1. General provisions
1.2. We designed the Policy to confirm you the compliance of services provided by AirAdvisor with the provisions of General Data Protection Regulation i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR") and other legislative acts regulating interactions with personal data of Internet users.
1.3. We respect personal data. Using services of AirAdvisor, you trust us with your personal information. And we doing our best to ensure the security of this data and, at the same time, giving you the opportunity to manage it.
1.4. Please note, the Policy applies to all personal data that you provide to us and which we collect on our own while you using services of AirAdvisor (including cookies).
1.5. With this Policy we want to tell you about:
- who we are;
- how we work with personal data;
- what personal data we collect;
- what is the purpose of processing personal data;
- where and why do we transfer personal data;
- how long do we keep personal data;
- what rights do you have as a subject of personal data;
- how we keep personal data confidential;
- how to contact us.
1.6. For us, the legal basis for the processing of personal data is, in accordance with Article 6 of the GDPR, separately or simultaneously:
- consent to the processing of your personal data and personal data of third parties, you are acting for and on behalf of, in order to provide our services;
- the need to execute a contract with you or third party, you are acting for and on behalf of.
1.7. The processing of a special category of personal data (for example, data concerning health) will be carried out only if there is appropriate consent for the processing of your personal data and personal data of third parties, you are acting for and on behalf of, and / or the need for carriers to provide special services related to the health of the passenger.
2. Consent to the processing of personal data
- accept terms of the Policy in full, without reserve and any amendments;
- are aware that collection of your personal data and personal data of the third parties you are acting for and on behalf of, as well as their processing using technical capabilities of AirAdvisor can be performed on this web site;
- give consent to collection and processing of all personal data you provide for the purposes set forth in the Policy;
- give consent to processing of special category of personal data (e.g. health information) related to you or third parties you are acting for and on behalf of, in the event of necessity of rendering special services directly associated with this category of personal data
- give consent to processing and trans-border transfer of your personal data and personal data of the third parties you are acting for and on behalf of, if required according to the service rendering terms;
- give consent to communication of personal data to the third parties for the purposes of performance of agreement terms and rendering appropriate AirAdvisor service;
- give consent to collection and storage of your personal data and personal data of the third parties you are acting for and on behalf of, without restriction on validity period, until you or the third party you are acting for and on behalf of submit a demand or request for termination of personal data processing and/or destruction thereof, and/or until the time of termination of the relationship initiated by AirAdvisor and/or otherwise in accordance with the provisions of the Policy and requirements of the legislation.
2.2. By accepting the terms of the Policy, you acknowledge that you are a capable person who has reached the age of 18.
2.4. When providing data about third parties you confirm that abovementioned third party is aware of the Policy provisions and he/she gives unlimited and unconditional consent to collection and processing of personal data in accordance with the terms of the Policy.
2.5. If you are using AirAdvisor service for and on behalf of the third parties (e.g. your clients), the information about these third parties you provide shall be collected and processed by AirAdvisor on the same terms as your own personal data are processed.
3. Personal data we collect and process
3.1. We receive and store all the information you provide via https://airadvisor.com website, communicate to our support division or transfer to AirAdvisor in whatever form and by whatever medium to the extent required for service rendering, improving of the service and fulfilment of contractual obligations towards you or the third parties you are acting for and on behalf of.
3.2. Abovementioned data include the following:
- information that can be used to identify a person using AirAdvisor service directly, in particular, surname, name, mobile phone number, e-mail address
- information that can be used to identify a passenger claiming a compensation, in particular, surname, name, date of birth, sex, nationality, mobile phone number, postal address, e-mail address;
- details of flight;
- details of identification documents;
- details of bank account;
- details of the documents needed to obtain compensation (e.g. booking reference);
- technical data, such as internet-protocol (IP) address used for Internet connection, your registration details, browser type and version, time zone, browser plug-in type and version, operating system and platform;
- profile details (settings, search history, booking and marketing history);
- data on your visit, clickstream and history of transitions from our site (inclusive of date and time), services you have been looking for or browsed, page response time, download failures, time spent on certain pages, information about activity on the page (e.g. scrolling, clicks, mouse overs), page transition methods;
- information communicated during telephone conversation, via e-mail, our website, social networks, support division, etc.;
- information required for conclusion or fulfilment of the agreement with you or with third parties you are acting for and on behalf of;
- information about activities involving you and us or third parties you are acting for and on behalf of;
- strictly necessary cookie-files of high importance, and cookie-files collected and send to Amplitude and Intercom in order to enable use of the tools thereof for the purpose of improvement of web site operation;
- other information you voluntarily leave on the website
3.3. If you do not want us to work with your personal data or personal data of third parties you are acting for and on behalf of, please do not provide us with such information.
3.4. We do not knowingly collect personal information from children under age 18. If you are under 18, do not use or provide any information on our Website or on or through our services. If we find out that the personal data is not submitted by one of the parents of the child (that is, a person under 18) or the legal guardian or the user directly authorized by them, we will immediately remove such data.
4.2. The information provided by the cookies is anonymous. We use it to simplify the use of our website due to the fact that it recognizes the user during his visit or during a re-session.
4.3. We inform you that you can block or delete cookies and limit their actions in the settings of your browser. The necessary actions for this in different browsers may vary. Please note that certain pages of our website are accessible only by using cookies. Disabling cookies may result in restricted access to our content and inadequate functionality of our website.
5. The purposes for which personal data will be used
5.1. We use your personal data and personal data of the third parties you are acting for and on behalf of for the purpose of full and high-quality rendering of services by AirAdvisor as stated in the Terms and Conditions.
5.2. We may also use personal data in order to provide you with quality answers or other information from the AirAdvisor based on your requests or requests from third parties you are acting for and on behalf of for.
5.3. Also, the purpose of processing personal data is to use them for marketing and advertising purposes, including direct marketing, market research, and statistics.
5.4 We also use personal data to continuously improve the AirAdvisor services, improve your experience of using our website https://airadvisor.com.
6. Transfer of personal data
6.1. Your data can be transferred to the third parties only for the purposes of proper rendering of AirAdvisor services that could not have been rendered without such transfering of your personal data or personal data of the third parties you are acting for and on behalf of. For example, personal data can be transferred to carriers for the purposes of claiming compensation.
6.2. In addition, we can furnish your personal data or personal data of the third parties you are acting for and on behalf of to AirAdvisor associated persons, officials, representatives, agents, employees or partners of AirAdvisor in order to enable them provide their services for you.
6.4. In addition, we may disclose your information:
- in reply to a writ of execution, summons letter or court decision;
- for protection from unlawful claims;
- for compliance with other legal requirements;
- if we deem it appropriate to react to illegal acts or perform analysis of unlawful act in order to demand performance of such analysis or taking corresponding measures; to protect or reserve our rights, property, or security of the AirAdvisor.
6.5. Where data transfer is performed on the grounds other than set forth in the Policy, you will be notified about such transfer and you will be able to enable or disable transfer of your personal data to the third party.
6.6. When transferring personal data, we always use the most secure and proven ways.
7. Cross-border transfer of personal data
7.1. You agree that in order to provide the services, AirAdvisor may store and process your personal data, including conduct security check of transactions on the servers and resources located outside of European Economic Area. You are giving your unconditional consent to transfer of any or all your personal data and personal data of third parties you are acting for and on behalf of outside of European Economic Area only to obtain the proper level of the ordered services. Storage and processing of your personal data may be held on the servers and resources owned by the AirAdvisor or its independent contractors, and may be located in any country of the world (e.g. the USA, Canada).
7.2. If you use this website, you hereby give your consent to the transfer of your personal data outside the European Union and European Economic Area. You are aware of and agree that your personal data may be transferred to the USA as well. Any cross-border transfer of data shall be held only to comply with the purpose to fulfill the conditions of the relevant requests, contracts, this Policy and to provide the AirAdvisor service. All cross-border transfer of data shall be limited to the categories of data and recipients that are required for compliance with the executing contracts, these terms and provision of the ordered services.
8. Term of personal data storage
8.1. We store your personal data for the time it remain necessary for the abovementioned purposes. It depends on the purposes of data collection or on presence of permanent lawful grounds for data storage (e.g., fulfilment of provisions of the agreement between ourselves, rendering services requested by you). We warrant you that where there is no reason or lawful necessity to process your personal data we will destroy them or continue their storage in a manner disabling your identification.
8.2. The storage time of different types of personal data depends on the following criteria:
- the purpose of collecting personal data;
- the time it takes to reach the purpose;
- any specific reason or strict legal obligation to store personal data for a certain time.
8.3. If you have Client account on our website we will keep such personal data such as your e-mail address, name, surname, employing company name, and mobile phone in order to enable you enter the system and get access to our service for a time of your account existence.
8.4. When determining the storage periods for personal data, we also take into account the storage time required to fulfill our obligations to you or third parties you are acting for and on behalf of, to regulatory authorities, as well as to submit accounting and tax reports.
9. Rights of user (personal data subject)
9.1. We respect your rights in relation to personal data and aid to exercising thereof. You can contact AirAdvisor with a request for exercising your rights using details displayed below. We ensure execution of your query within a reasonable time period but not later than 1 (one) month from the time of request receipt. This period can be extended to 3 (three) months with due allowance for complexity or huge number of requests from AirAdvisor clients. We will inform you about such time extension beforehand via e-mail using the address specified upon registration.
9.2. You can exercise rights to:
- access to information falling within the scope of agreement between us;
- obtaining an electronic copy of processed personal data;
- clarification and / or correction of your personal data, upon which we notify thereof all persons we previously shared your personal data with, provided that such notification is not impossible or does not demand disproportionate efforts on our part;
- direct transfer of your personal data from AirAdvisor to third parties;
- restriction or full or partial withdrawal of your consent to the processing of your personal data in one way or another;
- destruction of your personal data at your request, or if your consent to processing is withdrawn, or if the need for processing your personal data is no longer relevant.
9.3. If you consider that your rights and / or legal interests are violated, you have the right to file a claim or complaint with the competent state authority.
10. Protection of the confidentiality of personal data
10.1. We take the range of technical, organizational and legal measures to protect your personal data against unauthorized or accidental access, collection, storage, use, communication, interlock or destruction of data, as well as against other unauthorized actions or accidental loss of data.
11.1. You can contact us via email: [email protected]
11.2. You can also send us a letter to 16192 Coastal Highway, Lewes, DE 19958, USA.
Last update: 12 March 2020
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