Privacy and Cookie Policy

travelyn.com

1. General information

  • This Privacy Policy comes into effect on 1.03.2020.

  • The Privacy Policy sets out the rules of processing and protection of your personal data, collected in connection with provision of flight search, booking and purchase services to you through the travelyn.com website and its mobile version (the “Website”). The Privacy Policy also outlines the rules around collection and use of cookies and similar technologies.

  • Travelyn AB with its registered seat at c/o Saldoredo AB, Folkungagatan 108, 11630 Stockholm, Sweden („TRAVELYN”) is the controller of your personal data and takes appropriate steps to ensure security of your data.

  • By starting to use the Website or by your continued use of our services following the posting of new versions of this Privacy Policy (as applicable), you confirm that you have read and agree to be bound by provisions of the Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy forms part of, and should be read in conjunction with, our Terms of Use and any additional applicable terms of our services.

  • For important reasons, we may periodically be required to make changes to our Privacy Policy (for example if we substantially change our services or the Website's functions, or following legislative changes). We will notify you of these changes by e-mail, as well as by posting the modified Privacy Policy on the dedicated website:travelyn.com/privacy. We recommend that you revisit this Privacy Policy regularly. The date of the last review of the Privacy Policy will always be indicated at the top of the document.

2. What data do we collect? Scope, purposes and legal bases of processing

  • Contact data. To allow us to contact you, we request that you provide the following personal data: your e-mail address, name, surname and telephone number. Provision of at least your e-mail address is mandatory – otherwise, we will not be able to contact you.

    Purpose: Enabling you to contact TRAVELYN and allowing us to communicate with you with relation to your use of TRAVELYN’s services (among others for the purpose of sending you itineraries, boarding passes, other information regarding your bookings and responding to your requests, including processing of your complaints).

    Legal basis: Your personal data are processed based on Travelyn’s legitimate interest in responding to your messages, as well as contacting you in relation to our services used by you and any technical or organisational matters relating to your account or use of services. Processing of the aforementioned data is also necessary for the purpose of performance of contract with you.

    How long do you process your data? Your personal data is processed for as long as you keep expressing your interest in our services, however, not longer than for 2 years from the date on which we last heard from you. We will also stop processing your data when you request that we delete your personal data, unless there are other applicable legal bases for the processing.

  • Content of messages sent by you and other requests. The Website enables you to send messages to TRAVELYN. We process your personal data such as name and surname, e-mail address and all the other information which may be included in the communication or requests. We also process your data collected through telephone requests.

    Purpose: Responding to your messages and queries, and providing customer support to you.

    Legal basis: TRAVELYN’s legitimate interest in providing information to users, potential clients and providing customer support.

    How long do you process your data? Your personal data is processed for as long as you keep expressing your interest in our services, however, not longer than the limitation period of potential claims, following from generally applicable provisions of law.

  • Data related to ticket bookings. In order to make it possible for you to book and purchase tickets through our Website, we collect and process the following personal data: name and surname, date of birth, nationality, passport/ID data of the passenger and/or the person who makes the booking, e-mail address, payment information (including transaction amount), order history and itineraries; We also process information included on your tickets and boarding passes, such as booking reference numbers, allocated seats etc.

    Purpose: Enabling and processing bookings and payments, delivering tickets and boarding passes to you. Providing customer service and conducting business analytics.

    Legal basis: The processing is necessary for the conclusion and performance of the agreement with you.

    How long do we process your data? Your personal data is processed for as long as it is required by law for tax and accounting purposes, i.e. for the maximum of 6 years.

  • Your personal data may also be processed for the purpose of defence against claims or safeguarding our legal rights. In such an event, we process your data based on our legitimate interest in defending our claims, until conclusion of legal proceedings or expiry of statutory limitation periods, whichever happens first.

  • Data collected through cookies and other technologies. Through the use of cookies and other technologies, we collect device and network metadata, such as: information on the device you use, the type of browser, your IP address and other device IDs, as well as information on your behavior on the Website and your interaction with it. You can find more information on the use of cookies and similar technologies in Section 5 below.

    Purpose: We process such data for the purpose of providing access to the Website, ensuring you see the proper language version, improving your user experience, ensuring security (including fraud prevention), recording your preferences and for direct marketing purposes of TRAVELYN’s services.

    Legal basis: Depending on the types of cookies, and technologies applied, the processing of personal data may be performed on the following bases: (i) TRAVELYN’s legitimate interest in ensuring security and improving the Websites’ functionalities, as well as providing you with the best user experience and direct marketing of our services; (ii) consent to processing of your personal data for marketing purposes, insofar as TRAVELYN may not act on the basis of legitimate interest – such consent can be withdrawn at any time, which will not affect the legality of the processing performed prior to such withdrawal.

    How long do we proces your data? Your personal data is processed for as long as necessary for the purposes listed above, i.e. 14 months from the date of collection.

  • Data processed to inform you about special offers and deals. We may process your personal data (e-mail address, name and surname) for the purpose of informing you about special offers and deals which may be of interest to you. Your personal data may also be used for the purpose of direct marketing of Travelyn services, on condition that you grant a separate consent to telephone and/or e-mail contact and you don’t object to the processing of your personal data for marketing purposes.

    Purpose: Keeping you up to date with offers and deals.

    Legal basis: Your personal data are processed base on Travelyn’s legitimate interest in conducting direct marketing activities.

    Consent to phone and/or e-mail contact for marketing purposes. Your personal data is processed for marketing purposes based on Travelyn’s legitimate interest. However, to enable us to contact you, it is necessary for us to obtain additional, voluntary consent. Such consent may be withdrawn by you at any point.

    How long do we process your data? Your personal data is processed for as long as you keep expressing an interest in our services, however, not longer than for 2 years from the date on which we last heard from you. We will also stop processing your data when you request that we delete your personal data processed for marketing purposes.

3. Your rights

You have the right to object to the processing of your data by us, when it is based on legitimate interest (in particular when processed for marketing purposes – in such cases we will immediately stop processing your personal data). You also have the right to request that we correct or delete your data, if you find out that certain information about you is incorrect or outdated.

If you file a request that we stop processing your data and delete it, we will do so unless there exists an important overriding legal interest (e.g. defense of claims or existence of a legal obligation to retain the data, for example for accounting or tax purposes) which will entitle us to keep your personal data for a longer period. You also have the right of access to your data, to request a copy of data that we process about you, as well as the right to data portability and to restriction of processing.

If you have any questions with regard to the processing of your data by us or if you wish to exercise your rights, you can contact us at support@travelyn.com. You also have the right to file a complaint to data protection authority.

4. Data recipients

We entrust the processing of your personal data to entities, which act on our behalf and solely based on our instructions (data processors). In particular we use data processors, whom we select carefully, to store your data on secure servers located within the territory of the EU. Appropriate safeguards are applied, in particular we take care to appoint only trusted and verified processors and we sign GDPR-compliant data processing agreements with them, in particular to enable processing of payments and booking of tickets.

We share your personal data with payment service providers for the purpose of processing your payments for bookings as well as with airlines and other travel companies, with whom you book your travel. The transfer is made based on our legitimate interest and because it is necessary for the performance of the contract with you. We may also be obliged to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).

We may also be obliged to share your data in case we buy or sell subsidiaries or business units, in connection with a corporate transaction, such as: a sale, merger, consolidation or asset sale, or an internal reorganisation, or in the unlikely event of an insolvency. If such a transaction or event required the transfer of customer information, that information remains protected by the regulations of any pre-existing Privacy Policy or equivalent. You will also be notified of such a transfer beforehand.

5. Use of cookies and similar technologies

In order to improve the operation of the Website, we use cookies, web beacons, device fingerprinting and similar technologies. We also make use of the Google Analytics tools.

Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognise a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. The following types of cookies are used on the Website:

  • Persistent cookies - these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

  • Session cookies - these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

  • Strictly necessary cookies - These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

  • Performance cookies - These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.

  • Functionality cookies - These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device. These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

  • Targeting or advertising cookies - These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by a third party organisation.

Web beacons (also known as pixel tags) are transparent image files used to monitor your journey around a single interaction with the Website and its content.

Device fingerprinting is a technology which allows us to collect information about your device (what browser or operating system you use, plug-ins, time zone, other settings). We use this information to identify you and to ensure security of our website.

Cookies and similar technologies (including web beacons, device fingerprinting) are used for statistical purposes: to adapt the website content, performance and structure to users’ individual preferences, and to provide users with advertising content adapted to their preferences. Cookies and web beacons for targeted advertising purposes can be linked to other online services, such as Facebook. Please note that cookies may collect personal information to enhance the site's functionality. Such data is stored in encrypted form and the access to them is limited. Cookies that are used by the third parties via the Website, including in particular the users of the website, are subject to their own privacy policy.

Handling and use of "cookies" and similar technologies is allowed automatically. However, these settings can be changed at any time. For details on how cookies are handled and used, see the settings of your web browser. You can learn more about cookies and similar technologies and check how to disable them for the browser you use by visiting the following website: http://www.allaboutcookies.org.

Google Analytics: we use third party trackers to let us know when users have visited the Website by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Website uses Google Analytics & Firebase code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Website and the volumes of usage of the Website. This is done to ensure that the Website is functioning well and available when you need it. For more information on how Google Analytics processes this information, visit: www.google.com/analytics.

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