1 INTRODUCTION

When you use ClaimAir, you trust us with your information. We are committed to keeping that trust. That starts with helping you understand our privacy practices.

This policy describes the information we collect, how it is used and shared, and your choices regarding this information.

2 SCOPE

This policy applies to users of ClaimAir’s services anywhere in the world, including users of ClaimAir's apps, websites, features or other services.

3 PRINCIPLES

ClaimAir’s data protection policy is based on the following data protection principles:

Personal data shall be:

(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);

(d) accurate and, where necessary, kept up to date; every reasonable step must 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 (‘accuracy’);

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).

Data subjects shall 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.

By using the Service, you agree to the collection and use of personal data in accordance with this policy.

4 WHAT COMPANIES ARE COVERED BY THIS POLICY

The following companies are covered by this policy:

Short name: Full name

ClaimAir: ClaimAir s.r.o

Note: for ease of reading the companies are referred to throughout this policy by their Short name.

The Company is at this address: Dlouhá 730/35, Staré Město, 110 00 Prague 1

5 CLAIMAIR AS DATA CONTROLLER AND OUR RESPONSIBILITIES

ClaimAir is responsible for and is the Data Controller of your personal information that it receives through all ClaimAir websites. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Questions, comments, and complaints about ClaimAir's data practices can be submitted to ClaimAir via privacy@claimair.com.

6 CHANGES TO THIS PRIVACY POLICY

We may modify or update this privacy policy from time to time.

If we change this privacy policy, we will notify you of the changes by publishing an updated policy on this website. Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have (e.g. to object to the processing).

7 HOW DO WE COLLECT YOUR PERSONAL INFORMATION

These are the main ways we collect your information:

If you contact us directly via our websites or via our customer services to request information about our products and services.

If you buy a service directly from us.

If your contact details are transferred from authorized centers or other third parties.

8 KEEPING YOUR INFORMATION UP TO DATE

The User acknowledges that he/she is obliged to provide correct and true Personal Data (when registering, in his/her user account) and that he/she is obliged to reflect any changes of his/her Personal Data in the user account without undue delay.

Please help us to keep your information up to date by informing us of any changes to your contact details or privacy preferences. You may change or review your preferences in the user account.

9 WHAT INFORMATION MAY BE COLLECTED ABOUT YOU

The following types of personal information about you may be collected:

Purchasing our service

This type of information is collected when you contact ClaimAir, to enter into an agreement with us, to:

- help customers pursue their rights according to EC 261 or any other applicable air passenger rights regulation, when their flights have been delayed, cancelled or overbooked;

- inform travelers, free of charge, by e-mail about air passenger rights, flight data, airport data and other air traffic related services of relevance

This may include your name, surname, permanent residence address, email address, date of birth, telephone number, loyalty card numbers, bank account number numbers

User profile

We collect information when you create or update your ClaimAir account. This may include your name, email, phone number, login name and password, address, payment or banking information

Usage information

We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Policy.

Device Information

We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

Newsletters, marketing or promotional materials and other information

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

10 USE OF PERSONAL DATA

We will use personal data for the purpose it is collected and keep the data only for as long as it is necessary for that purpose.

We may retain the customer’s information for as long as the customer’s account is active or as needed to provide services, comply with our legal obligations.

We do not sell your personal data - such as your name and contact information - to third parties.

We use your data:

To provide and maintain our Service

To notify you about changes to our Service

To allow you to participate in interactive features of our Service when you choose to do so

To provide customer support

To gather analysis or valuable information so that we can improve our Service

To perform statistical analysis of the use of our Services

To monitor the usage of our Service

To detect, prevent and address technical issues

To send you newsletters, marketing or promotional materials and other information updates, recommendations, based on your interests and follows as well as general information, unless you have opted not to receive such information.

We may use the information we collect to investigate or address claims or disputes relating to your use of ClaimAir's services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

11 LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

ClaimAir legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

ClaimAir may process your Personal Data because:

We need to perform a contract with you

You have given us permission to do so

The processing is in our legitimate interests and it's not overridden by your rights

To comply with the law

12 YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

Access, update or to delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

Rectification: You have the right to have your information rectified if that information is inaccurate or incomplete.

Object: You have the right to object to our processing of your Personal Data.

Restriction: You have the right to request that we restrict the processing of your personal information.

Data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

Withdraw consent: You also have the right to withdraw your consent at any time where ClaimAir relied on your consent to process your personal information.

Complain: You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.

If you wish to:

- be informed what Personal Data we hold about you

- be removed from our systems

- exercise any of the rights hereinabove mentioned

Please contact the e-mail: privacy@claimair.com

13 SHARING OF PERSONAL DATA

Personal data will not be shared with third parties except in circumstances where such sharing is necessary to provide our services, as agreed with you.

In some occasions, ClaimAir will share your data provided under the services agreement, and only for that purpose, to the following categories of third parties:

- ClaimAir business partners (For example, if you requested a service through a partnership or promotional offering made by a third party, ClaimAir may share your information with those third parties. This may include, for example, business partners with whom ClaimAir may partner with to deliver a promotion or a specialized service.

- ClaimAir service providers

ClaimAir may provide information to its vendors, consultants, marketing partners, research firms, and other service providers, or external lawyers to pursue a claim for flight compensation, or technology companies for processing and delivery of systems and technologies to enhance our products and services. - For legal reasons or in the event of a dispute

ClaimAir may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect ClaimAir’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services.

This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

- With your consent

ClaimAir may share your information other than as described in this policy if we notify you and you consent to the sharing.

14 E-MAIL MARKETING

ClaimAir customers will always have the right to object, on request and free of charge, to the processing of personal data relating to the customer for purposes of direct marketing activities without having to provide specific justifications. Once a customer has objected, the personal data of that customer will no longer be processed for direct marketing. A customer can do so by using the “Unsubscribe” link found in emails received from us or by contacting us at privacy@claimair.com.

15 USE OF COOKIES

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. ClaimAir uses cookies and similar technologies for purposes such as:

Authenticating users

Remembering user preferences and settings

Determining the popularity of content

Delivering and measuring the effectiveness of advertising campaigns

Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services.

Please see our Cookie Policy for more information regarding the use of cookies and other technologies described in this section, including regarding your choices relating to such technologies.

16 COOKIE POLICY

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. Cookies served by the entity that operates the domain you are visiting are called “first-party cookies.”. Cookies served by companies that are not operating the domain you’re visiting are called “third-party cookies.” “Session Cookies” only last only as long as your browser is open. These are deleted automatically once you close your browser. “persistent cookies” survive after your browser is closed.

We may use or permit on our Services other technologies such as “Pixel tags” (small blocks of code installed on a webpage, app, or advertisement which can retrieve certain information about your device and browser), “Software Development Kits” ( like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function) The primary

Cookies are an important part of how our Services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Services, yet it is your right to choose whether or not to accept cookies

You can usually choose to set your browser to remove or reject browser cookies, following the instructions provided by your browser which are usually located within the "Help" or “Preferences” menu.

For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.allaboutcookies.org and www.youronlinechoices.eu.

17 INQUIRES

Any inquiries concerning this policy can be directed to the e-mail: privacy@claimair.com

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