Privacy Policy

famlo (www.famlo.in)

1. Introduction

This Privacy Policy (“Policy”) describes how famlo (“famlo”, “we”, “us”, or “our”) collects, uses, stores, processes, discloses, transfers, and protects the personal data of users who access or use our website at www.famlo.in, our mobile application (if any), and any related services, features, content, dashboards, or applications offered by us (collectively, the “Platform”).

famlo is an online travel marketplace that enables individuals (“Hosts”) to list their residential properties as homestays and assists Hosts in obtaining the necessary legal registrations and approvals for operating such homestays. The Platform also enables travellers and guests (“Guests” or “Users”) to discover, book, and pay for homestay accommodations and to engage with registered local companions (“Hommis”), who provide guided walking or vehicle-based tours and city-exploration services. Hosts are also provided with a dashboard to manage their listings, bookings, availability, pricing, and communications.

This Policy is published in compliance with: (i) the Digital Personal Data Protection Act, 2023 (“DPDP Act”); (ii) the Information Technology Act, 2000, and the rules made thereunder, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”); (iii) the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Rules”); and (iv) the Consumer Protection (E-Commerce) Rules, 2020.

By accessing, browsing, registering on, or otherwise using the Platform, you confirm that you have read, understood, and agree to be bound by this Policy and our Terms of Service. If you do not agree with any part of this Policy, you must immediately discontinue use of the Platform.

2. Applicability and Scope

This Policy applies to all Users of the Platform, whether registered or unregistered, and to all personal data collected by famlo through the Platform, including data collected from Hosts, Guests, Hommis, browsers, prospective customers, and any third parties whose data is shared with us by the foregoing categories of Users (such as travel companions).

This Policy does not govern the privacy practices of any third-party websites, applications, or services that may be linked to or accessed through the Platform. We are not responsible for the privacy practices of such third parties, and Users are advised to review the privacy policies of such third parties separately.

3. Definitions

• “Data Fiduciary” shall have the same meaning as ascribed to it under the DPDP Act, and refers to famlo, which alone or in conjunction with other persons determines the purpose and means of processing of personal data.
• “Data Principal” shall have the same meaning as ascribed to it under the DPDP Act, and refers to the individual to whom the personal data relates.
• “Personal Data” means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.
• “Sensitive Personal Data or Information” (“SPDI”) shall have the meaning ascribed under Rule 3 of the SPDI Rules, including financial information, passwords, biometric information, physical/physiological information, and identity-document information.
• “Processing” means any operation or set of operations performed on personal data, including collection, recording, organisation, structuring, storage, use, retrieval, disclosure, alignment, restriction, erasure, or destruction.

4. Information We Collect

We collect personal data and other information from Users in the following categories. The specific data collected depends on the nature of your interaction with the Platform (i.e., whether you are a Guest, a Host, a Hommi, or a casual visitor).

4.1 Account and Registration Data

• Full name (first name and surname);
• Email address;
• Mobile number (with country code);
• Date of birth (to verify that you are at least 18 (eighteen) years of age);
• Password (stored in encrypted/hashed form);
• Profile photograph (optional);
• Gender (optional);
• Residential or correspondence address (where required for billing or compliance).

4.2 Host Identity and KYC Data

If you register as a Host or list a property on the Platform, we additionally collect the following “Sensitive Personal Data” and identification information for the purposes of identity verification, regulatory compliance, anti-fraud screening, tax reporting, and assistance in obtaining homestay registrations and approvals:

• Government-issued photo identification (Aadhaar, PAN, Passport, Voter ID, or DL);
• PAN details for TDS reporting and GST compliance;
• Proof of ownership or legal right to list the property;
• Photographs of the property and its amenities;
• Bank account details for payout disbursement;
• Correspondence with municipal, tourism, or other regulatory authorities;
• Selfie or live-photograph for identity matching.

4.3 Booking, Stay and Travel Companion Data

• Booking details and property selected;
• Names and IDs of travel companions (where required);
• Special requests, dietary preferences, or accessibility requirements;
• Reviews, ratings, and content posted by you;
• Communications between Users exchanged through the Platform.

4.4 Payment Information

famlo does not directly store full payment-card numbers or net-banking credentials. Payments are processed by Razorpay (PCI-DSS certified). We may retain Transaction IDs, amount, status, and billing details.

4.5 Location Data

With your opt-in consent, we collect precise geolocation data to provide nearby discovery and tour guidance. You may withdraw this consent at any time.

4.6 Device, Technical and Usage Data

We automatically collect IP addresses, device identifiers, browser types, and usage patterns for analytics and fraud prevention.

5. Purposes for Which We Process Your Data

• To operate, authenticate, and maintain your account;
• To facilitate bookings and communications between Guests, Hosts, and Hommis;
• To verify identities and perform background checks;
• To assist Hosts in obtaining regulatory registrations and approvals;
• To process payments, payouts, and taxes;
• To provide customer support and resolve disputes;
• To detect, prevent, and investigate illegal or harmful activities;
• To comply with applicable laws and regulatory requests.

6. Legal Basis for Processing

In accordance with the DPDP Act, we process your personal data on one or more of the following legal bases: Consent, Performance of Contract, Legitimate Uses (Section 7 of the DPDP Act), and Legal Obligations.

7. Sharing and Disclosure of Your Personal Data

famlo does not sell your personal data. We share it with:

• Hosts, Guests, and Hommis to facilitate bookings;
• Payment Service Providers (Razorpay);
• Service Providers and Technology Vendors;
• Government and Law-Enforcement Authorities (when required by law);
• Professional Advisors (auditors, lawyers).

8. Data Retention

We retain data only as long as necessary. Financial and KYC records may be retained for 7-8 years to comply with Indian taxation and AML laws.

9. Your Rights as a Data Principal

Under the DPDP Act, you have the right to: Access your data summary, request Correction/Erasure, seek Grievance Redressal, Nominate an individual, and Withdraw Consent.

10. Children’s Personal Data

The Platform is not intended for individuals under 18. We do not knowingly collect data from children without verifiable parental consent.

11. Marketing and Promotional Communications

You may opt out of marketing emails at any time. We will still send transactional emails related to your bookings.

12. Cookies and Similar Technologies

We use cookies for essential functionality, performance analytics, and marketing. You can manage preferences via your browser settings.

13. Data Security

We implement industry-standard safeguards including TLS encryption, data-at-rest encryption, and regular security audits.

14. Third-Party Links and Integrations

This policy does not apply to third-party sites linked from our Platform. Please review their policies separately.

15. Data Storage Location and Cross-Border Transfers

Currently, all data is stored on servers within India. We do not transfer personal data outside India.

16. Changes to this Policy

We may update this policy periodically. material changes will be notified via email or in-app notice.

17. Contact Us

Email: hello@famlo.in | Registered Office: TISC IIT Jodhpur

18. Grievance Officer

Name: Aryan Krishan (Founder)

Email: aryan@famlo.in

Address: TISC IIT Jodhpur

19. Governing Law and Jurisdiction

This Policy is governed by Indian law. Disputes are subject to the exclusive jurisdiction of courts at Hisar, Haryana, India.

20. Acknowledgement and Consent

By using the Platform, you acknowledge that you have read and consent to this Privacy Policy.