Terms and definitions

Terms and definitions used in this Privacy Policy shall correspond the terms set in Website Terms of Use and/ or T&Cs, except if otherwise set herein:

Website user

means a person who visits the Website. Website user can stay in this status and never purchase a Travel Product. Website user also may be referred to as “you” based on the context.

Client

an individual, a party of service contract with TPP, purchasing Travel Product. Client also may be referred to as “you” based on the context.

Personal data

any information related to the identifiable or identified person (data subject). Reasonable measures such as costs and time limits are used to identify a person. Identification won’t happen if it proves to be impossible or involves disproportionate efforts. The term “Personal information” shall have the same meaning as Personal data.

Processing

any operation or set of operations which is performed on Personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Controller

a natural or legal person, which, alone or jointly with others, determines the purposes and means of the processing of personal data. The term “business” shall have the same meaning as Controller.

Processor

a natural or legal person, which processes Personal data on behalf of the Controller. The term "Service provider" shall have the same meaning as a Processor.

Travel Product Provider, TPP

the company, selling Travel Product on Website, including third party vendors (e.g. medical protection, car rentals etc.). Relations with this company are covered by T&C, which plays the main role in processing of Personal data of Clients. TPP also may be referred to as “we” based on the context.

Travel Product

means a ready-to-use services, rendered by Travel Products Providers, including, but not limited to flight tickets, car rentals, hotel bookings, transfers from/ to airport and upsell ancillary services (e.g. Travel Care Services).

Website Operator

a company responsible for operating Website, which performs activities including, but not limited to:

• Website security and maintenance;
• Administrating and publishing, updating and deleting content and information about possible Travel Products on the Website, in accordance with the TPP instructions;
• Attracting users and assisting them with Website navigation, including connecting them with TPP;
• Ensuring customer support regarding content published on Website and other related issues; Relations with this company is covered by Website Terms of Use

Website

means oojo.com and any extensions of the above domain, which is operated by Website Operator. By its nature Website is a marketplace, connecting Website users with TPP and allowing them to purchase Travel Products.

Privacy Policy

a legal statement explaining how TPP and/or Website Operator processes and protects Personal data.

About this Privacy Policy

We are committed to maximally avoid risky processing of your Personal data, as well as to process only as much data as it would be absolutely necessary for achievement of our purposes or providing services upon your request taking into consideration the proportionality principle.

This Privacy policy:

• applies to Personal data processed while you are visiting our Website and/ or purchasing Travel Products;
• aims to give you information on how we process your Personal data;
• is instrumental in our Personal data protection system.

We process your Personal data in material compliance with the following principal provisions:

• We respect and comply with the requirements of the applicable data protection legislation.
• We are fair and maximally transparent with you regarding your Personal data processing and protection.
• By default, we are processing only a Personal data, which:
  • is necessary to achieve the current purpose;
  • is accurate and, where necessary, kept up to date.
• Upon achievement of a purpose we are either deleting your Personal data or anonymizing it, so it is impossible to identify you. The only exception are cases, where the current Personal data is required for another purpose set herein or compatible with the initial one (for example, after the service rendered we might need to keep some data to comply with the requirements of the tax and other legislation).
• When data is being processed for security, statistical and analytical purposes, we are applying anonymization or additional safeguards preventing any undue impact on your person (functional separation).
• We perform and constantly improve organizational and technical measures ensuring Personal data protection against any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the data.
• We conduct staff training on a regular basis regarding data protection matters.
• We carry out all the necessary measures, so the relevant safeguards to be included in agreements with our partners, as well as responsibilities are clearly shared subject to the requirements of relevant data protection legislation.
• By using our Website, you acknowledge that we process your Personal data in accordance with this privacy policy.

Amendments and effective date

We might make minor amendments to this Privacy policy which shall not negatively affect you, except if applicable legislation set otherwise.

In case of material changes we will publish such amendments and amended policy on the internet and, as far as possible, notify you either by email or by pop-up windows when you are visiting our websites next time.

Amendments shall enter into force on the Effective Date: August 1, 2025.

Actual version of the Privacy policy is published on Website.

Contacts / Data controllers

Depending on your relations with the controller, your action on the Website and a currency you choose when purchasing Travel Product, your controller may vary.

Your principal data controller is the Website Operator, when you are browsing Website, however, if you purchase any Travel Product, the current Travel Products Provider you purchased from will be your data controller. For more information about contact details of data controllers, please click here .

If you have any questions or concerns about our use of your personal data, or wish to inquire about our personal data handling practices, send any requests according to the applicable legislation. Please use the table of contacts here with the list of companies.

What data do we collect about You?

We are collecting different hoho Data Categories List depending on your relationships with us, your request of services, requirements of applicable legislation and our legitimate interests conducting our business.

We might collect directly from you and process special categories personal data that could reveal sensitive information, including your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, health or disability information (e.g. meal/ seat preferences, insurance claims, car rentals for persons with disabilities, special rooms in hotels etc.), immigration or citizenship details. We will only use your sensitive information for the purposes of rendering services requested by you (including relevant communication and customer service), as well as for security and safety purposes (including compliance with law requirements).

How do we collect Your personal data?

We use different methods to collect personal data from and about you.

Personal data you give to us. We collect personal data directly from you (using life chat, online forms or via voice call/ messenger).

Any contact data (emails, phones etc.) provided by you throughout any interaction will be treated as your personal contacts and saved in your profile for future communications, unless specifically requested not to be stored (one-time communication only). For example, when you provide us with your personal data by requesting a quote, registering or booking travels, contacting our customer support. This includes personal data you provide when you:

For example, when you provide us with your personal data by requesting a quote, registering or booking travels, contacting our customer support. This includes personal data you provide when you:

• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• give us feedback or contact our customer support.

When we chat with you (e.g. WhatsApp, Facebook, regular sms etc.) the chat might be accidentally closed/ removed, there might be interruptions, slow internet connection etc. We may contact you later via automated phone and text messages or email (if available) in order to restore our communication started within the chat. No purchase necessary. You can opt out from further communication by replying to sms/ email or notifying us during the phone call.

Loyalty/Membership programs. If you participate in loyalty/membership programs organised by our associated companies and covering all or current associated companies, we might access data registered within your member account, so you are able to use benefits within those programs (e.g. use cashbacks in accordance with specific T&Cs when paying for our products/ services, etc.).

We might also collect your personal data passively. For example, with your consent we will collect Network Activity Information about your equipment, browsing actions and patterns. For additional information, please refer to our Cookie policy.

We might also collect additional information from our partners in order to prevent fraud, assist us in security matters, protect our legal claims or ensure the services requested by you.

Our associated companies might share data about benefits you are entitled to, when purchasing from us. For example, you might use earned DreamCoins (managed by our associated companies), which later can be later redeemed in connection with the eligible booking.

Other individuals might provide your personal data as well. For example, when someone purchases airplane tickets for you (you are the passenger), you receive an appreciation voucher as a gift from our client or someone referred your contacts to us within referral campaign (they should obtain your consent first!).

Data Accuracy

When you give us personal data, you are telling us, that the information is true, accurate, complete and current. You are also telling us, that you have the authorization to provide it to us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed, if your personal data changes during your relationship with us.

If you fail to provide personal data or you have provided incorrect personal data, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Children

We do not knowingly collect personal data from minors, except if the minor is one of travelers. If we become aware that a minor is attempting to submit personal data, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us personal data, please contact us so we can delete it.

Why do we need Your personal data?

Depending on the relationship (Client, Website user etc.) we collect only the minimal personal data necessary for achieving processing purposes (e.g. assist in purchasing air tickets, make a payment, detect fraud, prevent identity thefts, send a newsletter, provide customer support etc.).

Main groups of processing purposes you can find here:

Referrals:

• If you participate in our Referral Program and (1) forward an email / sms with referral Code to your friends or (2) share friends' contacts (email, phone, social media account etc.) with us, we presume that you have notified your friends in advance about sharing their PI with us and that their PI will be processed in accordance with this privacy policy.
• You shall respect any objections received from your friends regarding processing their PI (email, phone etc.) for marketing purposes. If you keep ignoring friends' objections and don't report it to us, we disclaim all responsibility which may be imposed on us as an advertiser.
• We won't unsubscribe friends' email/ phone if it was not specifically requested by your friends.

Change of purpose

We will only use your Personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Requests and complaints

To exercise your rights under applicable legislation (e.g. right to access or delete your Personal data) you should follow the procedure described below. Also please take into consideration specifics appliable to the American TPP here.

In case we are a processor, the main contact for data subjects should remain data controller. In such cases we will definitely provide possible support in contacting the relevant controller.

Due to the remote nature of our services, it is important for us to keep communicating through the same email (Verified Email), which was used by you to submit requests or as a contact email during purchase of Travel Products. The Verified Email is the key communication channel for us, so we can give quick answers and not divulge your data to any malicious person. You might also submit a request through the voice call, but still detailed answers would be provided to Verified email due to legal and technical requirements, also to protect our legal claims.

Each of our brands operates independent marketing programs tailored to specific audiences, regions, and product categories. When you unsubscribe (object), your preferences apply to the relevant brand to ensure you receive only communications aligned with your demonstrated interests.

CONTACTS: Please see the contact to send your requests here.

NONDISCRIMINATION: We shall not discriminate (deny services, charge different prices, provide different levels of quality) against you because you exercised any of the rights set herein. This right might be limited in case, if the difference in prices or levels or quality is reasonably related to the value provided to you by your Personal data. We might obtain your opt-in consent and provide to you financial incentives, so you agree to provide additional Personal data or not to request the deletion of your Personal data.

PERIOD OF ANSWERING: General period for answering is one month. One-month period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. If you’ve sent the request to the wrong controller within the Controller's list, we will resend it to the correct one within this list.

FEES: In case your requests are manifestly unfounded or excessive, we might refuse to act on the request explaining reasons or you might be charged a reasonable fee considering the administrative costs of providing the information or communication, or taking the action requested.

In case we have reasonable doubts concerning the identity of the natural person (also authorized representative) making the request, we may request the provision of additional information necessary to confirm the identity of such natural person.

You are entitled to receive one copy of your data free of charge. For any further copies we may charge a reasonable fee based on administrative costs. The right to obtain a copy shall not adversely affect the rights and freedoms of others.

How we share your personal data

Generally, we do not share your data with third parties.

The only way we are doing so, when it has a legal basis and processing purpose for doing so. Disclosing your data, we require recipients to follow applicable legislation and data protection measures when they process your data.

Our Website may contain links to third-party websites, products and services. We may also use or offer products or services from third parties − for example, a third-party app.

When you use a third party service or click a link to a third party website, our Privacy policy is not applicable. Please, contact the relevant third party to obtain their privacy rules.

Depending on processing purposes, we might share your data with our associated companies, our services and goods suppliers, as well as other third parties. Other detailed information on our sharing practices you can find here.

Regarding transfers to third countries and international organizations from the EU/UK/UAE, please see more information here.

Security measures

Considering the state of the art and costs of implementation, the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing.

We ensure and permanently improve security measures to protect your data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

To achieve the highest security level, we are performing organizational and technical measures. The most typical measures you could find here.

Your rights

1. Right to be informed. We will inform you at least of the identity of controller, the purposes of data processing and sources where to find additional information. In the event we are collecting your data from other controllers (processors) you will also be informed in a timely manner. In case, the processing of your data is based on consent, you will definitely have the right to withdraw your consent at any time. Please, be informed that the withdrawal of consent is not affecting the lawfulness of processing based on consent before its withdrawal. There might also be other cases where your rights to be informed are limited.

2. Right of access to your data. You are entitled to receive a confirmation as to whether or not your data is being processed by us, and if so, you have a right to access the relevant data.

3. Right to delete (erase) your data. You are entitled to obtain the erasure of your data, unless there are legislative requirements or other legitimate reasons not to erase your data.

4. Right to rectify and add. You are entitled to obtain the rectification of inaccurate personal data. Considering purposes of processing you are also entitled to supplement incomplete personal data.

5. Right to object. In certain cases you can object to processing your data, which can be in the form of withdrawing your consent or challenging certain grounds for processing your data.

Current TPPs might operate under different brands, so rights set in this section are being exercised in each brand separately.

Additional provisions regarding rights may be applied for the EU/UK/UAE located Clients and Website users, for more info see here.

Cookie policy

Cookies is a small piece of data sent from website and stored on your device (computer, smartphone etc.) by your web browser while you are browsing website and sometimes down the line. Without Cookies it would be impossible to provide you information and services you are requesting through the Internet. Cookies remember stateful information (such as items added in the shopping cart in an online store) or record your browsing activity. They can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords and billing address.

By using the website, you agree to the use of any of the cookies and tracking tools mentioned in this policy, unless you opted out (available only for some cookie types). Additional information about cookie purposes can be found here.