Privacy Policy

Last Updated: November 11, 2024

We have updated our privacy policy to make it shorter and easier to read, and to comply with the EU General Data Protection Regulation.

Who we are?

This privacy policy addresses the privacy practices of RateGain Travel Technologies Ltd., India and its step-one and step-two subsidiaries RateGain Technologies Inc., USA, BCV Social LLC., USA, RateGain Adara Inc., USA, Myhotelshop GmbH, Germany and RateGain Technologies Limited, UK and collectively referred to in this privacy policy as (“RateGain”, “we” or “us”). We at RateGain are committed to safeguarding your privacy. This Privacy Policy describes how we may collect, use, share, and keep personal information about you. Please make sure you read this Privacy Policy carefully.

What does this Privacy Policy cover?

This Privacy Policy applies to our public-facing ‘RateGain’ branded websites, our product & services and will be available by a link on all sites and services which it covers. We encourage you to take a moment to look at the applicable Privacy Policy, available by a link at the bottom of the homepage.

Data Protection/EU–U.S./Swiss–U.S. EU-US DPF Framework

RateGain complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  RateGain has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. RateGain has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. 

What is in this Privacy Policy?

• What personal information do we collect?
• Do we use cookies?
• How do we use your personal information?
• How long do we keep your personal information?
• How do we share your personal information?
• Where do we keep your personal information?
• What rights do you have in relation to your personal information?
• How do we safeguard your personal information?
• How will we update this Policy?
• Other important information.
• How can you contact us about this Policy? 

What personal information do we collect?

For the purposes of this Privacy Policy, references to ‘personal information’ mean any information relating to an identified or identifiable individual. Examples of personal information may include, for example, your name, your contact details or your location.

We collect information as a Data Controller that you supply to us when you choose to contact us for more information or when you register for one of our websites or online services. This information typically includes your name, professional credentials, email address and other contact data. We may append information from other sources, such as Google Analytics, to supplement what you give us. We do, on occasion, obtain or license contact information from third parties for limited marketing purposes, such as maintaining an accurate marketing database.

We gather date, time and certain additional information about a user’s browser and system or device configuration and capabilities for all visitors to our web sites. We may use this information for our internal security audit log, for trend analysis and system administration and to gather broad information about our audiences. We process your data to comply with the law of the land and to provide you certain benefits like employee stock ownership. We process your data on the basis of our legitimate interest and on the basis of consent provided by you.

Rategain process your data while acting as Data Processor. We collect your information including your official email ID when shared with us by your employer in order to avail our services.  We process your data where processing is necessary for the performance of a contract.

You are advised to read and understand the privacy notice of your data controller where RateGain acts as Data Processor.

Do we use cookies?

We use cookies and other commonly used data-collection technologies on our websites and in our newsletters and emails to collect information on both an aggregate and individual basis. Please see our Cookies Policy for more details on how we use cookies and how to control cookies or their use for targeted advertising or marketing.

How do we use your personal information?

We may use the personal information we collect to:

• Provide and administer our services;
• Understand our audience and improve how our websites work
• Contact you and answer your questions;
• Market and advertise our products and services to you;
• Allow you to publish comments and participate in professional web-based forums;
• Keep our systems, users, employees and services safe
• Provide you with the information or support you requested.

How long do we keep your personal information?

We keep your personal information for so long as is necessary in light of the purpose for which it was originally collected or lawfully further processed. The criteria we use to determine the period of time for which your personal information may be kept include:

• The nature and type of personal information that you provide to us;
• The purpose for which you provide your personal information to us; and necessary business and operational requirements to continue to supply you with the services or functionality you have requested.
• We may retain your information for a longer time period if we are required to do so by law.

How do we share your personal information?

We may disclose personal information about you to third parties, including:

• to other members of the RateGain;
• to vendors that work on our behalf;
• to law enforcement when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding or other legal process served on us;
• to exercise our legal rights or defend against legal claims; and
• to protect human safety or our networks or property, or as part of a sale or merger of our company or business assets.

We may retain your information for a longer time period if we are required to do so by law.

How do we use your personal information?

We may use the personal information we collect to:

• Provide and administer our services;
• Understand our audience and improve how our websites work
• Contact you and answer your questions;
• Market and advertise our products and services to you;
• Allow you to publish comments and participate in professional web-based forums;
• Keep our systems, users, employees and services safe
• Provide you with the information or support you requested.
• To comply with the law of the land
• To provide ESOP benefits
• To perform a contract

How long do we keep your personal information?

We keep your personal information for so long as is necessary in light of the purpose for which it was originally collected or lawfully further processed. The criteria we use to determine the period of time for which your personal information may be kept include:

• The nature and type of personal information that you provide to us;
• The purpose for which you provide your personal information to us; and necessary business and operational requirements to continue to supply you with the services or functionality you have requested
• We may retain your information for a longer time period if we are required to do so by law.

How do we share your personal information?

We may disclose personal information about you to third parties, including:

• to other members of the RateGain;
• to vendors that work on our behalf;
• to law enforcement when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding or other legal process served on us;
• to exercise our legal rights or defend against legal claims;
• to protect human safety or our networks or property, or as part of a sale or merger of our company or business assets.
• with Registrar and Transfer agents in order to provide you the benefits 

We ensure that appropriate organisational and technical measures are in place while sharing your data with a third party.

Where do we keep your personal information?

We collect, store, and process information on servers around the world and may access that information globally. We ensure that all such servers and storage systems are in compliance to privacy regulations. If you are located in the European Union, please note that your personal information may be transferred out of, or stored outside, the European Economic Area. We take steps to ensure that your personal information continues to be protected through adequate safeguards, copies of which are available from us on request at the email address below.

What rights do you have in relation to your personal information?

You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal information and the local law in your jurisdiction. Depending on this you may have the right to:

• Ask us for copies of your personal information. There are some exceptions, which mean you may not always receive all the information we process;
• Ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
• Ask us to delete your personal information;
• Ask us to restrict the processing of your information;
• Object to our processing of your personal information;
• Ask that we transfer information you have given us from one organisations to another, or to give it to you; and
• Complain to your local data protection authority.

Please note that deleting your information or restricting the continued processing of your information may limit our ability to continue to provide our websites, applications, and online services to you.

You also have a choice about:

Whether to receive email marketing messages from us. You may opt out of our email marketing lists by following the opt-out directions at the bottom of our promotional emails. Please note that we have a number of brands and products and allow you to opt out selectively.

Whether to share information about yourself and your use of our sites with third parties including social media sites.

If you use credentials from a third party, like LinkedIn, to register, then that third party will also record the fact that you have registered for our sites and may use that information consistent with its own privacy statements and practices. If you use, share, like or similar social media buttons, those actions may be posted elsewhere (such as on the relevant social media sites).

Whether to allow certain uses of cookies and other data collection technologies. Please see our Cookies Policy.

If you have any questions about your rights, please email us at datenschutz@slk-compliance.de for Myhotelshop GmbH, Germany and privacy@rategain.com for all other RateGain entities

You can also contact your local Data Protection Authority.

How do we safeguard your personal information?

We want to make sure your personal information is not shared with or used by those not allowed to see it. We use a variety of security measures and technologies to help protect your personal information. We carefully choose service providers to work with, and check they have security measures and technologies in place to protect your personal information. We do not allow our service providers and suppliers to use your personal information for their own purposes.

We include appropriate organizational and technical measures to protect your data including but not limited to encryption, anonymization, password protection, access control, inclusion of contractual obligations.

How will we update this Policy?

We are constantly working to develop new services. We may also change our practices over time as our business and technology evolve, and this may involve changes to the ways in which we collect, process and use your information. As a result, we may amend this Privacy Policy from time to time.

If we materially change our Privacy Policy, we will take steps to inform you of the change. We may do this through email, SMS, notices on our websites or other means (or a combination of these means). If you continue to use our websites, applications, and online services after the date any revised Privacy Policy comes into effect, you will be deemed to have read and agreed to the revised Privacy Policy. This privacy policy was last updated November 6th, 2024.

Human Resources Information

RateGain collects certain personally identifiable information about the organization’s employees, which RateGain uses solely in the context of the employment relationship. Information about RateGain’s employees may also be shared with RateGain entities or third-party service providers (such as RateGain’s benefits providers, ESOP, Insider Tool) solely in the context of the employment relationship. To facilitate this processing, employee data may be transmitted to countries outside the region where the employee resides. For example, data for an employee in the EU may be processed in India and the US., which would require transmittal of the data outside the employee’s country and region of residence.

With respect to EU employee data, RateGain commits to resolve complaints about its collection or use of its EU employees’ personal information in accordance with local regulations. EU employees should first contact the human resources department if they have questions or complaints about RateGain’s application of the EU-US DPF Principles to their personally identifiable information. If RateGain does not provide timely acknowledgment or resolution of a question or complaint, an employee may contact the EU-US DPF dispute resolution panel established by the EU data protection authorities. RateGain commits to cooperate with the dispute resolution panel and to comply with the advice given by the panel with regard to human resources data transferred to RateGain from the EU in the context of the employment relationship.

Data Privacy Framework organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Rategain Technologies Inc. to your question or complaint, please contact the independent recourse mechanism listed below.

HR Recourse Mechanism

• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• EU Data Protection Authorities (DPAs)
• UK Information Commissioner’s Office (ICO)

Non-HR Recourse Mechanism

• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• TRUSTe Dispute Resolution
• EU Data Protection Authorities (DPAs)

Appropriate statutory body with jurisdiction to investigate any claims against Rategain Technologies Inc. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission.

Dispute and Liability

RateGain commits to resolve complaints about our collection or use of your personal information under the EU-US DPF Principles. RateGain is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and is liable in cases of onward transfers to third parties. Any individual with inquiries or complaints regarding our privacy policy may contact RateGain via the email address or mailing address listed at the end of this privacy policy.

In compliance with the EU-US DPF Principles, RateGain Technologies Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our EU-US DPF policy should first contact

RateGain Technologies Inc. at:
Address: 105 Decker Court,
Suite 540, Irving, TX 75062, USA
E-mail: privacy@rategain.com

or

RateGain Travel Technologies Ltd.
Address : Club-125,
Plot No A – 3, 4 & 5, Tower A, 4th Floor,
Sector – 125, Noida 201301,
Uttar Pradesh, India
E-mail: privacy@rategain.com

or 

For Myhotelshop GmbH

SLK Compliance Services GmbHm Christian Krösch,
Königsbrücker Str. 76, 01099 Dresden,
+49 351 89676360

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

For more information on the circumstances under which binding arbitration can be invoked for complaints regarding EU-US DPF compliance, please visit:

https://www.dataprivacyframework.gov/EU-US-Framework

Other important information

Our sites contain links to other websites not owned by RateGain. We do not control the content or privacy practices of those sites.

Our websites and offerings are directed to people in their business or professional capacities.

They are not intended for children under 18 years of age. We do not knowingly solicit information online from, or market online to, children less than 18 years of age.

If you have a reason to believe that such data has been collected and processed by the RateGain, please inform us at privacy@ratgain.com.

We process personal information on the basis of your consent, our legitimate interest and performance of a contract. You have the right to withdraw consent at any time, but this will not affect any prior processing of your personal information.

How can you contact us about this Policy?
For questions regarding this Privacy Policy, practices of the website, or any other privacy issue, please send an email to our Data Protection Officer at

datenschutz@slk-compliance.de for Myhotelshop GmbH, Germany

privacy@rategain.com for all other RateGain entities