Please read this Privacy Policy (“Policy”) carefully. This contains important information about your rights and obligations. This Privacy Policy sets out the manner in which NORTHERN STAR TECHNOLOGY PRIVATE LIMITED (“NS”, “We”, “Us” or “Our”), the proprietor and owner of the “pneuma.club” website (“Website”), collects, uses, maintains, and discloses personal information collected from users (“User”, “You” or “Your”) of the Website. This Policy applies to all Website services and related services. The provisions of this Policy shall be read in consonance with the Terms of Use of the Website, and shall not be construed to override any provisions of the Terms of Use or any other contract between You and NS.

This Policy regulates Our use of Your personal information for Our own purposes, including how You interact with the Website and information submitted to Us in all interactions with Us or the Website. If You do not agree with this Policy, please stop using the Website and leave the Website. You may tell Us to delete any information collected until this point. Your continued access and use of the Website will mean Your acceptance of the provisions of this Policy.

NS may update and revise this Policy from time to time at its sole discretion. The revised Policy will be posted on the Website. NS will post a notice regarding modification of this Policy, and You will need to read the modified Policy. If You disagree to any of the changes to the Policy, please stop using or accessing the Website. Your continued use of the Website after posting of the revised Policy will mean that You agree with the changes and You will be bound by it.

Your use of the Website includes the collection of a variety of personal information from You. This is collected based on information provided by You to Us, from Your use of the Website and other sources. Please note that You are responsible for any personal information that You obtain, publish or share on behalf of any person with or through this Website and confirm that You have been duly authorised by such person to provide the information to Us. In the event that You are not authorised as indicated above, NS shall not be and specifically disclaims any liability for any information received from You pertaining to anyone else. The kind of information collected is detailed below:

• Personal information relating to Your account, involving Your full name, email address, date of birth, phone number, credit card details, registered frequent flyer program account details, points statements, payment information, information included in Your communications with us and identifying information provided to Us certifying Your identity.
• Information relating to Your activity on the Website, including but not limited to Your location, IP address, device IDs, clicks, scrolling, session heatmaps, timestamps, browsing times, transactions, load times, errors, internet service provider details, webpages visited prior as well as subsequent to accessing the Website, browser and platform type, browser language and related details.
• Information provided by You to Us when using the Website to make a booking with a Travel Service Provider [as defined in the Terms of Use] or procure the services / obtain an offering from a Financial Service Provider [as defined in the Terms of Use], including but not limited to names, addresses and their proofs, email addresses, phone numbers, itinerary details, financial information, verifying documents, location details, and other related details.
• Information You submit to Us through third party services, which may include but not be limited to Google and Apple, among others, for the purposes of creating an account on the Website and/or accessing accounts held with Travel Service Providers or Financial Service Providers.

Payments shall be made through third-party payment gateways as contracted by NS from time to time. Any such data or information collected by Us in this regard shall be collected solely for facilitating the processing of payments on the payment gateway or through the Travel Service Provider, and the same shall not be retained by Us following the successful completion of the payment. Any information collected by these third-parties shall be collected as per their own data collection and privacy policies and Your consent to such collection shall be governed by the respective third-party’s policies.

We may use information collected from You for the following purposes:

• To control Your access to the Website and services, to communicate with You, and customize Your experience by providing information that may be useful or interesting to You;
• To provide and operate the services offered on the Website, including but not limited to creating Your account, returning accurate results to queries inputted by You, accurately displaying Your miles/points/rewards balance, facilitating the processing of payments or responding to Your queries;
• To auto-renew Your subscription plan on the Website for You to be able to continuously avail Our services;
• To show You as accurate and true as possible information in response to a query that You have entered on the Website, such as providing a list of Paid Tickets [as defined in the Terms of Use] and Awards Tickets [as defined in the Terms of Use] for You to compare and choose from.
• To redirect You to a Travel Service Provider or Financial Service Provider with data collected by Us and enable
• To send administrative information, changes in account settings, changes to Our services or any updates pertaining to the services offered on the Website;
• To ensure that the services available on the Website are accessible and usable by You on Your specific device, such as for changing the way We display information to You depending on Your device type.
• To carry out Our internal business purposes, such as corporate transactions, audits, and data analysis, conduct research and analytics about Your use of the Website and interaction with Us, improve the Website and Our existing services, identify usage trends, assess the performance of Our advertisements, optimize Our advertising campaigns, and determine the effectiveness of Our communications;
• To provide customised advertising or promotional material regarding products, services, third party affiliations and related services, offers, programs and promotions of the Website;
• To ensure the security and integrity of the services of the Website;
• To analyse the use of the Website, and the people visiting and using the Website for improving the features of the Website. Further, the information provided by You may also be used to help Us in responding to Your requests and support needs more efficiently;
• To assist Our marketing partners by providing Your personal information to them for the purpose of promotional or marketing campaigns.
• To assist law enforcement agencies and ensure compliance with applicable laws and regulations if the disclosure of Your information is warranted by law or is warranted by any judicial proceeding by a court of competent jurisdiction.

We will not disclose any of Your information to any third parties except with regard to the following instances:

• Your payment information is required to be shared with NS’ designated payment gateway;
• Your personally identifying information is required to be shared with Travel Service Providers and Financial Service Providers in order to facilitate the provision of services on the Website and allow them to quickly populate the necessary details in order to allow You to make a booking;
• Your email address may be shared with email management and distribution tools, to ensure that information on the latest offers, points/miles/rewards related offers/schemes, or drops in prices or other promotional content that would be beneficial for You;
• Your data pertaining to the use of the Website may be shared with data aggregation and analytics software providers, to enable Us to effectively monitor and optimise the services available on the Website, as well as tracking tool providers, to allow Us to track how many times a User is redirected to a Travel Service Provider’s or Financial Service Provider’s website which would allow Us to build Our business with these third-party service providers;
• Your data may also be shared with agencies We hire to provide customer support services, so as to smooth over any issues You may face while utilising the services available on the Website;
• Your data may be stored on an online cloud storage, and therefore Your data may also be shared with cloud storage service providers and other essential IT support services;
• Your name and related data may be shared publicly on the Website’s blog where community discussions occur and information is exchanged relating to the services available on the Website as well as other general tips to maximise a User’s experience in making a booking on the Website;
• Your personal information may also be required to be shared with government agencies as required by law.

Data shared with Us or collected by Us will be primarily processed in India. NS may employ third party service providers situated in other countries to process Your data on NS’ behalf. The data protection regulations in India or such other countries mentioned previously may differ from those where You reside. However, subject to the local law, NS will apply appropriate technical, organisational and administrative safeguards and security measures to protect Your data.

Your data will be stored for as long as You continue to use the services of the Website, or for any extended period as required under applicable law. NS stores Your personal data only for as long as it is required, depending on the purpose for which it was collected, how long it will take to fulfil that purpose, and whether there is any specific reason or overriding legal obligation to retain it for a longer duration. Once the purpose is served, NS will either delete the information or anonymise it to ensure that it no longer contains any of Your personally identifiable information.

You may seek the deletion of Your data once You decide to stop using the services available on the Website. Where You have created an account with Us, You will be permitted to choose a ‘Delete Account’ option where You can delete Your account along with all data connected to it. Once selected, the data linked to Your account will be held for a retention period of 14 days, where if You log back in to Your account during these 14 days, the deletion process will be cancelled, and You will have to reselect the ‘Delete Account’ to delete Your account and all linked data. If You do not login to Your account within 14 days from initiating the deletion process, all Your account data and other linked data will be permanently deleted.

At any time during Your use of the Website and the services available on it, You may write to Us requesting Us to delete any part of Your data, and We shall comply with such request. However, Your request of deletion of such part of Your data may prevent Us from being able to provide a particular service, or a particular aspect of it, and You will not be able to continue using that particular service or particular aspect without re-entering such data or re-authorising NS to collect such data.

We set and access cookies on Your device to track the preferences and trends of Your searches in order to provide You with more personalized and improved services. You may reset the cookies to refuse such access by Us. However, in such a case, You may not be able to access some parts or features of the Website.

We may provide cookies for the following actions:

• Keeping You signed in
• Auto-populating Your details
• Keeping Your registered frequent flyer program details and credit card point details readily accessible
• Tracking Your redirection from the Website to the website of a Travel Service Provider’s or a Financial Service Provider’s website.
• Tracking analytical data of Your use of the Website, extending to performance, operation and effectiveness
• Tracking data for the effectiveness of Our marketing campaigns
• Security and risk analysis programs, fraud protection purposes, and in order to identify and prevent cyber attacks

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can modify Your browser setting to decline cookies if You prefer.

We understand and recognize that privacy on the internet is very important. We take all reasonable measures to protect the confidentiality of the information disclosed by You and will not disclose the information unless as provided in this Policy. We provide creation of password-protected accounts, which can be accessed only by You. We advise You to not share Your password with any other person and always log out before closing the browser window.

If You are a resident of California, in accordance with applicable Californian law, You have the right to request information from NS relating to NS’ sharing of Your information, including personal identifiable information, with marketing associates and other third parties. You may submit a request to NS through the contact email provided below in the Contact clause and receive the following information:

• The categories of information disclosed to third parties for the third parties’ marketing purposes during the preceding calendar year (determined according to the date of the request)
• The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then instances of the products or services marketed.

You are entitled to receive a copy of this information in a standardised format and the information will not be specific to You individually.

If you have any questions about this Privacy Policy or Your dealing with the Website or any of the services, please contact Us at hello@pneuma.club