The confidentiality of your personal data provided to us as part of our activity is very important for us. Through the present privacy statement we are providing you with information regarding the personal data we collect from you, through the means of our interactions, as well as the manner in which we use the data.

What is personal data?

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Every time we require your personal data, we do that for a distinct purpose, in your benefit, and we will hereby explain you the purpose for which we need your data, where we keep them, as well as who has access to them. Moreover, following a simple request, we shall provide you with any information regarding your personal data, and we shall also delete them upon your request.

What personal data do we collect/process (data type) and why (the purpose of collecting data)?

We collect personal data in order to be able to pick up and manage your requests regarding the amounts of money owed by the airlines. Moreover, we employ the data in order to implement, with respect to the website users, the internal policies and the legal obligations regarding the fight against money laundering, knowing the client (you) – KYC and identifying the ultimate beneficial owner – UBO. You provide directly some of this data, for instance, when you fill in the form for your request. You can make a choice regarding the data we collect, that is you have the right to refuse when are asked to provide personal data. If you choose not to provide the personal data needed in order to supply the service of picking up and implementing the request (completing the procedures towards the airlines), or in order to communicate with us, we shall not be able to execute your request and we will not obtain the compensation in question.

On the basis of the interaction you have with our website, the personal data we request are the following:

• Surname and name – for identifying and managing your request;

• Home address – for identifying and managing your request;

• ID card series and number for identifying and managing your request;

• Personal identification number – for identifying and managing your request;

• Copy / Image of your ID card or of other document mentioned by the applicable law as a primary identification document – for identifying and managing your request and for assigning an identity to the person signing the documents through the website integrated application;

• Bank account number – for managing your request and for paying you the amounts collected from the airline;

• Signature – for managing your request;

• E-mail address – to communicate;

• Phone number – to communicate;

• Data about the flight regarding which the request is made (copy/image of the e-ticket / boarding pass, reservation number, flight number, the problems encountered) – for managing your request;

• Information about the preferences regarding the language for communication; the ticket provider, buying habits, how have you heard about us? – optional data needed for better managing your request and for improving your experience with the website;

*The personal data required when filing the request, those of the requesting client, as well as those of other persons mentioned by the client in the compensation request (for which the client states that they have the consent of those persons for disclosing and employing their personal data for this purpose) are used for identifying and managing the request in relation with the airline, as well as for being able to contact you and to reply to your request. Additional data might be requested afterwards, in so far as they are requested from us by the airline or the court, in order for your request to be fulfilled.

Furthermore, when you interact with our website, certain data is involuntarily / indirectly sent, namely:

• IP address– When you visit our website, your IP address is registered. We do not use your IP address for identifying you or for any other purpose, but it is stored when you visit our website – mainly for security reasons. However, you have the right to request the deletion of your IP address.

• The operating system, the browser, the browsing activity, and other information regarding the manner in which you interacted with the website, and so on.

We can collect this information through cookies or other similar technologies in order to provide the best browsing experience (we improve your browsing experience, providing you with the version which is best adapted to your device), in order to prevent and detect the frauds against you or our website (we protect the website), in order to be able to provide data confidentiality.

For more information regarding the use of cookies on this website and the purpose of their use, as well as regarding your options to control and/or disable cookies, please consult our Cookie policy available on the website.

What is the legal basis for processing this data?

For the data you willingly provide to us (listed above) – the legal basis is different:

• your consent; (article 6 paragraph (1) letter a of the EU Regulation 679/2016) for picking up the compensation request against the airline and in order to complete it;

• action requested by the person concerned before signing a contract or in order to execute a contract (article 6 paragraph (1) letter b and c of the EU Regulation 679/2016) for executing the compensation request and completing the steps against the airline;

Executing a contract of which the user is part, namely the Terms and conditions; The vested interest constituted by the common interest of W AIR CLAIMS, LCC and the used of developing a commercial relation; complying with the legal requirements of the company in order to prevent and fight against money laundering, knowing the client and identifying the ultimate beneficial owner.

Regarding the data we automatically collect through cookies or other similar technologies, the basis for processing them is the consent. Once you access the website and select the option YES/I agree you have expressed your valid consent regarding the processing of the data.

The consent for commercial communication sent by the Company or the vested interest for sending communication to the users who have previously bought similar services of the Company, according to the applicable legal provisions. The option to unsubscribe is provided in all the commercial communications sent to you, regardless of their nature.

W AIR CLAIMS, LCC can supply references of links to other websites, such as Facebook, LinkedIn, Instagram, Twitter, YouTube (“External websites”). The company does not control either those eternal websites (third party websites), or their content. You agree to the fact that W AIR CLAIMS, LCC is in no way responsible or liable for the external websites referred to or the links listed on the website.

W AIR CLAIMS, LCC can process the personal data of the social networks users only if they communicate directly through these platforms (for instance, posted articles, likes, direct messages, questions addressed by the users, comments, and so on). In cases like these, W AIR CLAIMS, LCC is, also, responsible for processing the personal data collected through this method. Besides the data we process, other providers, especially social networks operators, also process the personal data of the users. The company has no influence whatsoever on this data processing and is not responsible for it – data processing takes place exclusively within the responsibility are of these providers. The amount of time for which we store the personal data: We store the personal data only for the amount of time needed in order to fulfill the purposes mentioned, but only until the moment that you request their deletion, observing the legal period regarding the handling of the registered request, unless otherwise stipulated by law.

To whom do we transfer the personal data?

We will not disclose your personal data to third parties, in order for them to use the data to their own commercial purposes, without your consent.

However, it is possible to disclose your personal data to service providers. Thus, we might disclose your data to other companies providing services to us and acting on our behalf, such as the companies that provide us billing services, the companies that provide us website maintenance services or that send e-mails on our behalf, or the law firms, in order to submit legal claims for the payment of the amounts, according to the requests.

However, these providers are very carefully selected in order to make sure that they fulfill the specific requirements in the field of personal data protection, basically, we are doing our best to make sure that all the entities with which we work store and process your personal data safely and securely and that they obey terms and conditions providing a similar / minimal level of protection to the one described in the present Confidentiality policy.

Moreover, the personal data that we disclose to our data processors is limited to the minimum amount they need in order to complete those services; at the same time, they have a limited capacity of using your data for purposes other than supplying services to us.

We are doing our best to make sure that all the entities with which we work store and process your personal data safely and securely and that they obey terms and conditions providing a similar / minimal level of protection to the one described in the present Confidentiality policy.

The personal data you provided, containing identification data, can be used in commercial communications, if you gave your consent, or in replies to the requests sent by you. In the case of fulfilling certain legal obligations (in the case of legitimate requests), your personal data will be sent / provided to the state authorities or to other legitimate parties, if the case may be.

Besides the disclosures described in the present Confidentiality policy, we might disclose data to other third parties, if you consent or ask us to make such disclosures.

In so far as, in the context of the operations mentioned above, your personal data imply the transfer of personal data abroad, they can be transferred to other member states of the European Union (EU) or of the European Economic Area (EEA) (for instance, in data centers around the world, where W AIR CLAIMS, LCC facilities or service providers are), any transfer conducted by the Company to a EU or EEA member state will comply with the GDPR legal provisions.

If certain airlines / suppliers are outside EEA/EU, based on your consent, the data will be communicated using various transfer mechanisms in order to ensure the protection of the transferred personal data, as follows: in relation to the provider/airline.

What are your rights as the data subject?

The protection of natural persons regarding personal data processing is a fundamental right. Article 8 paragraph (1) of the Charter of Fundamental Rights of the European Union (“CFR”) and article 16 paragraph (1) of the Treaty on the Functioning of the European Union (TFEU) stipulate the right of every person to personal data protection. Regulation 679/2016 concerns and entirely treats the manner of collecting, operating and processing personal data.

The rights of the natural persons / data subjects regarding the personal data are:

• the right to be informed Art. 13 and Art. 14

• the right of access Art. 15

• the right to rectification Art. 16

• the right to erasure (the right to be forgotten) Art. 17

• the right to restriction of processing Art. 18

• the right to data portability Art. 20

• the right to object Art. 21

• the right not to be subject of automated individual decision-making with legal effect Art. 22

Upon the request of the natural persons, the Operator confirms whether or not they process their data, the type of data, as well as the aim. If the processing of any data does not comply with the Regulations, then the Operator undertakes to rectify, update, block, delete or to anonymize, if the case may be, free of any charge, the data in question. According to the Regulations, the natural persons have the right of access, the right to rectify the data, the right not to be subject of individual decision-making (the automated individual decision-making process, including profile creation) and the right to go to court, the right to file a complaint with the supervising authority. They also have the right to object to their personal data processing and to request their data to be erased, except those situations stipulated by the law, when it is compulsory for the data to be processed by the Operator. In order to exert these rights, you can file a written request, dated and signed, with the operator, at the principal place of business of the company, or using the e-mail address of the DPO. If some of your data is incorrect, please inform us as soon as possible in order to update it to the correct form.

Data processing security

W AIR CLAIMS, LCC constantly assesses and updates the implemented security measures, in order to ensure the safety and security of personal data processing. These security measures include password protected folders and databases; PCI scan technologies in order to actively protect the company servers from hackers and from other vulnerabilities, but without limitation thereto. The encrypted information is safely stored in the W AIR CLAIMS, LCC database. Only the authorized and trained personnel of the Company are allowed to access your personal data, and they are required to treat your data as confidential information.

Age requirements

Our website is not intended for persons younger than 18 years, but they can access our services through the request of a legal representative / authorized person.

Modifying the confidentiality policy

You shall be notified every time we modify our confidentiality policy. The new confidentiality policy will become effective when published on the website.

Contact

If you need other additional information about personal data processed by the operator through the W AIR CLAIMS, LCC website, products or services, please contact us by e-mail at: [email protected]