Legal Document

Privacy Policy

We are committed to protecting your personal data. This policy explains what we collect, how we use it, and your rights as a user of our service.

Last updated: September 2026  |  Effective from: September 2026
Table of Contents
1

Who We Are

Resell Holidays is a service provided by Nattar Innovators LLP, registered under the Limited Liability Partnership Act, 2008. We operate the platform at www.resellholidays.com, which helps pre-owned holiday membership holders (Club Mahindra Holidays, Sterling Holidays) find buyers through our Assisted Resell Service.

Data Controller: Nattar Innovators LLP
2nd Floor, 7th Cross, North East Extension, Trichy – 620018, Tamil Nadu, India
📞 76 0380 0484  |  ✉ support@resellholidays.com

For all privacy-related queries, you may contact our team at support@resellholidays.com. We will respond within 7 business days.

2

What Data We Collect

We collect only the data necessary to provide our Assisted Resell Service. The categories of data we collect are:

Category Data Points Purpose
Identity First name, membership name To identify you and your membership
Contact Mobile number, email address, alternate contact, postal address OTP login, mandate delivery, transfer updates
Membership Membership type, category, membership number, expiry date, balance years/weeks, maintenance status Valuation calculation, buyer matching
Financial Agreed selling price, estimated value, ASF dues status Transaction processing, payment
Technical IP address, submission timestamp, session data, browser type Security, fraud prevention, audit trail
Behavioural Pages visited, time spent, actions taken on site Service improvement, analytics

We do not collect Aadhaar numbers, PAN numbers, bank account details, biometric data, or other sensitive information through the online valuation or seller mandate forms. Where such information is reasonably required for membership verification, the official transfer process, or payment to the seller, it may be collected separately and handled with appropriate confidentiality and security safeguards.

3

How We Collect Your Data

We collect your data through the following means:

✓ We never buy, rent, or obtain your data from third-party data brokers. All data we hold about you comes directly from your interactions with our platform.
4

How We Use Your Data

Your data is used strictly for the purposes for which it was collected:

We do not sell your personal information to third parties. We may use limited website and interaction data for analytics, advertising measurement and conversion tracking to understand how users find and use our service and to improve our marketing. Membership details, documents, selling price and other transaction information are not used for advertising profiling.
5

Data Sharing

We share your data only in the following limited circumstances:

  • Membership companies: Club Mahindra Holidays or Sterling Holidays Resorts Ltd receive only the information necessary to process the membership name transfer (e.g. your name, membership number, transfer request)
  • SMS service providers: Your mobile number is shared with our OTP delivery partner (SAP Teleservices or equivalent) solely to deliver the one-time password
  • Hosting and infrastructure: Our web hosting provider (Hostinger) stores your data securely as part of hosting our platform — they are contractually bound to protect your data
  • Legal authorities: We may disclose your data to law enforcement or regulatory authorities if required by a valid court order or legal obligation under Indian law
We do not disclose your agreed selling price, direct contact details, or personal information to prospective buyers except where reasonably necessary for an agreed transaction, required for the official membership transfer process, or required by law. We limit any such disclosure to information necessary for completing the transaction.

We do not share your data with any marketing companies, data brokers, insurance companies, or unrelated third parties.

6

Data Storage & Security

Your data is stored on secure servers hosted by Hostinger, located within their global infrastructure. We implement the following security measures to protect your data:

  • Encrypted transmission: All data between your browser and our server is transmitted over HTTPS (TLS encryption)
  • OTP security: One-time passwords are hashed using bcrypt before storage and are never stored in plain text
  • Session protection: Login sessions expire after 30 minutes of inactivity
  • CSRF protection: All forms are protected against Cross-Site Request Forgery attacks
  • Prepared statements: All database queries use PDO prepared statements to prevent SQL injection
  • Access control: Database access is restricted to authorised team members only
  • Rate limiting: OTP requests are rate-limited to 3 per 10 minutes per mobile number to prevent abuse
While we take all reasonable steps to secure your data, no internet transmission is 100% secure. We encourage you to use a secure network when accessing our platform.
7

Data Retention

We retain your data for as long as necessary to fulfil the purpose for which it was collected, and to comply with applicable legal obligations:

  • OTP session data: Deleted immediately after session expires (30 minutes)
  • Valuation records: Retained for 3 years from the date of submission for audit purposes
  • Mandate records: Retained for as long as reasonably necessary for transaction administration, record-keeping, dispute resolution, and compliance with applicable legal obligations
  • Completed transaction records: Retained for the period reasonably necessary to meet applicable tax, accounting, contractual, record-keeping, and other legal requirements
  • Incomplete or withdrawn mandates: Retained for 1 year then securely deleted

After the applicable retention period, your data is securely deleted or anonymised so that it can no longer be linked to you.

8

Your Rights

Subject to applicable law, including the Digital Personal Data Protection Act, 2023 and the rules thereunder as and when applicable, you may have rights regarding your personal data, including the following:

  • Right to access: You may request a copy of the personal data we hold about you
  • Right to correction: You may request correction of inaccurate or incomplete data
  • Right to erasure: You may request deletion of your data, subject to our legal retention obligations
  • Right to withdraw consent: You may withdraw your consent to data processing at any time — this does not affect the lawfulness of processing before withdrawal
  • Right to grievance redressal: You may raise a complaint about how we handle your data
To exercise any of these rights, please email us at support@resellholidays.com with the subject line "Privacy Request". We will respond within 7 business days. Please include your registered mobile number so we can identify your records.

Please note that certain rights may be limited where we are required to retain data by law, or where deletion would affect our ability to complete a transaction you initiated.

9

Cookies

Our platform uses a small number of essential cookies and browser session storage to function correctly:

  • PHP Session cookie: Used to maintain your login state after OTP verification. Expires when you close your browser or after 30 minutes of inactivity

We may use analytics and advertising measurement technologies, such as Google Analytics or Google Ads conversion tracking, to understand website usage, measure campaign performance and improve our service. We do not use membership details, documents, selling price or other transaction information for advertising profiling.

Our main WordPress website (www.resellholidays.com) may use standard WordPress cookies for its functionality. These are separate from the sell platform and do not affect your privacy in relation to the resale service.

10

Children's Privacy

Our services are intended for adults aged 18 years and above only. We do not knowingly collect personal data from children under 18.

If you believe a minor has submitted data through our platform without parental consent, please contact us immediately at support@resellholidays.com and we will promptly delete the data.

11

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make material changes, we will:

  • Update the "Last updated" date at the top of this page
  • Display a notice on our website for 30 days after a material change
  • Where feasible, notify registered users via their mobile number or email

Your continued use of our service after any update to this policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically.

The current version of this policy is always available at www.resellholidays.com/privacy-policy/

12

Contact for Privacy Queries

If you have any questions, concerns, or requests relating to this Privacy Policy or how we handle your personal data, please contact us through any of the following:

  • Email: support@resellholidays.com (subject: "Privacy Request")
  • Phone: 76 0380 0484 (Monday to Saturday, 10 AM – 6 PM IST)
  • Post: Nattar Innovators LLP, 2nd Floor, 7th Cross, North East Extension, Trichy – 620018

We are committed to resolving privacy concerns promptly and fairly. Where applicable under law, if you are not satisfied with our response, you may pursue the grievance or complaint mechanisms available under applicable data protection law.

Privacy Questions?

We take your privacy seriously. Reach out and we'll respond within 7 business days.

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