Indulge Global Privacy Notice
Annexure to the Membership Terms & Conditions
Pricetime Technologies Private Limited, 1-65/123, Amar Co-operative Society, Madhapur, Hyderabad, Rangareddy, Telangana – 500081 (“Indulge”, “we”) is the Data Fiduciary for the personal data described in this notice. This is a standalone notice explaining how we process personal data. It is also annexed to, and is applicable together with, the Membership Terms & Conditions. We send it to you when you join. Our Privacy Policy is at https://indulge.global/privacy-policy and in our App.
This notice is available in English and, on request, in any language listed in the Eighth Schedule to the Constitution of India. Ask in our App or on WhatsApp before you accept.
Who This Covers
Members, their guests and family whose details you give us for a booking, recipients of gifts you send through us, and your use of indulge.global and our App.
How You Accept
You accept this notice and the Membership Terms & Conditions when you tick the consent checkbox and sign this document electronically. We send you the e-signature link on WhatsApp. That single Acceptance is your consent to the processing described below for the Membership Purposes: administering your membership; handling your requests, bookings and purchases; maintaining your profile, preferences and service history and using them, including through AI-assisted tools, to personalise your concierge assistance; communicating with you about your membership; sharing necessary details with Suppliers; payments and records; security and misuse prevention; grievances and disputes.
Marketing communications and public-facing use of your photographs, videos, testimonials or name are not covered by your Acceptance. Before any such use we will give you a separate notice and ask for your consent, which you may refuse without affecting your membership. We do not share your personal data with partners or other third parties for their own marketing.
What We Collect and Why
Name, phone, email, company, message. Why: To onboard you, maintain your member profile, provide your services and, after your membership ends, keep minimum records (see Retention and Erasure). Basis: Your consent through your Acceptance. Kept for: While your membership is active and up to 3 years after it ends, unless you ask us to erase it sooner (see Retention and Erasure).
Membership and billing details, payment status (card details are held by our payment processor, not by us). Why: Membership administration, invoicing, payments, accounting and dispute handling. Basis: Your consent through your Acceptance, and compliance with tax and accounting laws. Kept for: While your membership is active; invoices and accounting records for the period required by tax and company law.
Booking details: itineraries, preferences, dietary needs, special requests. Why: To arrange restaurants, travel, events, gifts, purchases and other services you request; remember your preferences and past bookings; provide proactive and personalised service; and, after your membership ends, keep minimum records (see Retention and Erasure). Basis: Your consent through your Acceptance, and information you voluntarily provide for a specific request (a legitimate use under Section 7(a), DPDP Act). Kept for: While your membership is active and up to 3 years after it ends, unless you ask us to erase it sooner. Preferences are erased within 90 days after your membership ends.
Identity and travel documents (e.g. passport, visa) and any health or accessibility information you choose to share. Why: Only where required for a specific booking or service, and shared only with the relevant Supplier or service provider. Basis: Your consent through your Acceptance for that booking; sharing this information is your choice. Kept for: Only as long as needed for the booking or service, then erased, unless the law requires us to keep it.
Guest, family and gift-recipient details you give us. Why: To fulfil bookings or services you request for those guests or family members, or to deliver gifts you send. Basis: Information provided for the specific booking, with notice to the guest where required; for a child, or a person with a disability who has a lawful guardian, the verifiable consent of a parent or lawful guardian. Kept for: As long as needed for the booking and your service history, subject to Retention and Erasure below.
Chats, calls (which may be recorded), app usage and device data. Why: Service delivery, quality, security, dispute handling and keeping a record of service interactions, including to keep minimum records (see Retention and Erasure) after your membership ends. Basis: Your consent through your Acceptance. Kept for: While your membership is active and up to 3 years after it ends; processing logs for at least one year as required by law. Booking details inside chats follow the booking approach above, and identity or health documents follow the identity-document approach above.
E-signature records: your name, email, mobile number, signature and the signed copy of this document. The e-signature platform also adds a standard signing record with the date, time, IP address and device type of each signing step. Why: We use these records to show your Acceptance and your consent, as the law requires. Basis: Compliance with law, and to establish or defend legal claims. Kept for: While your membership is active and up to 3 years after it ends, or for a longer period if applicable law requires it.
App and website usage through analytics and crash-reporting tools. Why: To keep the App and Website working and secure and to fix problems. Basis: Your consent through your Acceptance; any non-essential cookies on our Website are used only with your separate cookie consent. Kept for: As long as needed for these purposes, and logs for at least one year as required by law.
Marketing communications (only with separate consent). Why: To send you curated offers, events and invitations. Basis: Your separate consent, requested with its own notice before any marketing is sent. Kept for: Until you withdraw that consent.
Photos, videos, testimonials and related content. Why: To record and support your Indulge experiences and, only after giving you a separate notice and obtaining your consent for that content, to use it in marketing, promotional, editorial, social-media, advertising, public-relations and brand communications. Basis: Your Acceptance for internal service records; your separate consent, given after a separate notice, for any public-facing use. Kept for: Internal records as for your service history; public-facing use until you withdraw that consent.
How We Use Your Data
We use personal data to manage membership, billing and bookings; remember your preferences and service history; provide proactive and personalised concierge assistance, including through AI-assisted tools; communicate with you about your membership and requests; maintain service quality and security; prevent misuse; handle disputes and grievances; keep minimum records (see Retention and Erasure) for up to 3 years after your membership ends; and comply with law. Only after giving you a separate notice and obtaining your consent do we send marketing communications or use content featuring you in public-facing media. We use anonymised information, not your identifiable data, to improve our internal AI-assisted systems.
Who We Share It With
Hotels, airlines, venues, restaurants, retailers and brands, couriers, event, home-service and wellness providers and other Suppliers you ask us to deal with, limited to what each booking or service needs. Our Data Processors, including cloud, CRM, messaging (including WhatsApp), e-signature, payments, analytics and AI tools, process data on our instructions under contract. Where a third party acts independently as a Data Fiduciary, its own privacy notice and legal obligations apply. We may disclose data where required or authorised by law. On request, we will tell you the identities of the Data Fiduciaries and Data Processors with whom your data has been shared. We do not sell your data.
Where It Goes
Many bookings and purchases are abroad, so Supplier data may be sent outside India to complete your request. Our service providers may also process or store data outside India. We do so subject to applicable law, including any restrictions notified by the Government of India.
Your Choices and Withdrawal
You can withdraw any consent at any time. It is as easy as when you gave it. Send a message on the WhatsApp chat where we sent you this document. In the message, tell us which consent you withdraw. For example: “I withdraw my consent for marketing messages.” You do not need to give a reason or complete a form. You can also make a request in our App or send an email to ethan@indulge.global. We will tell you when we record your withdrawal.
We will act without undue delay, stop processing the personal data concerned and require our Data Processors to do the same, and complete applicable deletion or anonymisation, by us and by our Data Processors, as soon as reasonably possible. Where there is no active or pending service, booking, request, transaction, grievance or other lawful purpose requiring the relevant personal data to be retained or processed, we will ordinarily complete such deletion or anonymisation before the expiry of 90 days from receiving your request and, in any event, within 90 days, or sooner where applicable law requires.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent for the Membership Purposes, we may be unable to continue Services that depend on the relevant data. You may also manage your consent through a Consent Manager registered with the Data Protection Board of India, once such services are available.
Your Rights
You have the right to: obtain a summary of your personal data, our processing activities, and the identities of those we have shared it with; have your data corrected, completed, updated or erased; withdraw consent; have your grievances redressed; and nominate one or more individuals to exercise your rights in the event of your death or incapacity.
To withdraw consent, send us a WhatsApp message. Tell us which consent you withdraw. You do not need a form or a reason. You can also make a request in our App or send an email to ethan@indulge.global. To request erasure, exercise any other right or raise a grievance, raise a request in our App or email ethan@indulge.global. To nominate someone, or to change or cancel a nomination, raise a request in our App or email ethan@indulge.global with your nominee’s name and contact details. When emailing, please write from your registered email address. We use your registered mobile number or email address to identify you. This notice, and the means to make each of these requests, are available on our website at www.indulge.global and in our App.
Grievance Officer
Ethan, Grievance Officer, Indulge Global (Pricetime Technologies Private Limited), H. No. 149, Indulge House, Karkachoval, Bardez, Revora, North Goa, Goa – 403513. Email: ethan@indulge.global.
We will resolve your grievance within one month after we receive it. If your grievance is not resolved to your satisfaction, you may, after exhausting our grievance process, file a grievance with the Data Protection Board of India online, through the Board’s portal or mobile application.
Retention and Erasure
We keep your profile, preferences and service history for as long as your membership continues and keep the minimum records in Section 22.8 of the Terms for up to 3 years after your membership ends, and longer only where retention is required by law, subject to applicable law and your rights.
Where there is no active or pending service, booking, request, transaction, grievance or other lawful purpose requiring the relevant personal data to be retained or processed, we will erase or anonymise the relevant personal data as soon as reasonably possible. Where deletion or anonymisation follows a valid erasure request or withdrawal of consent, we will ordinarily complete it before the expiry of 90 days from receiving the request and, in any event, within 90 days, or sooner where applicable law requires.
We may retain personal data where required or authorised by law, including where necessary to establish, exercise or defend legal claims. Where information is lawfully retained, we restrict its use to the purpose for which retention remains lawful. Anonymised information that can no longer identify you may be retained.
Security, Breaches, Children and Changes
We use reasonable security safeguards, including encryption or tokenisation where appropriate, access controls, monitoring and backups. If a personal data breach occurs, we will inform each affected member and every other affected individual, including guests, without delay. Our notice will explain what happened, its likely impact on you, the steps we have taken, the steps you can take to protect yourself, and who to contact. We will also inform the Data Protection Board of India, with a detailed report within 72 hours of becoming aware of it. Membership is for adults (18+). We do not knowingly process the personal data of children, or of persons with a disability who have a lawful guardian, except as permitted by law, including permitted guest bookings with the verifiable consent of a parent or lawful guardian, and we do not use children’s data for marketing, tracking or targeted advertising. We will notify you of material changes to this Privacy Notice and obtain any new consent required by law before processing for a new purpose.
Annexure to the Membership Terms & Conditions
Pricetime Technologies Private Limited, 1-65/123, Amar Co-operative Society, Madhapur, Hyderabad, Rangareddy, Telangana – 500081 (“Indulge”, “we”) is the Data Fiduciary for the personal data described in this notice. This is a standalone notice explaining how we process personal data. It is also annexed to, and is applicable together with, the Membership Terms & Conditions. We send it to you when you join. Our Privacy Policy is at https://indulge.global/privacy-policy and in our App.
This notice is available in English and, on request, in any language listed in the Eighth Schedule to the Constitution of India. Ask in our App or on WhatsApp before you accept.
Who This Covers
Members, their guests and family whose details you give us for a booking, recipients of gifts you send through us, and your use of indulge.global and our App.
How You Accept
You accept this notice and the Membership Terms & Conditions when you tick the consent checkbox and sign this document electronically. We send you the e-signature link on WhatsApp. That single Acceptance is your consent to the processing described below for the Membership Purposes: administering your membership; handling your requests, bookings and purchases; maintaining your profile, preferences and service history and using them, including through AI-assisted tools, to personalise your concierge assistance; communicating with you about your membership; sharing necessary details with Suppliers; payments and records; security and misuse prevention; grievances and disputes.
Marketing communications and public-facing use of your photographs, videos, testimonials or name are not covered by your Acceptance. Before any such use we will give you a separate notice and ask for your consent, which you may refuse without affecting your membership. We do not share your personal data with partners or other third parties for their own marketing.
What We Collect and Why
Name, phone, email, company, message. Why: To onboard you, maintain your member profile, provide your services and, after your membership ends, keep minimum records (see Retention and Erasure). Basis: Your consent through your Acceptance. Kept for: While your membership is active and up to 3 years after it ends, unless you ask us to erase it sooner (see Retention and Erasure).
Membership and billing details, payment status (card details are held by our payment processor, not by us). Why: Membership administration, invoicing, payments, accounting and dispute handling. Basis: Your consent through your Acceptance, and compliance with tax and accounting laws. Kept for: While your membership is active; invoices and accounting records for the period required by tax and company law.
Booking details: itineraries, preferences, dietary needs, special requests. Why: To arrange restaurants, travel, events, gifts, purchases and other services you request; remember your preferences and past bookings; provide proactive and personalised service; and, after your membership ends, keep minimum records (see Retention and Erasure). Basis: Your consent through your Acceptance, and information you voluntarily provide for a specific request (a legitimate use under Section 7(a), DPDP Act). Kept for: While your membership is active and up to 3 years after it ends, unless you ask us to erase it sooner. Preferences are erased within 90 days after your membership ends.
Identity and travel documents (e.g. passport, visa) and any health or accessibility information you choose to share. Why: Only where required for a specific booking or service, and shared only with the relevant Supplier or service provider. Basis: Your consent through your Acceptance for that booking; sharing this information is your choice. Kept for: Only as long as needed for the booking or service, then erased, unless the law requires us to keep it.
Guest, family and gift-recipient details you give us. Why: To fulfil bookings or services you request for those guests or family members, or to deliver gifts you send. Basis: Information provided for the specific booking, with notice to the guest where required; for a child, or a person with a disability who has a lawful guardian, the verifiable consent of a parent or lawful guardian. Kept for: As long as needed for the booking and your service history, subject to Retention and Erasure below.
Chats, calls (which may be recorded), app usage and device data. Why: Service delivery, quality, security, dispute handling and keeping a record of service interactions, including to keep minimum records (see Retention and Erasure) after your membership ends. Basis: Your consent through your Acceptance. Kept for: While your membership is active and up to 3 years after it ends; processing logs for at least one year as required by law. Booking details inside chats follow the booking approach above, and identity or health documents follow the identity-document approach above.
E-signature records: your name, email, mobile number, signature and the signed copy of this document. The e-signature platform also adds a standard signing record with the date, time, IP address and device type of each signing step. Why: We use these records to show your Acceptance and your consent, as the law requires. Basis: Compliance with law, and to establish or defend legal claims. Kept for: While your membership is active and up to 3 years after it ends, or for a longer period if applicable law requires it.
App and website usage through analytics and crash-reporting tools. Why: To keep the App and Website working and secure and to fix problems. Basis: Your consent through your Acceptance; any non-essential cookies on our Website are used only with your separate cookie consent. Kept for: As long as needed for these purposes, and logs for at least one year as required by law.
Marketing communications (only with separate consent). Why: To send you curated offers, events and invitations. Basis: Your separate consent, requested with its own notice before any marketing is sent. Kept for: Until you withdraw that consent.
Photos, videos, testimonials and related content. Why: To record and support your Indulge experiences and, only after giving you a separate notice and obtaining your consent for that content, to use it in marketing, promotional, editorial, social-media, advertising, public-relations and brand communications. Basis: Your Acceptance for internal service records; your separate consent, given after a separate notice, for any public-facing use. Kept for: Internal records as for your service history; public-facing use until you withdraw that consent.
How We Use Your Data
We use personal data to manage membership, billing and bookings; remember your preferences and service history; provide proactive and personalised concierge assistance, including through AI-assisted tools; communicate with you about your membership and requests; maintain service quality and security; prevent misuse; handle disputes and grievances; keep minimum records (see Retention and Erasure) for up to 3 years after your membership ends; and comply with law. Only after giving you a separate notice and obtaining your consent do we send marketing communications or use content featuring you in public-facing media. We use anonymised information, not your identifiable data, to improve our internal AI-assisted systems.
Who We Share It With
Hotels, airlines, venues, restaurants, retailers and brands, couriers, event, home-service and wellness providers and other Suppliers you ask us to deal with, limited to what each booking or service needs. Our Data Processors, including cloud, CRM, messaging (including WhatsApp), e-signature, payments, analytics and AI tools, process data on our instructions under contract. Where a third party acts independently as a Data Fiduciary, its own privacy notice and legal obligations apply. We may disclose data where required or authorised by law. On request, we will tell you the identities of the Data Fiduciaries and Data Processors with whom your data has been shared. We do not sell your data.
Where It Goes
Many bookings and purchases are abroad, so Supplier data may be sent outside India to complete your request. Our service providers may also process or store data outside India. We do so subject to applicable law, including any restrictions notified by the Government of India.
Your Choices and Withdrawal
You can withdraw any consent at any time. It is as easy as when you gave it. Send a message on the WhatsApp chat where we sent you this document. In the message, tell us which consent you withdraw. For example: “I withdraw my consent for marketing messages.” You do not need to give a reason or complete a form. You can also make a request in our App or send an email to ethan@indulge.global. We will tell you when we record your withdrawal.
We will act without undue delay, stop processing the personal data concerned and require our Data Processors to do the same, and complete applicable deletion or anonymisation, by us and by our Data Processors, as soon as reasonably possible. Where there is no active or pending service, booking, request, transaction, grievance or other lawful purpose requiring the relevant personal data to be retained or processed, we will ordinarily complete such deletion or anonymisation before the expiry of 90 days from receiving your request and, in any event, within 90 days, or sooner where applicable law requires.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent for the Membership Purposes, we may be unable to continue Services that depend on the relevant data. You may also manage your consent through a Consent Manager registered with the Data Protection Board of India, once such services are available.
Your Rights
You have the right to: obtain a summary of your personal data, our processing activities, and the identities of those we have shared it with; have your data corrected, completed, updated or erased; withdraw consent; have your grievances redressed; and nominate one or more individuals to exercise your rights in the event of your death or incapacity.
To withdraw consent, send us a WhatsApp message. Tell us which consent you withdraw. You do not need a form or a reason. You can also make a request in our App or send an email to ethan@indulge.global. To request erasure, exercise any other right or raise a grievance, raise a request in our App or email ethan@indulge.global. To nominate someone, or to change or cancel a nomination, raise a request in our App or email ethan@indulge.global with your nominee’s name and contact details. When emailing, please write from your registered email address. We use your registered mobile number or email address to identify you. This notice, and the means to make each of these requests, are available on our website at www.indulge.global and in our App.
Grievance Officer
Ethan, Grievance Officer, Indulge Global (Pricetime Technologies Private Limited), H. No. 149, Indulge House, Karkachoval, Bardez, Revora, North Goa, Goa – 403513. Email: ethan@indulge.global.
We will resolve your grievance within one month after we receive it. If your grievance is not resolved to your satisfaction, you may, after exhausting our grievance process, file a grievance with the Data Protection Board of India online, through the Board’s portal or mobile application.
Retention and Erasure
We keep your profile, preferences and service history for as long as your membership continues and keep the minimum records in Section 22.8 of the Terms for up to 3 years after your membership ends, and longer only where retention is required by law, subject to applicable law and your rights.
Where there is no active or pending service, booking, request, transaction, grievance or other lawful purpose requiring the relevant personal data to be retained or processed, we will erase or anonymise the relevant personal data as soon as reasonably possible. Where deletion or anonymisation follows a valid erasure request or withdrawal of consent, we will ordinarily complete it before the expiry of 90 days from receiving the request and, in any event, within 90 days, or sooner where applicable law requires.
We may retain personal data where required or authorised by law, including where necessary to establish, exercise or defend legal claims. Where information is lawfully retained, we restrict its use to the purpose for which retention remains lawful. Anonymised information that can no longer identify you may be retained.
Security, Breaches, Children and Changes
We use reasonable security safeguards, including encryption or tokenisation where appropriate, access controls, monitoring and backups. If a personal data breach occurs, we will inform each affected member and every other affected individual, including guests, without delay. Our notice will explain what happened, its likely impact on you, the steps we have taken, the steps you can take to protect yourself, and who to contact. We will also inform the Data Protection Board of India, with a detailed report within 72 hours of becoming aware of it. Membership is for adults (18+). We do not knowingly process the personal data of children, or of persons with a disability who have a lawful guardian, except as permitted by law, including permitted guest bookings with the verifiable consent of a parent or lawful guardian, and we do not use children’s data for marketing, tracking or targeted advertising. We will notify you of material changes to this Privacy Notice and obtain any new consent required by law before processing for a new purpose.