is not completely secure, no electronic storage system is entirely immune from cyber risks, and absolute security cannot be guaranteed.
Users must immediately notify LuLu Holidays of unauthorized access, suspicious login activity, security breaches, or misuse of accounts.
In the event of any material data breach or security incident affecting personal information, LuLu Holidays shall take commercially reasonable steps to investigate, mitigate, and notify affected parties where required under applicable law.
12. Cookies & Tracking Technologies
The Platform may use cookies, analytics tools, session identifiers, and related technologies to improve user experience, remember preferences, analyze Platform traffic, enhance performance, provide personalized services, maintain login sessions, and improve security and fraud prevention.
Users may disable cookies through browser settings; however, certain functionalities of the Platform may become unavailable or restricted.
13. Third-Party Websites & Services
The Platform may contain links, integrations, or access to third-party websites, supplier systems, or applications.
LuLu Holidays shall not be responsible for privacy practices, content, security, or policies of external third-party websites or services.
Users are encouraged to review third-party privacy policies independently.
14. International Data Transfers
Users acknowledge and consent that personal information may be transferred, processed, or stored in jurisdictions where suppliers, technology providers, cloud providers, or travel partners operate.
Such transfers shall be undertaken in accordance with applicable Indian data protection laws and only where operationally necessary for travel booking, fulfilment, customer support, supplier coordination, or technology infrastructure management.
Users further acknowledge and consent that personal information and travel-related data may be shared with international airlines, hotels, global distribution systems (GDS), visa authorities, overseas travel partners, and foreign suppliers where necessary for booking, reservation, ticketing, travel coordination, or fulfilment of travel services.
15. User Rights
Subject to applicable law, Users may request access to personal information, correction or updating of inaccurate data, deletion where legally permissible, withdrawal of consent where processing is consent-based, restriction of certain processing activities, details of categories of personal data processed, grievance redressal, nomination under applicable law, and erasure of personal data where legally permissible.
Certain information may continue to be retained where required for legal compliance, taxation, supplier obligations, fraud prevention, or dispute resolution.
Requests may be submitted using the contact details provided below.
15.1 Communication Consent
Users consent to receiving transactional, operational, booking-related, support, promotional, and service communications through email, SMS, WhatsApp, telephone calls, push notifications, or other electronic communication methods used by LuLu Holidays.
16. User Responsibilities
Corporate Clients and Users are responsible for maintaining confidentiality of login credentials, lawful sharing of employee and traveler information, ensuring accuracy of submitted information, reporting unauthorized access or misuse, and ensuring valid travel documentation and regulatory compliance.
17. Disclaimer
The Platform and services are provided on an "as is" and "as available" basis without warranties of any kind, express or implied.
LuLu Holidays does not guarantee uninterrupted Platform access, error-free operation, continuous availability, complete security, or uninterrupted supplier connectivity.
18. Limitation of Liability
To the maximum extent permitted by applicable law, LuLu Holidays shall not be liable for unauthorized access, data breaches beyond reasonable control, supplier failures, cyber incidents, internet disruptions, operational interruptions, loss of profits, loss of business, indirect or consequential damages, or data loss arising from external causes.
19. Compliance Statement
This Privacy Policy is intended to comply, to the extent applicable, with the Information Technology Act, 2000 and applicable rules framed thereunder; the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; the Digital Personal Data Protection Act, 2023; and other applicable Indian laws and regulations.
20. Grievance Officer
In case of any grievance, concern, complaint, or request relating to privacy or personal data, Users may contact:
Name: ____________________
Designation: ____________________
Email: ____________________
Phone Number: ____________________
LuLu Holidays shall endeavor to address grievances within timelines prescribed under applicable law.
21. Arbitration
In the event that any dispute or grievance is not resolved amicably, the same shall be referred to arbitration in accordance with the provisions of the Arbitration and Conciliation Act, 1996.
- The arbitration shall be conducted by a sole arbitrator appointed in accordance with applicable law.
- The seat and venue of arbitration shall be at Ernakulam, Kerala.
- The proceedings shall be conducted in the English language.
- The arbitral award shall be final and binding upon the parties.
22. Policy Modifications
LuLu Holidays reserves the right to revise, update, amend, or modify this Privacy Policy at any time.
Continued access or use of the Platform after such modifications shall constitute acceptance of the updated Policy.
23. Governing Law & Jurisdiction
This Privacy Policy shall be governed by and construed in accordance with the laws of India.
Courts located in Ernakulam, Kerala shall have exclusive jurisdiction only for matters relating to interim relief, enforcement of arbitral awards, or proceedings ancillary to arbitration.
24. Contact Information
Customer Support: support@luluholidays.in
Phone: +91 9526026786
Registered Office:
Y Tower, Civil Line Road, Chembumukku, Edappally, Kakkanad, Kerala - 682030
Corporate Office:
2nd Floor, Gokulam Towers, LuLu Holidays Pvt Ltd, Mahatma Gandhi Road, Jos Junction, Pallimukku, Kochi, Kerala - 682016
25. Acceptance of Privacy Policy
By accessing or using the Platform, the User confirms that they have read, understood, and agreed to this Privacy Policy.