Purposes for the Website Operator
| The purpose of processing | The legal basis of processing | Data Storage Period (criteria) |
|---|---|---|
perform operating activities on Website, including: Website administration and publishing, updating and deleting content and information about possible Travel Products on the Website; users' attraction and assistance with Website navigation, including connecting them with TPP MAIN ACTIVITY | contractual obligations | Not longer than it is necessary under Website Terms of use |
to provide customer support related to the MAIN ACTIVITY and redirecting it to customer support of TPP (to answer your inquiries, restore data entry auto-save tool, etc.); | legitimate interest (provision of customer support) |
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to render web-based services upon your request (newsletter subscription, price quotes, itinerary review etc.); | consent | until the consent was withdrawn, except evidence of consent and its withdrawal used for our legal claim protection |
to provide you with value added advertising related to the MAIN ACTIVITY, including our newsletters and advertising on third party websites and social media platforms; | legitimate interests | until opted out or turned off personalised advertising, except evidence of opting out used for our legal claim protection |
to ensure the security of our services, property and your data, including troubleshooting, data security analysis, error testing, system maintenance, support, reporting and hosting of data; | legitimate interests | no longer that it is necessary to investigate the incident, no longer than for preventing or remediating any negative consequences, as well as protecting/ exercising TPP’ legal claims |
to enhance the quality of our services and customer experience, e.g. conducting surveys, improving staff communication culture, sending holiday greetings; | legitimate interests | until opted out, except evidence of opting out used for our legal claim protection; OR - no longer than it is necessary to resolve issues related to the customer experience |
| to exercise, establish and protect our and our partners’ legal claims; | legitimate interests | not more than 5 years after the termination of Terms of use |
to comply with the requirements of applicable legislation, e.g. regarding taxes, accounting, consolidated accounting, regulatory matters etc.; | legal obligations | According to the current accountancy (including consolidated part) and tax legislation, but not more than 7 years |
to comply with the requirements of the data subject request regarding objection to process personal data for direct marketing purposes (maintenance of Unsubscribe list) | legal obligations | not more than 5 years after the receipt of data subject request |
| to manage data subject requests | legitimate interests | not more than than 5 years after the request’s submission date. |
to achieve internal administrative purposes within group of companies, part of which is Website operator (maintenance and security of ICT resources; management of data protection systems etc.); | legal obligations | no longer than:
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| to maintain backup and archive systems and restore data (if necessary); | legitimate interests | no longer than the backup or archived system is restored to an active system or next processed for the performance of the MAIN ACTIVITY (commercial purposes) or shared with third parties |
to use personal data in aggregated form for statistical and analytical purposes, e.g. to improve our website, products/services, marketing, customer relationships and experiences. | legitimate interests | no longer than the statistical/ analytical report was created |
Purposes for TPP (EU and UK based)
| The purpose of processing | The legal ground of processing | Retention period (criteria) |
|---|---|---|
To fulfil preparatory steps for entering into agreement on purchase of Travel Product (see also T&C); conclude and perform the agreement with TPP, communicate with you sending booking confirmations, alerts etc. – MAIN ACTIVITY | contractual obligations | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (flight date/ car drop-off date/ hotel check-out date). |
To render other services related to the MAIN ACTIVITY (customer support (to answer your inquiries, restore data entry (auto-save tool) ,concierge services, route changes, refunds, chargebacks, bank card verification, managing cashbacks (if you participate in loyalty/membership programs), etc.); | legitimate interests |
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to render web-based services upon your request (newsletter subscription, price quotes, itinerary review etc.); | consent | until the consent was withdrawn, except evidence of consent and its withdrawal used for our legal claim protection |
to ensure the security of our services, property and your data, including troubleshooting, data security analysis, error testing, system maintenance, support, reporting and hosting of data; | legitimate interests | no longer that it is necessary to investigate the incident, no longer than for preventing or remediating any negative consequences, as well as protecting/ exercising TPP’ legal claims |
to enhance the quality of our services and customer experience, e.g. conducting surveys, improving staff communication culture, sending holiday greetings; | legitimate interests |
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to exercise, establish and protect TPP and partners’ legal claims; | legitimate interests | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (flight date/ car drop-off date/ hotel check-out date). |
To fulfill the requirements of international agreements (e.g. passengers' data (PNR) on fighting serious crime and terrorism); | legal obligations | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (flight date/ car drop-off date/ hotel check-out date). |
To comply with legal obligations (e.g. tax, accounting, AML requirements, fraud prevention, border control etc.). | legal obligations | According to the requirements of applicable legislation |
To improve border controls (security) and to combat illegal immigration (e.g. EU; USA; Canada; UK); | legal obligations | not more than applicable legislation provides after the flight date |
to achieve internal administrative purposes within group of companies, part of which is EU/UK TPP (maintenance and security of ICT resources; management of data protection systems etc.); | legitimate interests | no longer than:
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To maintain backup and archive systems and restore data (if necessary); | legitimate interests | no longer than the backup or archived system is restored to an active system, shared with third parties or next processed for the (commercial) purposes other than technical maintenance and IT security |
To use personal data in aggregated form for IT security, maintenance, statistical and analytical purposes, e.g. to secure or improve products/services. | legitimate interests | no longer than the statistical/ analytical report was created or IT security/maintenance measures are applied |
To manage data subject requests | legitimate interests | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the request’s submission date. |
To comply with the requirements of the data subject request regarding objection to process personal data for direct marketing purposes (maintenance of Unsubscribe list) | legal obligations | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the request’s submission date. |
Purposes for TPP based in the US and Canada
| The purpose of processing | Activity | Category of Personal data |
|---|---|---|
To fulfil preparatory steps for entering into agreement on purchase of Travel Product (see also T&C); conclude and perform the agreement with TPP, communicate with you sending booking confirmations, alerts etc. – MAIN ACTIVITY | To start a business relationship |
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To process and deliver your order including:
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To render other services related to the MAIN ACTIVITY | To perform the following activities (but not limited to):
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For solely internal uses that are based on your relationship with us or compatible with the context in which Personal data was collected | To manage our relationship with you and enhance the quality of our services and customer experience which will include:
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To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, provide an opportunity to be subscribed to our newsletter, receive price quotes. For more information about marketing click here. |
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To use data analytics to improve our products/services, marketing, customer relationships and experiences | Network Activity Information | |
To make suggestions and recommendations to you about goods or services that may be of interest to you |
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To ensure the security of our services, property and your data |
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To comply with a legal obligation |
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To exercise, establish or defend legal claims |
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To use personal data in aggregated form for statistical and analytical purposes | To analyze information to secure or improve products/services | Aggregated information, including Identifiers and Network Activity Information |
To manage data subjects' requests |
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To comply with the requirements of the data subject request regarding objection to process personal data for direct marketing purposes |
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Purposes for TPP based in the UAE
| The purpose of processing |
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to fulfil preparatory steps for entering into agreement on purchase of Travel Product (see also T&C); conclude and perform the agreement with TPP, communicate with you sending booking confirmations, alerts etc. – MAIN ACTIVITY |
to render other services related to the MAIN ACTIVITY (customer support (to answer your inquiries, restore data entry (auto-save tool) ,concierge services, route changes, refunds, chargebacks, bank card verification, managing cashbacks (if you participate in loyalty/ membership programs), etc.); |
to render web-based services upon your request (newsletter subscription, price quotes, itinerary review etc.); |
to ensure the security of our services, property and your data, including troubleshooting, data security analysis, error testing, system maintenance, support, reporting and hosting of data; |
to enhance the quality of our services and customer experience, e.g. conducting surveys, improving staff communication culture, sending holiday greetings; |
| to exercise, establish and protect TPP and partners’ legal claims; |
to fulfill the requirements of international agreements (e.g. passengers' data (PNR) on fighting serious crime and terrorism); |
To comply with legal obligations (e.g. tax, accounting, AML requirements, fraud prevention, border control etc.). |
to improve border controls (security) and to combat illegal immigration (e.g. EU; USA; Canada; UK); |
to achieve internal administrative purposes within group of companies, part of which is UAE TPP (maintenance and security of ICT resources; management of data protection systems etc.); |
| to maintain backup and archive systems and restore data (if necessary); |
to use personal data in aggregated form for IT security, maintenance, statistical and analytical purposes, e.g. to secure or improve products/services. |
| to manage data subject requests |
to comply with the requirements of the data subject request regarding objection to process personal data for direct marketing purposes (maintenance of Unsubscribe list) |