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Your personal concierge is on the way.
Your privacy is of significance to AIRCONCIERGE (AIRCONCIERGE, “Platform”, “we”, “us”, “our”) and we are committed to maximally avoid risky processing of your personal data, as well as to process as much data as it absolutely necessary for achievement of our purposes or providing services on your request taking into consideration proportionality principle.
AIRCONCIERGE processes your personal data in material compliance with the following principal provisions:
We are collecting different categories of data
depending on your request of services, requirements of LAWS and our legitimate interests conducting
When you provide to us your 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.
AIRCONCIERGE does not aim any of our products or services directly at children and we do not knowingly collect personal data about children, except in cases where it might be indirectly implied by nature of services (e.g. the air ticket booked for a passenger who is a child)
We collect your data from third parties. In addition, we also integrate third party software that collects information about users for security reasons.
Separately from other data, there are specified category of data as cookies. We are using cookies when you are using our Platform (e.g. browsing websites, applications of AIRCONCIERGE, sending email and text messages, communicating through social media accounts). The cookies mostly relate to the necessity of providing services you have explicitly requested by you (e.g., to open a website or some section of it, mankind payments etc.) or your authentication during the login process.
Please find additional information on usage of cookies HERE.
Depending on relationship (client, partner agreement, website user etc.) AIRCONCIERGE collects
only whose personal data minimally necessary for achieving processing purposes (e.g. sell/buy 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.
We also might use your data in aggregated form* for statistical and analytical purposes, e.g. to improve our website, products/services, marketing, customer relationships and experiences.
Depending on the current purpose, we apply on of the following lawful grounds: consent, performance of contract, legal obligation and/ or legitimate interests of controller or third parties.
Our legitimate interests, for which your data might be processed, are:
Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data.
One of the main collection methods are VOICE CALLS, which may be recorded for the purposes set herein.
We have vested interest to ensure you have chosen the best possible option. Voice calls are an exclusive opportunity to provide you with an immediate customer support and disclose additional product features, you might not notice on a website or within our price quote.
Usually, we call back on your request. Sometimes there might be unfinished conversations regarding current flights (misunderstanding in live chat, email system error, poor internet connection etc.), which require immediate response.
We don’t make unwanted telemarketing robocalls or any annoying advertising campaigns.
You can opt-out this communication at any time by contacting us via phone or email.
Where AIRCONCIERGE collects personal data to comply with LAWS or under the terms of a contract where you are a party to such a contract, and you fail to provide your data when requested, we may not be able to perform the contract or 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.
Generally, we do not share your data with third parties.
The only way AIRCONCIERGE is doing so, when it has a legal basis and processing purpose for doing so. Disclosing your data, we require recipients to follow LAWS and data protection measures when they process your data.
Our Platform and services 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.
Depending on processing purposes, we might share your data with associated companies of AIRCONCIERGE, our services and goods suppliers, as well as other third parties. Other detailed information on our sharing practices you can find HERE.
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,
AIRCONCIERGE ensures and permanently improves 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.
The scope of your rights (as data subjects) is set under each current processing purpose and legal basis
which will be informed to you when AIRCONCIERGE collects / you are providing your data to us.
In case we are a processor, you should take it into account exercising your rights, as the main contact for data subjects should remain data controller. In such cases we will definitely provide possible support in contacting the relevant controller.
Right to be informed
Every time we collect your data, AIRCONCIERGE will inform you at least of the identity of a 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.
So, our communication is made in intelligible, plain and clear way, but the texts are not burdensome, we will not inform you on details you already know.
There might be also other cases where your rights to be informed are limited.
Right of access
You are entitled to receive from AIRCONCIERGE 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.
Right to rectify and add
You are entitled to obtain from AIRCONCIERGE without undue delay the rectification of inaccurate personal data. Considering purposes of processing you are also entitled to supplement incomplete personal data.
Right to erasure (“right to be forgotten”)
You are entitled to obtain from AIRCONCIERGE the erasure of your data. In cases set by LAWS we shall delete your data.
Unfortunately, since the exceptional character of exercitation of such rights the LAWS set restrictions when your request might be refused.
Right to restriction of processing
In current cases you are entitled to file a request, so AIRCONCIERGE restrict you data processing.
Nonetheless the restriction of processing, we will still be entitled to:
Right to data portability
You are entitled to transmit your data, which you have provided to AIRCONCIERGE, to another controller, where:
Unfortunately, there might be cases, when your data transmission to another controller is not technically easible. In this regard we will try to do our best in providing maximum support, so another controller receives your data.
Right to object (opt-out)
In case AIRCONCIERGE processes your data:
You are entitled to object to such processing, specifying in your request the particular situation
(reason for objection).
In such cases we will not process your data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
There are also other cases set by LAWS, when you are entitled to object, as well as the conditions under which the right to object might be exercised.
Your rights regarding automated individual decision-making, including
You are entitled not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where the decision:
Right to lodge a complaint
Without prejudice to any other administrative or judicial remedy, you are entitled to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you c onsider that the processing of your data infringes LAWS and we are not able to settle a claim in an amicable way.
Please, be informed that each of your right and some of the principal provisions set herein might be restricted due to legislative measures, mostly to the advantage of other natural and legal persons, as well as national interests and public security.
AIRCONCIERGE might transfer your data to third country providing safeguards and
security measures, so the level of your data
protection is not undermined.
Such transfers might take place in cases, if:
without undue delay and in any event within one month of receipt of the request, except in cases, we are
not able to identify you (we are either not processing your personal data or it was anonymized/ erased).
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.
In case, your requests are manifestly unfounded or excessive (e.g., repeats the substance of previous requests within period of time of 12 months or providing false or misleading information), AIRCONCIERGE might refuse to act on the request explaining reasons or you might be charged a reasonable fee taking into account 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 a natural person and/ or to prevent identity fraud.
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.
In case you have any questions regarding your data processing by AIRCONCIERGE or you have any comments
The controller of your data is International Travel Network, LLC (Delaware, USA). The UK representative of the controller is TRAVELTECH ENTERPRISES LTD, having its registered address at 7 Hanover Square, Office 3.18, London, England, W1S 1BN.
to your privacy, except if LAWS set otherwise.
In case of material changes AIRCONCIERGE will definitely publish such amendments and amended policy on our websites and, as far as possible, notify you either by email or by pop-up windows when you are entering our websites next time.
Amendments shall enter into force on the Effective Date.