Please read this policy carefully. By using our services, you acknowledge that you have read and understood how we handle your personal data. If you do not agree with this policy, please do not use our services.

This policy is governed by the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules), and is consistent with applicable data protection principles under Indian law, including the Digital Personal Data Protection Act, 2023 ("DPDPA") as and when its provisions come into effect.

1. WHO WE ARE

Jetlagged Private Limited is a company incorporated under the Companies Act, 2013, with its registered office at:

Jetlagged Private Limited
Q 1003, Phase 3, Centria Hills And Dales Apartment
Mohamadwadi, Pune — 411060, India

We operate the travel brand Jetlagd and provide group travel experiences, membership services, and related products. For the purposes of this policy, Jetlagged Private Limited is the data fiduciary — the entity that determines the purpose and means of processing your personal data.

For any privacy-related queries, contact our Grievance Officer:

Grievance Officer: Sibu Samuel
Email: ss@jetlagd.com
Address: Jetlagged Private Limited, Q 1003, Phase 3, Centria Hills And Dales Apartment, Mohamadwadi, Pune — 411060

Response time: We will acknowledge your complaint within 24 hours and resolve it within 30 days of receipt.

2. WHAT PERSONAL DATA WE COLLECT

We collect personal data in the following categories:

A. Information You Give Us Directly

— Full name

— Email address

— Phone number

— Date of birth

— Passport number, nationality, and passport expiry date (required for trip bookings and visa processing)

— Emergency contact details

— Travel preferences and interests (e.g. sport, music, culture, adventure, food)

— Dietary requirements and health-related information relevant to your trip

— How you heard about us

— Any other information you choose to provide to us in correspondence or forms

B. Information Generated by Your Booking

— Trip itinerary and departure details

— Payment transaction records (note: we do not store payment card data — this is handled entirely by our payment gateway provider)

— Travel insurance policy details, where you arrange this through us

— Booking history and JetPoints balance

— Referral records, where applicable

C. Information Collected Automatically

— IP address and approximate location derived from it (we do not collect GPS or precise device location)

— Browser type, device type, and operating system

— Pages visited, time spent on pages, and links clicked on our website

— Referral source (how you arrived at our website)

— Cookie identifiers and session data — see Section 8 for our Cookies Policy

D. Sensitive Personal Data or Information (SPDI)

Under the SPDI Rules, certain categories of information are classified as sensitive and require additional protection. We may collect the following SPDI where necessary:

— Passport and government identity document details

— Health or medical information (e.g. dietary requirements, physical limitations, or medical conditions relevant to trip participation)

We will always seek your explicit consent before collecting SPDI and will use it only for the purposes for which it was provided.

3. HOW WE USE YOUR PERSONAL DATA

We use your personal data only for legitimate purposes directly related to providing and improving our services. Specifically:

Trip Booking and Delivery

— To process and confirm your booking

— To communicate pre-trip information, including visa guidance, packing lists, and itinerary details

— To share necessary details with local guides, accommodation providers, ground transport operators, and other service partners required to deliver your trip

— To process travel insurance on your behalf, where applicable

— To manage cancellations, date changes, and refunds

Jetlagd Club and JetPoints

— To create and manage your Jetlagd Club membership account

— To calculate, record, and apply JetPoints earned and redeemed

— To manage referral tracking for Crew and Circle members

— To communicate membership-related updates

Safety and Emergency Response

— To share your emergency contact details with our local partners and medical services in the event of an emergency during your trip

— To comply with legal obligations, including requirements imposed by destination country authorities

Marketing Communications

We intend to send marketing communications, including trip announcements, member newsletters, and promotional offers, by email and WhatsApp. We will only send these if you have provided explicit consent, which you may withdraw at any time. See Section 7 for your rights.

Legal and Compliance

• To comply with applicable Indian laws and regulations

• To enforce our Terms and Conditions and Booking Conditions

• To respond to legal process, court orders, or government requests

• To detect and prevent fraud, security incidents, or other harmful activity

Website and Service Improvement

— To analyse website usage and improve our user experience

— To conduct research and analytics to understand traveller preferences

— To test new features and services

4. LEGAL BASIS FOR PROCESSING

Under applicable Indian data protection law, we process your personal data on the following bases:

— Consent — where you have given us clear, specific, and informed consent to process your data for a particular purpose, including marketing communications and collection of SPDI

— Contractual necessity — where processing is necessary to perform a contract with you, including processing your booking and delivering your trip

— Legal obligation — where we are required to process data to comply with applicable law

— Legitimate interests — where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and interests

Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

5. WHO WE SHARE YOUR DATA WITH

We do not sell your personal data. We share it only in the following circumstances and only to the extent necessary:

Service Partners

To deliver your trip, we share relevant personal data with:

— Local guides, ground handlers, and destination management companies

— Accommodation providers

— Ground transport operators

— Activity and experience providers listed in your itinerary

— Travel insurance providers, where you have arranged insurance through us

— Visa facilitation agents, where applicable

These partners are permitted to use your data only for the specific purpose for which it was shared and are required to maintain appropriate security standards.

Technology and Platform Providers

— Payment gateway providers (who process payment card data on our behalf and are bound by PCI-DSS standards)

— Website hosting and cloud infrastructure providers

— CRM and customer communication platforms

— Analytics providers

— Membership and authentication platform providers

These providers act as data processors on our behalf and process data only on our instructions.

Legal and Regulatory Authorities

We may disclose your data to government authorities, law enforcement agencies, or courts where required by law, court order, or to protect the rights, property, or safety of Jetlagged Private Limited, our travellers, or others.

Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving Jetlagged Private Limited, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this policy.

International Transfers

Some of our service partners and technology providers may be located outside India. Where we transfer your data internationally, we take appropriate steps to ensure it receives a level of protection consistent with Indian data protection law, including through contractual safeguards with the receiving party.

6. HOW LONG WE KEEP YOUR DATA

We retain your personal data only for as long as necessary for the purposes described in this policy, or as required by law. Our general retention periods are:

— Booking and trip records — 7 years from the date of travel, to comply with financial and tax record-keeping obligations under Indian law

— Jetlagd Club account data — for the duration of your membership and 2 years thereafter, unless you request deletion

— Marketing consent records — until you withdraw consent, plus 3 years

— Website analytics and cookie data — as specified in our cookie settings, typically 12 to 26 months

— Correspondence and support records — 3 years from the date of last interaction

— Passport and identity document data — deleted within 30 days of trip completion, unless required by law to retain for longer

When data is no longer required, we delete or anonymise it securely. Where deletion is not immediately possible (e.g. data stored in backup systems), we isolate the data and protect it from further processing until deletion is possible.

7. YOUR RIGHTS

Under applicable Indian data protection law, including the DPDPA, you have the following rights in relation to your personal data:

Right to Access

You have the right to request a copy of the personal data we hold about you and information about how we use it.

Right to Correction

You have the right to request that we correct inaccurate or incomplete personal data we hold about you. You can update most of your account information directly through your Jetlagd Club dashboard.

Right to Erasure

You have the right to request that we delete your personal data where there is no legitimate reason for us to continue holding it. Note that we may be required to retain certain data for legal or contractual reasons, in which case we will inform you.

Right to Withdraw Consent

Where we process your data on the basis of consent — including marketing communications and SPDI — you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Right to Grievance Redressal

You have the right to raise a complaint or grievance about our handling of your personal data with our Grievance Officer (see Section 1). If you are not satisfied with our response, you may escalate to the Data Protection Board of India once it is constituted under the DPDPA.

How to Exercise Your Rights

To exercise any of the above rights, write to our Grievance Officer at ss@jetlagd.com. Please include your full name, email address associated with your account, and a clear description of your request. We will respond within 30 days.

8. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies to improve your experience, analyse usage, and support our marketing activities. A cookie is a small text file placed on your device when you visit a website.

Types of Cookies We Use

— Essential cookies: necessary for the website to function. These cannot be disabled.

— Analytics cookies: help us understand how visitors use our website (e.g. Google Analytics). These collect anonymised or pseudonymised data about pages visited, time on site, and traffic sources.

— Preference cookies: remember your settings and choices (e.g. language, membership login state).

— Marketing cookies: used to deliver relevant advertising and track the effectiveness of our campaigns. These will only be placed with your consent.

Managing Cookies

When you first visit our website, you will be presented with a cookie consent notice. You can accept all cookies, reject non-essential cookies, or manage your preferences individually. You can also manage cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the website.

For more information on cookies and how to manage them, visit www.allaboutcookies.org.

9. HOW WE PROTECT YOUR DATA

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

— Encryption of data in transit using TLS/SSL protocols

— Access controls restricting data access to authorised personnel only

— Secure third-party payment processing through PCI-DSS compliant payment gateways — we do not store payment card data on our systems

— Regular security assessments of our systems and third-party providers

— Staff awareness and training on data handling and privacy obligations

No method of transmission over the internet or electronic storage is completely secure. While we use commercially reasonable means to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights, we will notify you and the relevant authorities as required by law.

10. CHILDREN'S PRIVACY

Jetlagd trips are intended for adults. We do not accept direct bookings from individuals under the age of 18.

However, we understand that adults may book trips that include minors travelling with them. In such cases, the adult making the booking is responsible for ensuring they have appropriate authority to provide the minor's personal data, including any SPDI such as passport details or health information. We will process the minor's data only for the purposes of delivering the trip and for no other purpose.

We do not knowingly collect personal data from minors for marketing purposes or for Jetlagd Club membership.

11. THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to third-party websites, including destination guides, visa application portals, insurance providers, and partner services. This Privacy Policy applies only to jetlagd.com and our services. We are not responsible for the privacy practices of third-party websites and encourage you to read their privacy policies before providing any personal data.

12. MARKETING COMMUNICATIONS

We intend to send marketing communications — including trip announcements, exclusive member offers, newsletters, and promotional content — via email and WhatsApp. We will only do this if you have provided explicit consent at the time of account creation or booking.

You may withdraw your consent to receive marketing communications at any time by:

— Clicking the unsubscribe link in any email we send you

— Sending a message to “@jetlagd.com with the subject line "Unsubscribe"

— Updating your preferences in your Jetlagd Club account dashboard

Withdrawing marketing consent will not affect your ability to receive transactional communications related to your booking or account, such as booking confirmations, pre-trip documents, and payment receipts.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by email (if you have an account with us) and update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

Your continued use of our services after any changes to this policy constitutes your acceptance of the updated terms.

14. GRIEVANCE REDRESSAL

In accordance with the Information Technology Act, 2000 and the SPDI Rules, we have appointed a Grievance Officer to address any complaints or concerns regarding our handling of personal data.

Grievance Officer: Sibu Samuel
Designation: Grievance Officer
Company: Jetlagged Private Limited
Email: ss@jetlagd.com
Address: Q 1003, Phase 3, Centria Hills And Dales Apartment, Mohamadwadi, Pune — 411060

We will acknowledge your grievance within 24 hours of receipt and resolve it within 30 days. If you are not satisfied with our resolution, you may escalate your complaint to the Data Protection Board of India once it is constituted under the Digital Personal Data Protection Act, 2023.

15. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of India. Any disputes arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the courts of Pune, Maharashtra, India.

CONTACT US

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Jetlagged Private Limited
Q 1003, Phase 3, Centria Hills And Dales Apartment
Mohamadwadi, Pune, Maharashtra — 411060
Email: contact@jetlagd.com
Grievance Officer: ss@jetlagd.com
Website: www.jetlagd.com