This Privacy Statement represents the full online privacy policy applicable to our activities. The Privacy Statement explains the types of information we collect, how we use, share, and secure the information you provide. It also describes your choices regarding the use, access, and correction of your personal data.

Your personal data is processed lawfully. Our activities are governed under applicable data privacy and data protection laws (collectively, “Data Protection Laws”) in connection with the services we provide. The particular Data Protection Laws may include, depending on the circumstances, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados or LGPD), and other applicable legislation and regulations implementing Data Protection Laws.

Flight Delay Expert is considered to be the data controller as it determines the purposes and means of the processing of personal data.

Definitions

In this Privacy Statement, unless otherwise defined herein, the capitalized terms below shall have the same meaning as in our Terms And Conditions.

Personal Data

Personal data means any information relating to an identified or identifiable natural person. Personal data includes all types of information that directly or indirectly identify a person, such as names, dates of birth, addresses, email addresses, telephone numbers, etc.

Principles

Our Privacy Statement is based on the following data protection principles:

• The processing of personal data shall take place in a lawful, fair, and transparent way.
• The collection of personal data shall only be performed for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
• The collection of personal data shall be adequate, relevant, and limited to what is necessary in relation to the purpose for which they are processed.
• The personal data shall be accurate and where necessary, kept up to date.
• Every reasonable step shall be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
• Personal data shall be kept in a form which permits identification for no longer than it is necessary for the purpose for which the personal data are processed.
• All personal data shall be kept confidential and stored in a manner that ensures appropriate security.
• Personal data shall not be shared with third parties unless the transfer is necessary in order for Flight Delay Experts to deliver the services in the agreement.
• You have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.

Collection and Use of Personal Data

If you would like to benefit from our services and submit information to us, you may be asked to provide personal data in order for us to operate and improve our business and services. Personal data may be submitted via our website, email, other electronic or software solutions supported by us, postal service, or phone. All personal data is collected in accordance with the applicable Data Protection Laws. We will process personal data only to the extent required for a specified, explicit and legitimate purpose or for a purpose required by law in places where we operate.

We primarily collect personal data such as names, dates of birth, addresses, email addresses, telephone numbers, passports/IDs, and national identification numbers. We collect this personal data for the purpose of delivering our Eligibility Service, Information Service, Compensation Service, and any other Services in accordance with the agreement. This is the core activity of Flight Delay Experts as a business.

Furthermore, we collect personal data for other purposes such as statistics, administration and communication, IT and security administration, physical security, authentication and authorization systems, support systems, collaboration of internal projects, and organizational teams and activities.

We purchase flight data from third parties, e.g., information on delayed or canceled flights within a given time, etc. This information is non-personal data, which we combine with personal data. This Eligibility Service is only used to inform about the likelihood of having an eligible Claim. We will provide our Compensation Service for Eligible Claims on request.

Insofar as you share personal data of Fellow Passengers with us, you are obligated to ensure that all Fellow Passengers have explicitly given their consent for the sharing of their personal data with our organization, in compliance with data protection regulations. Moreover, you are required to provide the Fellow Passengers with access to our privacy policy to ensure that they are fully informed about the processing of their data by us.

We may ask you for additional information or documents related to Fellow Passengers. If you or Fellow Passengers fail to provide such information and/or documents, we will not be able to offer our services to the respective Fellow Passenger. Consequently, we will be compelled to remove the personal data of that Fellow Passenger from our databases and we will not be able to provide them with our Services.

Use of Personal Data

We will use personal data for the purpose it is collected, and keep the data for no longer than necessary for that purpose. We may retain your information for as long as your account is active or as needed to provide services, comply with our legal obligations, or any of the purposes listed above. Access to personal data is strictly limited to personnel of Flight Delay Experts and its controlled subsidiaries and affiliates who have the appropriate authorization under a corporate binding agreement with Flight Delay Experts, and a clear business need for the data.

Automated Processes and Profiling

Flight Delay Experts does not rely on automated processing in accordance with Article 22 p. 1 of the GDPR, and your personal data will not be used for profiling purposes. Your data will not be used for these purposes unless explicitly communicated otherwise, and only with your separate consent.

We may, however, use our technology and technology from our partners to automate certain processes. This allows us to provide faster and better Services to you.

In order to ensure that these automated processes have no negative or unjustified impact on you, our teams regularly investigate whether they are correct. This concerns legacy and future processes.

Questions about your data and automated processes can be directed to the Data Protection Officer (“DPO”) at cs@flightdelayexperts.com.

Use of Cookies

Our website and our partners use cookies or similar technologies to ensure the best user experience and to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

Our use of cookies is governed by our Cookie Policy.

Sharing of Personal Data

We will only transfer personal data to third parties under the conditions as listed below:

• If you have given consent
• If it is for a purpose directly related to the original purpose for which the personal data was collected
• If it is necessary for the preparation, negotiation, and fulfilling the agreement with you
• If it is required due to legal obligation, administrative, or court order
• If it is required for the establishment or protection of legal claims or in defense of court actions
• If it is required for responding to lawful requests by public authorities, including to meet national security or law enforcement requirements
• If it serves the prevention of misuse or other illegal activities, such as deliberate attacks, to ensure data security

Occasionally we sign up with other companies and business partners, in and outside the European Economic Area, to work on our behalf, such as legal representatives to take Legal Action, or technology companies to enhance our products and services, and we will share necessary information in these cases. Before we share personal information, we enter into written agreements with the recipients which contain data protection terms that safeguard your data according to relevant Data Protection Laws.

Service providers will only be permitted to obtain the personal data that they need to deliver their service. We will not disclose personal data to third parties for the purpose of allowing them to market their products or services to you. If you do not want us to share personal data with these companies, please contact the Data Protection Officer (“DPO”) at cs@flightdelayexperts.com.

Security of Processing

The security of your personal data is important to us. We will process personal data securely, apply and maintain appropriate and generally accepted standards of technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. Questions about the security of personal data can be directed to the DPO at cs@flightdelayexperts.com.

Your Data Protection Rights

You have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability, at any time. To help us keep personal data updated, we advise you to inform us of any changes or discrepancies. To view and/or edit personal data, or receive information on how long we intend to retain personal data or other questions related to the access of personal data, or if you would like to request that we provide you with information about whether we hold or process on behalf of a third party any of your personal data, please contact the DPO at cs@flightdelayexperts.com. We will respond to your request within a reasonable timeframe.

Applying for a Job

For job applications, we use a third-party recruitment tool for management purposes. When applying for a job position at Flight Delay Experts, personal data will be processed and controlled by Flight Delay Experts. Applications shall not be stored for longer than necessary or shared with any third parties. If you wish to access, rectify, or erase personal data, restrict processing, or object to processing as well as use the right of data portability, please contact the DPO at cs@flightdelayexperts.com.

Marketing Emails and Advertising Preferences

Upon consent, we are allowed to send marketing emails. This specific form of consent must be freely given, specific, informed, and unambiguous. These requirements are fulfilled when you opt-in (i.e., actively agree) to receive marketing emails.

You will always have the right to object, on request and free of charge, to the processing of your personal data relating to direct marketing activities without having to provide specific justifications. You can do so by using the “Unsubscribe” link found in emails received from us or by contacting us at cs@flightdelayexperts.com. If you object, your personal data will no longer be processed for direct marketing.

The marketing emails contain information which we believe may be of interest, such as the latest news on our products and services.

We partner with a third party to display advertising on our website or to manage our advertising on other sites, including social media platforms. Our third-party partner may use cookies or similar technologies to provide you with advertising based upon your browsing activities and interests. You may opt out of interest-based advertising. Please note that you will continue to receive generic ads.

Responsibility

The Privacy Statement is under the responsibility of our Legal Team, who have the overall responsibility to ensure compliance. The DPO is ensuring compliance with the Privacy Statement on a daily basis and is involved in all issues related to the protection of personal data.

We are responsible for and will at any given time be able to demonstrate compliance with the Data Protection Laws as well as our principles set out in this Privacy Statement. We shall maintain records of processing activities under our responsibility containing the information required by the Data Protection Laws and where applicable make the records available to the supervisory authority on request.

Any inquiries concerning this Privacy Statement can be directed to the DPO at cs@flightdelayexperts.com.

Complaint

You have the right to file a complaint concerning our processing of your personal data. All queries and complaints shall be handled in a timely manner by the DPO in accordance with internal procedures. Complaints can be submitted to the DPO at cs@flightdelayexperts.com.

In the unlikely event that you consider that our processing of your personal data infringes any Data Protection Laws, you may also lodge a complaint with a relevant supervisory authority.

Changes to this Privacy Statement

This Privacy Statement may be updated from time to time, e.g., due to modifications of relevant legislation or changes to our corporate structure. If any material changes are made, you will be notified by email or by means of notice on the website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact

Flight Delay Experts
c/o Travel Village Ltd
124 City Road
London
EC1V 2NX

Email: cs@flightdelayexperts.com
Updated: 27 December 2023
Version T1.24