Purposes for the Website Operator

The purpose of processingThe legal basis of processingData 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 obligationsNot 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)
  • no longer that it is necessary to fulfill current customer request or to prevent possible negative consequences, as well as protecting/ exercising our legal claims; OR
  • no longer than it is necessary to resolve issues related to the customer support

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until the consent was withdrawn, except evidence of consent and its withdrawal used for our legal claim protection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 requestslegitimate 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:

  • it is necessary to investigate the incident, AND/ OR
  • for preventing or remediating any negative consequences, AND/ OR
  • as well as protecting/exercising our legal claims
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 interestsno longer than the statistical/ analytical report was created

Purposes for TPP (EU and UK based)

The purpose of processingThe legal ground of processingRetention 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

  • Until the termination of the agreement for MAIN ACTIVITY
  • no longer that it is necessary to fulfill current customer request or to prevent possible negative consequences, as well as protecting/ exercising TPP’S legal claims; OR
  • no longer than it is necessary to resolve issues related to the customer support

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

  • 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 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:

  • it is necessary to investigate the incident, AND/ OR
  • for preventing or remediating any negative consequences, AND/ OR
  • as well as protecting/ exercising our legal claims.

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 processingActivityCategory 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

  1. Identifiers
  2. Contact Data
  3. Audio/Electronic information

To process and deliver your order including:

  1. Managing payments, cashbacks (if you participate in loyalty/ membership programs), fees and charges
  2. Collecting and recovering money owed to us
  3. Providing to you post-sale customer support
  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Inferences
  5. Audio/Electronic information

To render other services related to the MAIN ACTIVITY

To perform the following activities (but not limited to):

  1. general customer support (to answer your inquiries, restore data entry (auto-save tool),
  2. concierge services,
  3. route changes,
  4. refunds,
  5. Chargebacks
  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Inferences
  5. Audio/Electronic information

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:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  3. Sending holiday greetings
  4. improving staff communication culture
  1. Identifiers
  2. Contact Data
  3. Inferences
  4. Audio/Electronic information

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.

  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Network Activity Information
  5. Inferences

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

  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Network Activity Information
  5. Inferences

To ensure the security of our services, property and your data

  1. To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  2. To maintain backup and archive systems and restore data (if necessary);
  3. To identify and repair errors that impair existing intended functionality
  1. Identifiers
  2. Contact Data
  3. Network Activity Information
  4. Audio/Electronic information

To comply with a legal obligation

  1. To manage tax matters;
  2. Bookkeeping and accountancy of transactions;
  3. To manage consolidated reports and annual financial reports;
  4. To comply with the requirements of licenses, registrations and permissions obtained by us, including industry standards (airline safety rules, PCI DSS etc.);
  5. To comply with law requirements (e.g. EU , USA, Canada, UK etc.) of improving border controls (security) and combating illegal immigration.
  6. To fulfill the requirements of international agreements (e.g. passengers data (PNR) on fighting serious crime and terrorism);
  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Audio/Electronic information

To exercise, establish or defend legal claims

  1. To manage complaints
  2. To comply with requests, subpoenas and other enforcement notices issued by regulators, courts and law enforcement agencies
  3. To protect and exercise our legal claims before court, authority or law enforcement agency
  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Network Activity Information
  5. Inferences
  6. Audio/Electronic information
  7. Geolocation data

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

  1. To record incoming requests
  2. To answer to the requests in the timely manner
  3. To store them so that correct chronology of communication is sustained
  1. Identifiers
  2. Contact Data
  3. Commercial Information
  4. Network Activity Information
  5. Audio/Electronic information

To comply with the requirements of the data subject request regarding objection to process personal data for direct marketing purposes

  1. To sustain deletion requests
  2. Maintain Unsubscribe list
  1. Identifiers
  2. Contact Data

Purposes for TPP based in the UAE

The purpose of processing

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)