FlyOcheap, LLC (“FlyOcheap” or “Company”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Notice and Policy (this “policy”) describes the types of information we may collect from you or that you may provide when you visit www.flyocheap.com and the Company’s mobile website and mobile and tablet applications, or use any content, functionality and services offered on or through www.flyocheap.com and/or the Company’s Application (“App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
As a travel search engine, FLYOCHEAP connects travelers with travel services and products offered by third parties, such as flights, accommodations, rental cars, packages, and travel insurance. This involves sharing personal information with third parties, including online travel agencies, hotels, rental car providers, airlines, and others (collectively, “travel partners”).
ABOUT THIS POLICY
You’ll come across the term ‘personal data’ a lot in this policy. By that, we mean any information relating to you as an identifiable individual. For example, this includes information that may of itself identify you such as your name, contact details, trip itinerary, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.
CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age. No one under the age of 16 may provide any information on or through the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com
We will obtain your consent for purposes such as:
sending you emails for services you request such as Price Alerts;
sending you direct marketing communications via email, push notification or other means where you have consented to us doing so;
storing certain cookies on your device, where doing so requires consent; and
recording and evaluating feedback you give us where you agree to take part in one-to-one user testing.
Where we process your personal data based only on your consent, you can withdraw this consent at any time either by using the functionality provided within the appropriate product feature or by contacting us on firstname.lastname@example.org
Where it’s necessary to exercise or comply with our own legal rights or obligations.
We may need to retain and use your information in connection with legal claims, or for compliance, regulatory and auditing purposes. For example we may retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any applicable legal rights you have to access, amend or delete your personal data, we may request identification and verification documents from you for the purpose of confirming your identity.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Everyone who uses our services will have bits and pieces of information about them collected, stored and processed. However, we don’t collect more information than we need.
We can’t help you plan and book your dream trip without information. So, when you use our services, we have to collect, keep and share some personal data and ask that you agree to that in line with this policy. We collect information in three ways:
You give it to us voluntarily
Information you choose to give us might include personal data needed for you to book travel for yourself and others. This ranges from the dates and destination you choose in a search, to the basic stuff for making a booking with a Travel Supplier such as names and contact details. It can also include content like the reviews or photographs you upload to our services to share with other travellers. Most importantly, it’s always up to you whether or not you choose to give us this kind of information.
We generate or collect it automatically
We generate or collect some information from your computer or device automatically as you use our services. This includes stuff like your IP address, information about the device and browser you are using to access our services, the website URL you visited us from and the third party sites you visit when you click on links to exit the Flyocheap site. It also includes details of the bookings you have made via Flyocheap. We may also know your location from your mobile or your IP address. This helps us to improve your experience and make sure you receive the content that’s most relevant to you.
We receive it from third parties
Sometimes we’re given information about you from third parties, depending on how you choose to interact with us. For example, when you come to our website via a promotional partner, or when you log into your Flyocheap account using our social network login feature. And, if you’ve made a booking with a Travel Supplier, we might collect information from them about whether you went ahead with your trip, what you booked and whether your booking was successful. We may also collect information about you from fraud prevention services providers we cooperate with to prevent misuse of your personal data.
Depending on how you interact with our services, we may collect or process the following categories of personal data via the three different ways explained above.
Contact Information: such as your name, address, email address, telephone number and other similar information.
Identification information: such as a copy of your passport or other identity confirming documentation which may contain information like your name, address, gender, nationality and date of birth.
Payments information: such as your credit or debit card number, expiry date and verification code when you book travel via our services.
Booking information: such as, for each traveler, the traveler’s name, frequent flyer details, passport number, redress control number, country of citizenship, booking reference number, and itinerary, which may include name of airline or carrier, hotel accommodation and/or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover information.
Demographic information: your age, gender, location and preferred language when you use our services.
Device and Location information: generic details from your device such as your IP address, type, make, model and operating system of your device, specific location data based on GPS data from your mobile device (when you grant us access to this information via your device settings) and non-specific location based on your IP address.
Account information: such as login credentials, including email address and password, and account settings, how you’ve interacted with our services, including time you spend on our site and/or app and the pages, features or functionality you have accessed, links you have clicked on to be redirected to or from our services, including the identity of the Travel Supplier you are redirecting to and the type of travel service you have selected and where you’ve redirected to a Travel Supplier’s website or app for the purposes of completing a booking, we may collect information from that Travel Supplier about whether and what you went on to book with them.
Communication information: includes communications we receive from you such as feedback, help requests and queries via email and other electronic communication methods such as online chat, instant messaging or social media and metadata associated with those communications, such as time and date.
Social Media Information: email address is automatically collected by us from the third party social media platform you log in to Flyocheap form.
Preferences information: such as your home airport, seating preference, meal preferences, communication preferences and other preferences you provide us.
You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.
We do not proactively collect sensitive personal information, such as health-related information. However, our Services include text boxes that are designed for you to describe certain details about your travel preferences or special requests that you want us or our travel partners to know. Please be aware that information you freely submit in these boxes may reveal to us or to the travel partners or third parties with whom we share information (as detailed in the Disclosure of Your Information section below) certain information that may be considered sensitive personal information under applicable law (for example, information about dietary restrictions or disability accommodations). Sensitive personal information you voluntarily submit is processed on the basis of your consent, which you may revoke at any time by contacting us at the details set out in the How to Contact Us section below.
Device information: When you visit or use our Services, we automatically collect certain information about your device (e.g., your mobile device, computer, or tablet), including information about your hardware and software, device configuration, and nearby networks. Such data may include data about your device operating systems, browsers, and other software installed on your device; such as IP address or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.
Usage and performance information: We also automatically collect personal information about your usage of the Services, including information about your searches, statistics about the travel itineraries you share with us, how you interact with the features of our Services and the links you click, your preferences, access times, referring URL, and performance of our Services.
Location information: If you use our Services, we automatically collect approximate location information about you (such as your city) or, with your consent, precise geographic location data from your mobile device when the app is running and when it is not running, depending on the choices you make when you are asked to consent to our collection of location information. The technologies we use to determine your location may include IP address mapping, cell tower position, Wi-Fi position and GPS signals. We may use and store this information to provide and improve features of our Services, for example, to tailor our Services on a needs-based manner to better facilitate your requests (such as helping you find the hotel closest to you) and to provide you with more relevant content in the cities you visit (such as sending you marketing communications relating to goods or services in your current city, including local accommodations and travel options). Flyocheap does not have control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location-based features and functionality offered. Please see the Your Choices and Rights section below for more information about how to adjust your preferences, including those related to location information.
Inferences about you: We combine the information we collect, generate, or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the advertising we and our partners display or offer to you.
Personal Information We Obtain from Third Parties: We may also receive certain categories of personal information from third parties, such as third-party websites, applications, social media networks, and services (each, a “third-party platform”),our group companies, travel partners, and other third parties, including individuals who have shared their travel itineraries with you through our Trips service. If you are an existing FLYOCHEAP user, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of personal information we may obtain from third parties includes:
Email address or other contact information
Social media data, if you connect to our Services using a social media third-party platform or interact with FLYOCHEAP by liking or commenting on our social media pages or content, we may receive information from that social media third-party platform about those interactions and from your social media profile (e.g., name, age, gender, photograph, and other personal information related to that account)
Browsing, purchase, usage and advertising details, including information about restaurant or travel accommodations and bookings you make through our group companies and travel partners (for example, if you book a flight through one of our group companies, we or our travel partners may receive the general location of your destination and use that information to provide recommendations for hotels or other accommodations or complementary services); how you use third-party websites, applications, and services; information relating to your interactions with our advertising and marketing materials; and demographic information about users of our Services.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Your Choices and Rights” below.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including payment processing, billing and collection.
To fulfill your travel reservations and purchases, to communicate with you regarding your reservations and purchases, and to otherwise provide you with information, products, or services that you request from us.
To notify you about changes or updates to our Website, App or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website or App.
To promote our products and services by sending you marketing and advertising communications that we develop and believe may be of interest to you.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
To contractors, service providers, and other third parties we use to support our business, but only to the extent such parties are necessary for the fulfillment of your travel arrangements. Generally, it will be necessary for us to process personal data via a third party, including, but not limited to, airlines, hotel vendors, car rental companies, and entry visa or passport companies, in the course of completing your purchases of travel.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Flyocheap’ assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Flyocheap about our Website users is among the assets transferred.
To third parties to market their products or services to you.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent
We may also disclose your personal information to fulfill our legal obligations:
To comply with any court order, subpoena, law, or legal process, including to respond to any government or regulatory request.
If we in good faith believe that disclosure is necessary to conform to the edicts of law, prevent or investigate fraud, protect your safety or the rights, property, and/or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Notice to EU Individuals: Under applicable law, the Company will not process and disclose your personal data without a lawful basis to do so, as such bases are defined in Article 6 of the GDPR. In general, at least one of the of the following must apply whenever personal data is processed;
Consent. The individual has given clear consent for the processing of their personal data for a specific purpose.
Contract: the processing is necessary for the performance of a contract.
Legal obligation: the processing is necessary to comply with the law.
Vital interests: the processing is necessary to protect someone-s life.
Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for the legitimate interests of the data controller, unless there is a good reason to protect the individual-s personal data which overrides those legitimate interests.
NOTICE OF RIGHTS OF EU INDIVIDUALS
As a “Data Subject” within the meaning of GDPR, under applicable law you have certain rights that you may exercise to protect your personal data, which you can exercise at any time. These Date Subject rights are:
Right to be informed – you have the right to inquire about what personal data (about you) we process and the rationale for such processing.
Right of access to information – you have the right to request a copy of the personal data that we collect and process for you. If we refuse your request under your right of access, we will provide you with a reason as to why and you will have the right to complain to a relevant data protection supervisory authority about our processing of your personally identifiable information.
Right of rectification – you have a right to correct any inaccurate or incomplete data that we collect and process for you.
Right to restriction of processing – where applicable, such as when there is a pending legal dispute or the data is being corrected, you have a right to temporarily restrict the processing of your data.
Right to be forgotten (right to erasure) – in certain circumstances you can ask for the data we collect about you to be erased from our records.
Right of portability – you have the right to have the data we collect about you to be transferred to another organization and for such data to be provided in a commonly used, structured, and machine-readable format.
Right to withdraw consent – you have the right to withdraw a previously given consent for processing of your personal data for a specific purpose.
Right to object – you have the right to object to certain types of processing, such as using your personal data for direct marketing and advertising. This also applies to profiling, where appropriate, insofar as it is associated with such direct marketing and advertising.
The Data Subject may exercise these rights at any time by contacting the responsible party. The responsible party, according to Article 4 (7) of the GDPR, is Flyocheap, LLC, 2602 Starlight Valley St., Henderson, NV 89044. E-mail: email@example.com.
YOUR CALIFORNIA RIGHTS POLICY
California Civil Code permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
YOUR CHOICES AND RIGHTS
If you’ve got a Flyocheap account, you can access, edit, download or delete the key personal data associated with your profile at any time by going to your Profile. From here you can also manage your subscription and marketing preferences.
You also have rights in relation to the personal data we have about you, which we explain in more detail below. You can exercise these rights by getting in touch with us via our Help Centre.
If you are a California resident, learn more about your rights under the California Consumer Privacy Act.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request at email@example.com or you can unsubscribe.
Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request at firstname.lastname@example.org or you can unsubscribe. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request at email@example.com or you can unsubscribe. For this opt-out to function, you must have your browser or smartphone set to accept browser cookies.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on NAI’s website.
Safeguarding your privacy is embedded in our culture and we use a combination of industry-standard methods to protect it.
Keeping your personal data secure is our highest priority. We limit access to only FLYOCHEAP employees who have to come into contact with your information to do their jobs and deliver our services.
Unfortunately, no website or app can guarantee complete security but we have created an organisation-wide security programme designed to keep your personal data as safe as possible. It uses a range of technical, organisational and administrative security measures and best-practice techniques, depending on the type of data being processed. For example, the computer systems we use to store your data have access limitations and in-cloud based servers that use industry-standard disc encryption. We use HTTPS encryption to protect your personal data when we transfer it across the internet. And we carry out security assessments on Third Party Processors who handle your data.
To make sure we maintain a culture of ‘Privacy by Design’, we provide thorough data protection and privacy training to all FLYOCHEAP group employees. We develop our services with the goal of using the minimum amount of personal data possible, including through use of data minimisation techniques like anonymisation and pseudonymisation. Also, whenever we develop or update our services in ways that involve the collection or use of new forms of personal data, we conduct a privacy impact assessment to understand, and reduce, the likelihood of any unintended impact on you.
PROCESSING YOUR INFORMATION
CHANGES TO THIS POLICY
To ask questions or comment about this policy and our privacy practices, or to reach the data protection coordinator, please contact us a: firstname.lastname@example.org.