So Thank you for choosing to be part of our community at Westay Ltd, doing businessas Westay (“Westay,” “Westay Ltd” “Westay.com” “we,” “us,” or “our,”). We arecommitted to protecting your personal information and your right to privacy. If youhave any questions or concerns about our policy, or our practices with regards to yourpersonal information, please contact us at Help@westay.comWhen you visit our website http://www.westay.com, mobile application, Facebookapplication, and use our services, you trust us with your personal information. We takeyour privacy very seriously. In this privacy policy, we seek to explain to you in theclearest way possible what information we collect, how we use it and what rights youhave in relation to it. We hope you take some time to read through it carefully, as it isimportant. If there are any terms in this privacy policy that you do not agree with,please discontinue use of our Sites or Apps and our services.

This privacy policy applies to all information collected through our website (suchas http://www.westay.com), mobile application, Facebook

application, ("Apps"), and/or any related services, sales, marketing or events (we referto them collectively in this privacy policy as the "Services").

Please read this privacy policy carefully as it will help you make informed decisionsabout sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. DO WE USE GOOGLE MAPS?

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

8. HOW LONG DO WE KEEP YOUR INFORMATION?

PRIVACY POLICY

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. DATA BREACH

12. CONTROLS FOR DO-NOT-TRACK FEATURES

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

14. DO WE MAKE UPDATES TO THIS POLICY?

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when registering atthe Services or Apps, expressing an interest in obtaining information about us or ourproducts and services, when participating in activities on the Services or Apps orotherwise contacting us.

The personal information that we collect depends on the context of your interactionswith us and the Services or Apps, the choices you make and the products and featuresyou use. The personal information we collect can include the following:Publicly Available Personal Information. We might collect first name, maiden name,last name, and nickname; ID; passport number; phone numbers; emailaddresses; current and former address; social media; (driver's license number if youbook a car with us); Nationality; business phone number; and other similar data.

Personal Information Provided by You. We collect app usage; and other similar data.

Westay collects and uses information which you provide to us. When you make a TripReservation, you are asked for your name and email address. Depending on the TripReservation, we may also ask for your home address, telephone number, paymentinformation, date of birth, the names of any guests travelling with you and anypreferences (such as meal preferences and any mobility restrictions) you might havefor your Trip.

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Payment Data. We collect data necessary to process your payment if you makepurchases, such as your payment instrument number (such as a credit card number),and the security code associated with your payment instrument. All payment data isstored by https://www.ccavenue.com. You may find their privacy policy link(s)here: https://www.ccavenue.com/privacy.jsp

Social Media Login Data. We may provide you with the option to register using socialmedia account details, like your Facebook, Twitter or other social media account. Ifyou choose to register in this way, we will collect the Information described in thesection called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

All personal information that you provide to us must be true, complete and accurate,and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as IP address and/or browser and devicecharacteristics — is collected automatically when you visit our Services or Apps.

We automatically collect certain information when you visit, use or navigatethe Services or Apps. This information does not reveal your specific identity (like yourname or contact information) but may include device and usage information, such asyour IP address, browser and device characteristics, operating system, languagepreferences, referring URLs, device name, country, location, information about howand when you use our Services or Apps and other technical information. Thisinformation is primarily needed to maintain the security and operation ofour Services or Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similartechnologies.

Online Identifiers. We collect devices; applications; tools and protocols, such as IP(Internet Protocol) addresses; cookie identifiers, or others such as the ones used foranalytics and marketing; Radio Frequency Identification (RFID) tags; device'sgeolocation; and other similar data.

Personal data you give us about others

Of course, you might not simply be making a Trip Reservation for yourself. You may bedoing a Trip with other guests whose details you provide as part of the Trip Reservation, orPRIVACY POLICY

you may make a Trip Reservation on behalf of someone else. If you maintain Westay.comfor Business account, you can also create an address book to facilitate business travel, aswell as manage the bookings of others. In some cases, you can use Westay to shareinformation with others. This might take the form of forwarding a wish list or participatingin referral programs, but such information may only be used as described in the offeredinterface.

However, at this point we have to point out that it’s your responsibility to ensure that theperson or people you have provided personal data about are aware that you’ve done so,and have understood and accepted how Westay uses their information (as described inthis Privacy Statement).

Information collected through our Apps

In Short: We may collect information regarding your geo-location, mobile device, pushnotifications, and Facebook permissions when you use our apps.

If you use our Apps, we may also collect the following information:§ Geo-Location Information. We may request access or permission to and tracklocation-based information from your mobile device, either continuously orwhile you are using our mobile application, to provide location-based services.

If you wish to change our access or permissions, you may do so in your device'ssettings.

§ Mobile Device Access. We may request access or permission to certain featuresfrom your mobile device, including your mobile

device's calendar, camera, contacts, reminders, sensors, sms messages, socialmedia accounts, and other features. If you wish to change our access orpermissions, you may do so in your device's settings.

§ Mobile Device Data. We may automatically collect device information (such asyour mobile device ID, model and manufacturer), operating system, versioninformation and IP address.

§ Push Notifications. We may request to send you push notifications regardingyour account or the mobile application. If you wish to opt-out from receivingthese types of communications, you may turn them off in your device's settings.

§ Facebook Permissions. We by default access your Facebook basic accountinformation, including your name, email, gender, birthday, current city, andprofile picture URL, as well as other information that you choose to make public.

We may also request access to other permissions related to your account, suchas friends, checkins, and likes, and you may choose to grant or deny us accessPRIVACY POLICY

to each individual permission. For more information regarding Facebookpermissions, refer to the Facebook Permissions Reference page.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate businessinterests, the fulfillment of our contract with you, compliance with our legal obligations,and/or your consent.

We use personal information collected via our Services or Apps for a variety ofbusiness purposes described below. We process your personal information for thesepurposes in reliance on our legitimate business interests, in order to enter into orperform a contract with you, with your consent, and/or for compliance with our legalobligations. We indicate the specific processing grounds we rely on next to eachpurpose listed below.

We use the information we collect or receive:

§ To facilitate account creation and logon process. If you choose to link youraccount with us to a third party account (such as your Google or Facebookaccount), we use the information you allowed us to collect from those thirdparties to facilitate account creation and logon process for the performance ofthe contract. See the section below headed "HOW DO WE HANDLE YOURSOCIAL LOGINS" for further information.

§ To send you marketing and promotional communications. We and/or ourthird party marketing partners may use the personal information you send to usfor our marketing purposes, if this is in accordance with your marketingpreferences. You can opt-out of our marketing emails at any time (see the"WHAT ARE YOUR PRIVACY RIGHTS" below).

§ To send administrative information to you. We may use your personalinformation to send you product, service and new feature information and/orinformation about changes to our terms, conditions, and policies.

§ Fulfill and manage your orders. We may use your information to fulfill andmanage your orders, payments, returns, and exchanges made throughthe Services or Apps.

§ Deliver targeted advertising to you. We may use your information to developand display content and advertising (and work with third parties who do so)tailored to your interests and/or location and to measure its effectiveness.

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§ Administer prize draws and competitions. We may use your information toadminister prize draws and competitions when you elect to participate incompetitions.

§ Request Feedback. We may use your information to request feedback and tocontact you about your use of our Services or Apps.

§ To protect our Services. We may use your information as part of our efforts tokeep our Services or Apps safe and secure (for example, for fraud monitoringand prevention).

§ To enforce our terms, conditions and policies for Business Purposes, LegalReasons and Contractual.

§ To respond to legal requests and prevent harm. If we receive a subpoena orother legal request, we may need to inspect the data we hold to determine howto respond.

§ To manage user accounts. We may use your information for the purposes ofmanaging our account and keeping it in working order.

§ To deliver services to the user. We may use your information to provide youwith the requested service.

§ To respond to user inquiries/offer support to users. We may use yourinformation to respond to your inquiries and solve any potential issues youmight have with the use of our Services.

§ For other Business Purposes. We may use your information for other BusinessPurposes, such as data analysis, identifying usage trends, determining theeffectiveness of our promotional campaigns and to evaluate and improveour Services or Apps, products, marketing and your experience. We may useand store this information in aggregated and anonymized form so that it is notassociated with individual end users and does not include personal information.

We will not use identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provideyou with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:§ Consent: We may process your data if you have given us specific consent touse your personal information in a specific purpose.

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§ Legitimate Interests: We may process your data when it is reasonablynecessary to achieve our legitimate business interests.

§ Performance of a Contract: Where we have entered into a contract with you,we may process your personal information to fulfill the terms of our contract.

§ Legal Obligations: We may disclose your information where we are legallyrequired to do so in order to comply with applicable law, governmentalrequests, a judicial proceeding, court order, or legal process, such as inresponse to a court order or a subpoena (including in response to publicauthorities to meet national security or law enforcement requirements).

§ Vital Interests: We may disclose your information where we believe it isnecessary to investigate, prevent, or take action regarding potential violationsof our policies, suspected fraud, situations involving potential threats to thesafety of any person and illegal activities, or as evidence in litigation in whichwe are involved.

More specifically, we may need to process your data or share your personalinformation in the following situations:

Business Transfers. We may share or transfer your information in connection with,or during negotiations of, any merger, sale of company assets, financing, oracquisition of all or a portion of our business to another company.

Third-Party Advertisers. We may use third-party advertising companies to serveads when you visit the Services or Apps. These companies may use information aboutyour visits to our Website(s) and other websites that are contained in web cookies andother tracking technologies in order to provide advertisements about goods andservices of interest to you.

Affiliates. We may share your information with our affiliates, in which case we willrequire those affiliates to honor this privacy policy. Affiliates include our parentcompany and any subsidiaries, joint venture partners or other companies that wecontrol or that are under common control with us.

Business Partners. We may share your information with our business partners tooffer you certain products, services or promotions.

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Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offerwall allows third-party advertisers to offer virtual currency, gifts, or other items tousers in return for acceptance and completion of an advertisement offer. Such anoffer wall may appear in our mobile application and be displayed to you based oncertain data, such as your geographic area or demographic information. When youclick on an offer wall, you will leave our mobile application. A unique identifier, such asyour user ID, will be shared with the offer wall provider in order to prevent fraud andproperly credit your account.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: In certain circumstances, we’ll share your personal data with third parties.

The Trip Provider you booked: This one’s pretty crucial for what we do! In order tocomplete your Trip Reservation, we transfer relevant reservation details to the TripProvider you have booked. Depending on the Trip Reservation and the Trip Provider,this can include your name, contact details, payment details, the names of the gueststravelling with you and any preferences or other information you specified when youmade your Trip Reservation. If you have a query about your Trip, we may contact theTrip Provider and ask them to handle your request. Unless payment is made during thebook process via westay.com website, we will forward your credit card details to thebooked Trip Provider for further handling (assuming you’ve provided us with thosedetails during your booking process). In cases of reservation-related disputes, we mayprovide the Trip Provider with information about the reservation process as needed tohandle the dispute. This may include a copy of your reservation confirmation as proofthat a Trip Reservation was actually made.

Third-party service providers:

We use service providers, which are not part of the Westay.com corporate family, tosupport us in providing the westay.com services. These service providers providesupport services such as customer support; market research; fraud detection andprevention services, including anti fraud screening service.

Payment services. We use third parties to process payments, handle chargebacks orprovide billing collection services. When a chargeback is requested for your TripReservation by either you or by the holder of the credit card used to make yourreservation, we need to share certain reservation details with the payment serviceprovider and the relevant financial institution to handle the chargeback. This may alsoinclude a copy of your reservation confirmation or the IP address used to make yourreservation. We may share information with relevant financial institutions, if weconsider it strictly necessary for fraud detection and prevention purposes.

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marketing services. We share personal data with advertising partners, including youremail address, as part of marketing the Westay.com services via third parties (toensure that relevant advertisements are shown to the right audience). We strive to onlyshare email addresses in hashed form to enable the matching of your email addresswith an existing customer database so that your email address cannot be used forother purposes. For more information on personalised advertisement and yourchoices.

All service providers are required to continue to adequately safeguard your personaldata.

Competent authorities: We disclose personal data to law enforcement insofar as it isrequired by law or is strictly necessary for the prevention, detection or prosecution ofcriminal acts and fraud or if we are otherwise legally obliged to do so. We may need tofurther disclose personal data to competent authorities to protect and defend ourrights or properties, or the rights and properties of our business partners.

Business partners: We work with many business partners around the world. Thesebusiness partners distribute or advertise the Westay.com services, including theservices and products of our Trip Providers.

Also Allow Users to Connect to their Third-Party Accounts

Facebook account, Google account and apple account.

§ Functionality and Infrastructure Optimization

§ Invoice and Billing

§ Social Media Sharing and Advertising

§ User Account Registration and Authentication

§ Web and Mobile Analytics

§ Website Hosting

§ Website Testing

5. DO WE USE COOKIES AND OTHER TRACKING

TECHNOLOGIES?

PRIVACY POLICY

In Short: We may use cookies and other tracking technologies to collect and store yourinformation.

We may use cookies and similar tracking technologies (like web beacons and pixels) toaccess or store information. Specific information about how we use such technologiesand how you can refuse certain cookies is set out in our Cookie Policy.

6. DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. Youmay find the Google Maps APIs Terms of Service here. To better understand Google’sPrivacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms ofService. You agree to allow us to obtain or cache your location. You may revoke yourconsent at anytime.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social mediaaccount, we may have access to certain information about you.

Our Services or Apps offer you the ability to register and login using your third partysocial media account details (like your Facebook or Twitter logins). Where you chooseto do this, we will receive certain profile information about you from your social mediaprovider. The profile Information we receive may vary depending on the social mediaprovider concerned, but will often include your name, e-mail address, friends list,profile picture as well as other information you choose to make public. If you loginusing Facebook, we may also request access to other permissions related to youraccount, such as friends, check-ins, and likes, and you may choose to grant or deny usaccess to each individual permission.

We will use the information we receive only for the purposes that are described inthis privacy policy or that are otherwise made clear to you on the Services or Apps.

Please note that we do not control, and are not responsible for, other uses of yourpersonal information by your third party social media provider. We recommend thatyou review their privacy policy to understand how they collect, use and share yourPRIVACY POLICY

personal information, and how you can set your privacy preferences on their sites andapps.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposesoutlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for thepurposes set out in this privacy policy, unless a longer retention period is required orpermitted by law (such as tax, accounting or other legal requirements). No purpose inthis policy will require us keeping your personal information for longer than the periodof time in which users have an account with us.

When we have no ongoing legitimate business need to process your personalinformation, we will either delete or anonymize it, or, if this is not possible (forexample, because your personal information has been stored in backup archives), thenwe will securely store your personal information and isolate it from any furtherprocessing until deletion is possible.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 16 years ofage.

We do not knowingly solicit data from or market to children under 16 years of age. Byusing the Services or Apps, you represent that you are at least 16 or that you are theparent or guardian of such a minor and consent to such minor dependent’s use ofthe Services or Apps. If we learn that personal information from users less than 16years of age has been collected, we will deactivate the account and take reasonablemeasures to promptly delete such data from our records. If you become aware of anydata we have collected from children under age 16, please contact us atHelp@westay.com

10. WHAT ARE YOUR PRIVACY RIGHTS?

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In Short: In some regions, such as the European Economic Area, you have rights thatallow you greater access to and control over your personal information. You mayreview, change, or terminate your account at any time.

If you have questions or comments about your privacy rights, you may email usat help@westay.com.

Account Information

If you would at any time like to review or change the information in your account orterminate your account, you can:

■ Log into your account settings and update your user account.

■ Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete youraccount and information from our active databases. However, some information maybe retained in our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies bydefault. If you prefer, you can usually choose to set your browser to remove cookiesand to reject cookies. If you choose to remove cookies or reject cookies, this couldaffect certain features or services of our Services or Apps. To opt-out of interest-basedadvertising by advertisers on

our Services or Apps visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list atany time by clicking on the unsubscribe link in the emails that we send or bycontacting us using the details provided below. You will then be removed from themarketing email list – however, we will still need to send you service-related emailsthat are necessary for the administration and use of your account. To otherwise optout, you may:

■ Note your preferences when you register an account with the site.

■ Access your account settings and update preferences.

■ Contact us using the contact information provided.

11. DATA BREACH

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A privacy breach occurs when there is unauthorized access to or collection, use,disclosure or disposal of personal information. You will be notified about databreaches when Westay Ltd believes you are likely to be at risk or serious harm. Forexample, a data breach may be likely to result in serious financial harm or harm to yourmental or physical well-being. In the event that Westay Ltd becomes aware of asecurity breach which has resulted or may result in unauthorized access, use ordisclosure of personal information Westay Ltd will promptly investigate the matter andnotify the applicable Supervisory Authority not later than 72 hours after havingbecome aware of it, unless the personal data breach is unlikely to result in a risk to therights and freedoms of natural persons.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applicationsinclude a Do-Not-Track (“DNT”) feature or setting you can activate to signal yourprivacy preference not to have data about your online browsing activities monitoredand collected. No uniform technology standard for recognizing and implementing DNTsignals has been finalized. As such, we do not currently respond to DNT browsersignals or any other mechanism that automatically communicates your choice not tobe tracked online. If a standard for online tracking is adopted that we must follow inthe future, we will inform you about that practice in a revised version of this privacypolicy.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rightsregarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permitsour users who are California residents to request and obtain from us, once a year andfree of charge, information about categories of personal information (if any) wedisclosed to third parties for direct marketing purposes and the names and addressesof all third parties with which we shared personal information in the immediatelypreceding calendar year. If you are a California resident and would like to make such arequest, please submit your request in writing to us using the contact informationprovided below.

If you are under 18 years of age, reside in California, and have a registered accountwith the Services or Apps, you have the right to request removal of unwanted data thatPRIVACY POLICY

you publicly post on the Services or Apps. To request removal of such data, pleasecontact us using the contact information provided below, and include the emailaddress associated with your account and a statement that you reside in California.

We will make sure the data is not publicly displayed on the Services or Apps, butplease be aware that the data may not be completely or comprehensively removedfrom our systems.

14. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevantlaws.

We may update this privacy policy from time to time. The updated version will beindicated by an updated “Revised” date and the updated version will be effective assoon as it is accessible. If we make material changes to this privacy policy, we maynotify you either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this privacy policy frequentlyto be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email usat help@westay.com or by post to:

Westay Ltd

PO Box. 413281

Unit 208, Level 1 Gate Avenue,

DIFC, Dubai, United Arab Emirates

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to thepersonal information we collect from you, change that information, or delete it insome circumstances. To request to review, update, or delete your personalinformation, please submit a request form by sending us an email to Help@westay.com We will respond to your request within 30 days.