Privacy Policy

GENERAL INFORMATION

We created this Privacy Policy to show our commitment to fair information practices and protecting your privacy. These principles apply to all our Services, and we strictly follow the rules outlined in this Privacy Policy.

By using our Services, you agree to the collection, processing, retention, manipulation, transfer, and disclosure of your Personal Data, or any other use as described in this Privacy Policy.

Unless otherwise specified, all terms in this Privacy Policy have the same meaning and effect as those in our Terms & Conditions.

If you have questions about our Service regulations, please review our Terms & Conditions, which govern the use and provision of our Services.

TYPES OF PERSONAL DATA WE COLLECT

We mainly gather personal information including names, dates of birth, gender, nationality, flight details, banking details, addresses, email addresses, phone numbers, passports or identification documents, and national identification numbers. This data is collected to enable us to provide our Service, which is central to our business operations.

We may collect your geographical location data when you log in to our Services or visit our website. This information is used solely to track and analyze user locations with the aim of enhancing and improving our services, while maintaining our commitment to your privacy.

We collect non-personal information about how you interact with our website and the Services we offer. This data may include your device's IP address, browser type and plugin versions, operating system, visit date and time, pages viewed, time spent on each page, download errors, and other usage statistics. Additionally, we analyze aggregated usage data and volume metrics to enhance our site's performance and improve our analytics capabilities.

WHO COLLECTS YOUR PERSONAL DATA

Air Fair Pay OÜ is a company based in Tallinn, Estonia, specializing in securing compensation for disrupted flights.

PURPOSES FOR PROCESSING YOUR PERSONAL DATA

We process your personal data for several reasons, which are outlined below:

• To claim and collect on your behalf any compensation owed by airlines due to the Flight Disruption you experienced;
• To transfer to you the funds we have received on your behalf;
• For accounting and financial record-keeping purposes;
• For marketing activities;
• For statistical analysis, company management, administration, and the enhancement of Air Fair Pay's services.

WHOSE INFORMATION WE COLLECT

We gather information from the following sources:

• Visitors or browsers of our website,
• Users who have subscribed to our Services,
• Third-party data that has been uploaded to our servers or provided to us by our Users.

LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA

If you are an individual located in the European Economic Area (EEA), the legal grounds on which we collect and process your Personal Data depend on the nature of the data and the context in which it is obtained. We may rely on one or more of the following lawful bases:

• Consent: You have freely given us your explicit, specific, informed, and unambiguous consent to process your Personal Data. By accepting our Privacy Policy, you agree to provide us with the consent for the data processing for the purposes described here or those communicated at the time of data collection.
• Contractual Necessity: Processing is required to fulfill a contract to which you are a party. This includes any agreements between you and us, such as our Terms & Conditions related to the provision of our Services.
• Legal Obligation: We process your Personal Data to comply with legal requirements imposed on us by applicable laws.
• Legitimate Interests: We may process your Personal Data when it is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms. This includes tailoring our Services to your needs, preventing fraud or unlawful activities, and protecting the security of our network and data.
• Public Interest or Official Authority: Processing is necessary for performing a task carried out in the public interest or in the exercise of official authority vested in us.
• Vital Interests: Processing is necessary to protect your vital interests or those of another natural person, such as in emergency situations.
• Withdrawal of Consent: If our processing is based on your consent, you have the right to withdraw it at any time. Withdrawal will not affect any processing carried out prior to your withdrawal.
• Legitimate Interest Transparency: When we rely on legitimate interests as the basis for processing, we will clearly inform you of these interests at the time your data is collected

HOW WE COLLECT PERSONAL DATA

We may collect your Personal Data directly from you during the course of our relationship—for example, when you disclose your information publicly, use any of our Services or parts thereof, complete a survey, provide feedback voluntarily, or when a User subscribed to our Services shares Personal Data about you.

USER RESPONSIBILITY AND INDEMNIFICATION

We disclaim any responsibility and you agree not to hold us liable for any Personal Data that is provided to us by a User. The User bears full responsibility for ensuring that the collection, processing, transfer, lawful basis, purpose, and all other legal requirements related to such Personal Data are properly met. Furthermore, the User explicitly agrees to defend, indemnify, and hold Air Fair Pay, along with its subsidiaries, parent companies, affiliates, and their respective officers, directors, employees, agents, contractors, service providers, subcontractors, suppliers, insurers, and representatives harmless—at the User's sole expense—from any claims, lawsuits, or legal proceedings, including reasonable attorney fees, arising out of or connected to the use, collection, processing, or transfer of third-party Personal Data in relation to the Services we provide.

WHO DO WE SHARE WITH AND DISCLOSE PERSONAL DATA

You provide your consent to share and disclose your Personal Data with the following recipients:

• Airlines, courts, administrative authorities and dispute resolution bodies and other entities with whom we operate in order to perform the Service,
• Subsidiaries that we own or have control over,
• Our business partners and subcontractors,
• Our suppliers who are using your Personal Data to provide the Services on our behalf or to assist us with our business activities such as processing your payments, providing customer service, or hosting our platform and servers,
• Our auditors, legal counsel, and other professional advisors,
• Authorized and competent law enforcement agencies, regulatory authorities, courts, government bodies, or any third parties as required by law,
• When we have a good faith belief that disclosure is necessary to safeguard the rights or safety of any individual or organization,
• Payment processing companies,
• Any third party, without restriction or limitation, concerning solely Non-Personal data.

DURATION OF PERSONAL DATA RETENTION

We will retain your Personal Data for either 5 years from your last account access or 8 years after the termination of our services—whichever period is longer.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Whether you are an individual residing within the European Economic Area (EEA) or outside of it, you are granted certain rights regarding the use of your Personal Data, as established and protected by the General Data Protection Regulation (GDPR). Accordingly, every user has the following rights:

Right of Access

You have the right to ask if we are processing your Personal Data and, if so, to obtain information about the data we possess. Upon your request, we will supply copies of your Personal Data; however, a fee may be charged for this service.

Right to Rectification

You have the right to request the correction of any Personal Data that is inaccurate or incomplete. In cases where your data has been shared with third parties, we will notify them of the updates made.

Right to Erasure

Under certain conditions, you may request the deletion of your Personal Data, including situations where:

• The data is no longer needed for the purpose it was originally collected,
• You withdraw your consent for its processing,
• You object to the processing and there are no overriding legitimate reasons to continue,
• The data has been processed unlawfully,
• Deletion is necessary to comply with legal requirements, or
• The data relates to individuals under the age of 16.

If your Personal Data has been shared with third parties, we will inform them of your deletion request.

Right to Data Portability

You have the right to request a copy of the Personal Data you have submitted to us or to ask that we transfer this data directly to a third party you designate.

Right to Object

In specific circumstances, you have the right to oppose the processing of your Personal Data, and if applicable, we will stop processing it.

Right to Withdraw Consent

If we process your Personal Data based on your consent, you have the right to withdraw that consent at any time by reaching out to us via email at office@airfairpay.com.

Right to Lodge a Complaint

If you feel that our management of your Personal Data falls short of your expectations or legal requirements, you are encouraged to contact us to resolve your concerns. Furthermore, you have the right to submit a formal complaint to the appropriate supervisory authority.

Should you choose to exercise any of these rights, we commit to responding within 30 days of receiving your request at office@airfairpay.com.

TRANSFER OF YOUR DATA

By using our Services, you explicitly acknowledge and consent that your Personal Data may be transferred to countries outside the European Union (EU) or the European Economic Area (EEA) when required to provide our Services. This may include sharing information with legal representatives for pursuing legal actions or with technology companies to improve our products and services. In such a scenario, we will maintain the highest privacy protection stipulated by this Privacy Policy and ensure that appropriate data sharing agreements are in effect.

COOKIES

Cookies are small data files sent from our website to your browser and stored on your computer's hard drive to collect certain information about you. You always have the option to configure your browser to reject all cookies or to notify you when a cookie is being sent. However, please be aware that choosing to block cookies may limit your ability to use some features of our Services.

We may utilize cookies, pixels, and similar technologies to:

• Develop, maintain, and enhance our Services,
• Analyze and report on how our Services are used and perform,
• Generate aggregated data about groups and categories of Users,
• Detect and prevent fraud or other illegal activities,
• Market, deliver, offer, and personalize marketing related to our Services.

Please note that third parties may also use cookies, pixels, or similar technologies on our website or through our Services. We do not control these third-party technologies and are not responsible for any damages or costs that may result from their use.

HOW DO WE USE ANALYTICS

We utilize data analytics and measurement to gain insights into how our Services are used. For example, we may analyze data related to your website visits or use of our Services to optimize service efficiency and product design. To accomplish this, we employ various tools, which may include third-party services like Google Analytics. By using our Services, you explicitly agree to this data usage and provide your clear consent.

SERVICE PROVIDERS

To assist in delivering our Services or carrying out related tasks on our behalf, we may hire third-party service providers. These providers will access your Personal Data, which is subject to their own privacy policies. By using our Services, you explicitly consent to and accept this arrangement.

CHILDREN'S PRIVACY

We recognize the sensitive nature of children's privacy online and are dedicated to protecting it. Therefore, we neither publish content specifically aimed at children under the age of 16 nor seek to attract this age group ("Children").

Any information we hold relating to Children will be permanently deleted and will not be shared with third parties.

If you become aware that Children have provided us with Personal Data, please inform us immediately so we can remove that information.

OUR SECURITY PROCEDURES

Protecting your Personal Data is a top priority for us. We adhere to widely accepted security standards to safeguard your data both during transmission and after we receive it. While we take extensive measures, you acknowledge that no security system is completely foolproof, and we cannot guarantee that your Personal Data will never be accessed or used without authorization.

You agree not to hold us responsible for any data breaches occurring over the internet, email, or other transmission methods. We also ask that you exercise care when deciding what sensitive information to share with us.

All data we collect is stored securely on protected servers, and payment information is encrypted using Secure Socket Layer (SSL) technology. The information stored in our databases is not publicly accessible.

Furthermore, we continuously monitor and review our data processing and collection practices to prevent unauthorized access to your Personal Data, in compliance with applicable state and federal laws.

CHANGES TO THIS PRIVACY POLICY

At our sole discretion, we may update or modify this Privacy Policy at any time by posting changes or amendments on our website or other locations we consider suitable, ensuring you are informed about the Personal Data we collect and process. To stay aware of any future updates that might affect you, we recommend regularly reviewing this policy.

CONTACT US

If you have any questions about our Privacy Policy or any related policies mentioned or accessible via the provided link, please feel free to reach out to us at office@airfairpay.com.

This Privacy Policy is in effect as of January 1, 2024.

Last updated on January 1, 2024.