FindAir

PRIVACY POLICY

FINDAIR PRIVACY POLICY

Effective as of June 1 ^st , 2018

This policy describes FINDAIR LIMITED ("Findair") practices regarding personally identifiable information and data ("personal information"). This policy applies to our websites, applications, email and text messages, and social media accounts (the "Platforms"). When you use the Platforms, you agree to the terms in this policy.

1. The categories of Personal Information we collect

1.1. Platform information: When you visit the Platforms, we may collect information from you. Some of it may be personal information. This information can include search history, IP address, screen resolution, browser used, operating system and settings, access times and referring URL. If you are using a mobile device, we may also collect data that identifies your device, your settings and your location.

1.2. Booking information: If you book a travel product via the Platforms, we may need additional information from you. This information can include your name (and traveler’s if different) name, age, birthday, gender, passport number, redress control number, email address, telephone number, credit card information, billing address, itinerary and frequent flyer details. You can also choose to store personal information in your user account for future bookings.

1.3. Account information: If you choose to register, we will collect your email address, password and home airport, and other preference information you provide us. If you choose a third-party service, like Facebook Login, to register or login, you are permitting us to use and store that information related to the account.

1.4. Consumer support: If you choose to contact our consumer support services we will collect any inquires, complaint or other information that you may submit to our support team.

1.5. Promotional information: If you choose to participate in a sweepstake, contests or similar campaign we will collect any information you provide in relation to such activity such as photos, images, captions or other content, in accordance with the terms provided at that time.

When you give us personal information, 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.

2. How we collect your Personal Information

2.1. Personal information you give to us: We collect your personal information directly from you. For example, when you provide us your personal information when you register or book travel, contact our customer support or participate in a contest or sweepstake.

2.2. Personal information we collect passively: We also collect your personal information passively. For example, we collect information about you over time and across different Web sites when you visit this Platform. We also use tracking tools like cookies and beacons.

For more information about cookies, refer to http://www.allaboutcookies.org/.

Platform features may make use of your device attributes and settings that will allow us to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to enhance and personalize your experience and provide you with offers and services that may be of interest to you. For example, we may help you find your closest hotel or send you messages that may be of interest to you based on your current location. Findair 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.

2.3. Personal information we receive from third parties: We collect your personal information from third parties. This can include when you log in using a third party platform, such as Facebook. In addition, we also integrate third party software (i.e. Google’s Invisible CAPTCHA) that collects information about users for security reasons.

3. For what purposes we use your Personal Information

Your personal information may be used in the following ways:

3.1. Improving our services: To provide you and improve our Platforms and services, to better understand the users of our Platforms and services, and to protect our property and to prevent damage to them.

3.2. Bookings: We and our travel partners use your personal information to process your bookings and store your itinerary information where applicable.

3.3. Marketing activities: We use your information for marketing purposes. These activities may include:

To send you marketing emails from a Findair address regarding our services or those of our partners, if you have opted-in to receive emails from us or have transacted with us, and as permitted by law. You can easily unsubscribe from these marketing communications at any time by clicking on the "Unsubscribe" link included in the newsletter

To display more relevant advertising and recommendations, or suppress advertising and content that you might find irrelevant. This advertising might be shown to you on our Platforms as well as third party platforms (including social media sites) and include information or offers that we, or our business partners’, believe you will find interesting. Individualized advertising may be based on information collected through cookies or other tracking technologies.

If you choose to participate in promotional activities (such as sweepstakes, competitions or other similar campaigns), relevant information may be used to administer these promotions

To communicate with you, including as follows:

To send booking confirmations.

To send alerts and notifications you have subscribed to, including to your mobile device.

To solicit reviews.

To communicate with you if you have contacted Findair consumer support.

To send you information servicing and administrative emails.

To send you information about services, offered by Findair or our business partners, that we believe you would be interested in.

3.4. Legal purposes: In certain cases we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance or to enforce the terms of use of the service.

3.5. Performance of a contract: The use of your personal information may be necessary to perform the services and provide you products that you have requested from us. For example, if you make a booking on our Platform, we need to collect personal information from you in order to complete the booking.

3.6. Legitimate interest: We may use your personal information for our legitimate interests, such as displaying relevant advertising and recommendations and for legal purposes.

3.7. Consent: We may rely on your consent to use your data for certain direct marketing purposes. You can withdraw your consent anytime by contacting us or change your settings in your account as described below.

4. Your Choices

You can manage your communication preferences in your account. Marketing email has an opt-out URL and you can unsubscribe from such communication at any time. You cannot unsubscribe from servicing emails and administrative messages that are considered part of your account membership, unless you cancel your membership.

5. How we share your Personal Information

5.1. Corporate affiliates and change of control: We may share your personal information with our corporate affiliates and if Findair itself (or part of its business) is sold or otherwise changes control, owners would have access to your personal information for the uses set out herein.

5.2. Service providers: We may share your personal information with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information.

5.3. Payment service providers and travel vendors: If you book through the Platforms, we may share your personal information with the payment service providers and the travel vendors you have booked with. This can include online travel agencies, hotels, airlines, car rental companies, and travel insurance providers. These third parties will process your personal information as data controllers in accordance with their own privacy policies. If you contact our consumer support, they may need to share information about your request with the relevant travel vendor in order to assist you.

5.4. Business partners: We may share your personal information with various business partners. Some of these business partners may use your personal information for online behavioral advertising purposes, or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. For example, if you provide information to enter a sweepstakes, we may share your information with the promotional partners. We may also share anonymous aggregated usage information with partners.

5.5. Information shared in public: If you provide us a review of your trip, you authorize us to publish it on all our Platforms under the screen name you provided. You also authorize us to aggregate it with other reviews.

5.6. Authorities: We may disclose personal information if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your personal information if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.

We may also share anonymous aggregated usage information with others.

6. How we store and protect your Personal Information

Our servers and data centers are located in Ireland, Europe, and our service providers may be located there and in other countries. By providing us personal information, you agree that your personal information may be transferred to and stored in these countries. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your personal information may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries. Subject to the applicable laws in such other countries, we will provide the necessary safeguards to maintain protections of your personal information, e.g. by obtaining from the data recipients contractual commitments based on the EU model clauses.

Findair has a security program intended to keep the personal information stored in our systems protected from unauthorized access and misuse. Our systems are configured with data encryption, or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the data you send over the Internet. Personal information may only be accessed by persons within our organizations, or our third parties to carry out the uses indicated in this Privacy Policy. In addition, information collected by Google’s Invisible CAPTCHA is held in accordance with the Google Privacy Policy.

7. Retention periods

We will retain your personal information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information.

We will also retain your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our contracts.

8. Cookies and tracking tools

Findair uses cookies and tracking tools.

For more information about cookies, refer to http://www.allaboutcookies.org/.

9. Other Websites

If you click through to third party websites or other platforms, Findair’s privacy policy does not apply.

10. Children

Findair does not knowingly collect personal information from minors. If we become aware that a minor is attempting to submit personal information, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us personal information, please contact us so we can delete it.

11. Changes to the Privacy Policy

We may modify this Privacy Policy at any time and without prior notice. We will notify you of material changes to how we use your personal information prior to implementing them. We may notify you about such a material change by email or prominent notice on our website. By using our services and Platforms after we post these changes, you indicate you accept them.

12. Your rights with respect to personal information

Before contacting Findair for any request you may have, note that you can manage your account settings in the "My Account" page on the Platform.. Your rights:

Access: You are entitled at any time to obtain information about your personal information that we store, in accordance with applicable law and without any fee. However, in exceptional cases we ask you to pay reasonable fee before we provide the information if permitted by applicable law.

Rectification: You may request that we rectify any of your personal information that is incomplete or incorrect.

Deletion: You may request that we delete your account.

Objection: You may object, at any time, to your personal information being processed for direct marketing purposes.

Restrictions of processing: You may ask us to cease processing of your personal information for example if you have objected to the processing and the existence of legitimate ground is still under consideration.

Right to withdraw consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn.

We may request proof of your identity before acting upon any request. We may not be able to allow you to access certain personal information in some cases. For example if your personal information is connected with personal information of other persons, or for legal reasons. In such cases we will provide you with an explanation why you cannot obtain this information. We may also deny your request for deletion or rectification of your personal information due to statutory provisions, especially those affecting Findair’s accounting, processing of claims, and mandatory data retention, which may prohibit deletion or anonymization.

13. How to contact us or how to lodge a complaint

Findair Limited. controls the processing of personal information on its Platforms. To exercise your rights, or if you have questions about our privacy practices or need assistance with exercising or understanding your privacy choices, please contact our Data Protection Officer at support@findair.co.uk or you may write to:

Findair Limited.

Attention: Data Protection Officer

60 Gracechurch Street, London