Effective January 1st
DeluxeFlights (“DeluxeFlights”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal information. This policy describes DeluxeFlights practices regarding personally identifiable information or personal data (“personal information/ PI”). This policy applies to our websites, applications, email, voice calls and text messages, and social media accounts(the “Platforms”). When you use the Platforms, you agree to the terms in this policy.
This privacy policy aims to give you information on how
DeluxeFlights collects and processes your PI, including any PI you
may provide through the Platforms, when you purchase a product or
service or sign up to our newsletter.
It is important that you read this privacy policy together with any
other privacy policy, notice or fair processing policy we may
provide on specific occasions, when we are collecting or processing
PI about you, so that you are fully aware of how and why we are
using your PI.This privacy policy supplements other notices and
privacy policies and is not intended to override them.
DeluxeFlights is the company (business) responsible for your PI.
We have appointed a Data Protection Officer (DPO) who is responsible
for overseeing questions in relation to this privacy policy. If you
have any questions about this privacy policy, please contact the DPO
using the details set out below.
Full name of legal entity: Luxury Travel Services, LLC
Email address:
privacy@deluxeflights.com
We keep our privacy policy under regular review updating it at least
once in 12 months.
DeluxeFlights might make minor amendments to this Privacy policy
which shall not adversely affect your privacy, except if laws set
otherwise.
In case of material changes DeluxeFlights will definitely publish
such amendments and amended policy on our website and, as far as
possible, notify you either by email or by pop-up windows when you
are using our Platforms next time.
Amendments shall enter into force on the Effective Date.
Actual version of the Privacy policy is published on our website.
When you give us PI, 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
It is important that the PI we hold about you is accurate and
current. Please keep us informed, if your PI changes during your
relationship with us.
We may collect, use, store and transfer different kinds of PI about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your PI, but is not considered PI in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Network Activity Information to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your PI, so that it can directly or indirectly identify you, we treat the combined data as PI which will be used in accordance with this privacy policy.
Customer support If you choose to contact our customer
support services we will collect any inquires, complaint or other
information that you may submit to our support team.
We do not
collect any Special Categories of PI about you (this includes
details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health, and genetic and
biometric data). Nor do we collect any information about criminal
convictions and offences.
DeluxeFlights does not knowingly collect PI from minors, except if the minor is one of travelers. If we become aware that a minor is attempting to submit PI, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us PI, please contact us so we can delete it.
Where we collect PI required by law or under the terms of a contract, and you fail to provide that PI when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect PI from and about you including through:
PI you give to us: We collect your PI directly from you (using life chat, online forms or via voice call/ messenger). Any contact data (emails, phones etc.) provided by you throughout any interaction will be treated as your personal contacts and saved in your profile for future communications, unless specifically requested not to be stored (one-time communication only). For example, when you provide us with your PI by requesting a quote, registering or booking travels, contacting our customer support. This includes PI you provide when you:
When we chat in WhatsApp, Facebook chat or via regular sms, it might be accidentally closed/ removed, there might be interruptions, slow internet connection etc. We may contact you later via automated phone and text messages or email (if available) in order to restore our communication started within the chat. No purchase necessary. You can opt out from further communication by replying to sms or notifying us during the phone call.
One of the main collection methods are VOICE CALLS.
We have vested interest to ensure you have chosen the best possible option. Voice calls are an exclusive opportunity to provide you with an immediate customer support and disclose additional product features, you might not notice on website. Usually, we call back on your request. Sometimes there might be unfinished conversations regarding current flights (misunderstanding in live chat, email system error, poor internet connection etc.), which require immediate response. We don’t make unwanted telemarketing robocalls or any annoying advertising campaigns. You can opt-out this communication any time by contacting us via phone or email.
Loyalty/Membership programs If you participate in loyalty/ membership programs organised by our associated companies and covering all or current associated companies, we might access data registered within your member account, so you are able to use benefits within those programs (e.g. use cashbacks in accordance with specific T&Cs when paying for our products/ services, etc.).
PI we collect passively: We also collect your PI passively.
For example, we collect information about you over time and across
different Websites when you visit the Platform. We also use tracking
tools like cookies and beacons. As you interact with our Platforms,
we will automatically collect Network Activity Information about
your equipment, browsing actions and patterns. We collect this PI by
using cookies and other similar technologies. For additional
information, please, refer to our Cookie Policy
Platform features may make use
of your device attributes and
settings that will allow us to determine your physical location
(country, state). Such technologies may include IP address mapping
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. DeluxeFlights 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.
PI we receive from service providers: We collect your PI
using service providers. This can include when you log in using a
service provider platform, such as Facebook. In addition, we also
integrate service providers' software that collects information
about users for security reasons.
The categories of PI
DeluxeFlights has collected/ disclosed/sold for a business purpose
in the preceding 12 months you can find
HERE
We will use your PI for the following purposes:
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.
Regular customers
If you have ever requested a price quote or purchased our services,
we treat you as the Regular (loyal) Customer. Regular Customers have plenty of benefits:
Bookings We and our travel partners use your PI to process your bookings and store your itinerary information where applicable.
Marketing activities We use your information for marketing purposes. These activities may include:
To communicate with you, including as follows:
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.
Performance of a contract The use of your PI 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 PI from you in order to complete the booking.
Consent We may rely on your consent to use your PI for
certain direct marketing purposes. You can withdraw your consent
anytime by contacting us.
We have set out below, in a table
format, a description of all the ways we plan to use your PI.
| Purpose | Activity | Category of PI |
|---|---|---|
| To assist in purchasing air tickets and related travel products (car rentals, hotel booking etc.) - MAIN ACTIVITY, to provide an assistance requested by you or otherwise perform contractual obligations | To register you as a new or a Regular customer/ to start a business relationship |
|
To process and deliver your order related to the MAIN ACTIVITY, including:
|
|
|
| For solely internal uses that are based on your relationship with us or compatible with the context in which PI was collected |
To manage our relationship with you which will include:
|
|
| To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
|
|
|
|
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
|
|
To provide customer support related to the MAIN ACTIVITY:
|
|
|
| To detect, handle and/ or prevent technical errors and security incidents, protect against malicious, deceptive, fraudulent, or illegal activity |
|
|
| To comply with a legal obligation |
|
|
| To exercise or defend legal claims |
|
|
| To use PI in aggregated form for statistical and analytical purposes | To analyze information to secure or improve products/services | Aggregated information, including Identifiers and Network Activity Information |
| To manage your requests, especially when you exercising your rights set herein |
|
|
We will only use your PI for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
As a customer-oriented business we respect and value your
expectations.
As a result, you are able to make announcements
and queries at any time regarding your concerns in privacy matters.
Each of our marketing email has an opt-out button and you can
unsubscribe from such communication at any time. You cannot
unsubscribe from servicing emails and administrative messages.
Associated companies We may share your PI with the associated companies, as well as combine it with other information to organize internal workflow, enhance our efficiency, provide and improve our Platforms, products and services. For example, if you want to check your booking information, you might be redirected to application of our associated company that accumulates and centrally displays such information and allows to manage it within account (specific terms and policies might be applied). If you participate in loyalty/ membership programs organised by our associated companies and covering all or current associated companies, we might share the information about products purchased by you, so you are able to use benefits within those programs (e.g. cashback calculation etc.).
Corporate affiliates and change of control We may share your PI with our corporate affiliates and if DeluxeFlights itself (or part of its business) is sold or otherwise changes control, owners would have access to your PI for the uses set out herein.
Service providers We may share your PI with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information (for example, IT development and maintenance, data storage and security services, communication and request management tools, marketing services, providing legal advice, analytical services, accounting programs, etc.).
Payment service providers and travel vendors If you book through the Platforms, we may share your PI with the payment service providers, acquirer banks and the travel vendors you have booked with. This can include online travel agencies, Global Distribution Systems (e.g. Amadeus, Galileo, Sabre etc.), hotels, airlines, car rental companies, eSIM providers and travel insurance (including medical protection and similar products) providers. These third parties will process your PI as data controllers in accordance with their own privacy policies. If you contact our customer support, they may need to share information about your request with the relevant travel vendor in order to assist you.
Business partners We may share your PI with various business
partners. Some of these business partners may use your PI for fraud
detection, including, but not limited Identifiers, Contact Data and
Network Activity Information , also to detect, prevent, or otherwise
address fraud, security or technical issues. We may also share your
PI to ask our partner to create a survey, form, application, or
questionnaire, so we know the degree of your satisfaction with our
services. Some of these business partners may use your PI 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. We may also share anonymous aggregated usage information
with partners.
We enter into confidentiality and PI processing
terms with partners to ensure they comply with high levels of
confidentiality and best practice in privacy and security standards
and we regularly review these standards and practices.
Trips shared by you If you use or have itineraries as part of our Service, you can send or grant access to your itinerary to anyone you choose. Your itinerary may contain enough details (for example, booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. If you choose to display your itinerary on publicly-viewable web pages (Facebook, for instance), that information may be collected and used by others.
Legal consultants We may share your PI with our legal consultants, if it is necessary to represent us in relations with external actors (e.g. plaintiffs, authorities, courts etc.) in order to exercise, establish and protect DeluxeFlights’s and partners’ legal claims.
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.
Authorities We may disclose PI 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
PI 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.
All the above categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.
Our servers and data centers are located in the U.S and our service providers may be located there and in other countries. By providing us PI, you agree that your PI 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 PI 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 of such countries, we will provide the necessary safeguards to maintain protections of your PI, e.g. by obtaining from the PI recipients contractual commitments based on the EU model clauses.
DeluxeFlights has a security program intended to keep the PI 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 PI you send over the Internet. PI may only be accessed by persons within our organizations, or our service providers to carry out the uses indicated in this Privacy Policy.
We have put in place appropriate security measures to prevent your PI from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your PI to those employees, agents, contractors and other service providers who have a business need to know. They will only process your PI on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected PI breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your PI for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes
of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your PI for a longer period in the event
of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
To
determine the appropriate retention period for PI, we consider the
amount, nature and sensitivity of the PI, the potential risk of harm
from unauthorised use or disclosure of your PI, the purposes for
which we process your PI and whether we can achieve those purposes
through other means, and the applicable legal, regulatory, tax,
accounting or other requirements.
If you click through to third party websites or other platforms, DeluxeFlights’s privacy policy does not apply.
Under certain circumstances set by applicable law, you are entitled to:
Due to the remote nature of our services, it is important for us to
keep communicating through the same email (Verified Email), which
was used by you to request a price quote or purchase air tickets and
other related services.
The Verified Email is the key
communication channel for us, so we can give quick answers and not
to divulge your data to any malicious person.
You might also
submit request through the voice call, but still we must use the
Verified Email to reply, due to law requirements and in order to
protect our legal claims.
If you submit your request through the authorised agent or by using third party
service we will ask for additional verification by contacting you via Verified Email.
NONDISCRIMINATION: We shall not discriminate (deny services,
charge different prices, provide different levels of quality)
against you because you exercised any of the rights set herein.
This right might be limited in case, if the difference in
prices or levels or quality is reasonably related to the value
provided to you by your PI.
We might obtain your opt-in
consent and provide to you financial incentives, so you agree to
provide additional PI or not to request the deletion of your PI.
FEES and DENIALS: You will not have to pay a fee to access
your PI (or to exercise any of the other rights). However, we may
charge a reasonable fee if your request is clearly unfounded,
repetitive (more than twice in a 12-month period) or excessive.
Alternatively, we could refuse to comply with your request in these
circumstances.
We might also refuse to act on your request,
when we are not in a position to identify you and verify your
request.
We may need to request specific information from you
to help us confirm your identity and ensure your right to access
your PI (or to exercise any of your other rights). This is a
security measure to ensure that PI is not disclosed to any person
who has no right to receive it. We may also contact you (via email,
phone or messenger) to ask you for further information in relation
to your request to speed up our response.
Due to law limitations we might deny your request to know if you are asking us to disclose a high-risk
data (e.g. SSN, driver's license number, financial account data, passwords etc.). In such cases we will
definitely inform you that we have collected such types of information, unless prohibited from doing so by
law.
TERMS: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. The maximum response time shall not exceed 90 days.
CONTACTS: you can submit your complaint/ request to DPO email (see above).
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.
In most cases our Platforms use cookies in order to ensure technical feasibility to connect our Platform with your device and provide services requested by you. This cookies is integrated by default into our Platforms.
In case, you try to block/ turn off any of such cookies you might not receive some essential part of services, requested by you. Some examples of such cookies are:
Such Cookies help us to optimize and make more user-friendly our Platforms, enhance security level, facilitate faster and more convenient use of Platforms, receive valuable statistics in anonymized way, including, but not limited to:
In case we are collecting Cookies for statistical purposes, we are
committed to apply a “functional separation” principle, so the
results of the processing shall be without any negative impact to
Your privacy or there should not be any decisions made against
You.
Retention period of Functionality Cookies usually is very
short. In case of longer periods, please, be aware that we always
assess the risk level of such processing, so it does not adversely
affect Your privacy.
Under the strict supervision we might
allow service providers to collect Functionality Cookies on our
Platforms in order to provide us with aggregated statistics. In such
cases we require service providers to aggregate or erase data
obtained from Your device.
We and our third party vendors, including Google and Facebook, use Advertising cookies to serve ads based on a Your prior visits to our Platforms. For example:
We and our advertising partners may also use web beacons (single pixel GIF images). These web beacons are placed in the code of a Web page or an email newsletter. When you access a partner site within our mobile applications, we may track your activity on that site.
Your browser gives you the ability to control cookies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. Your opt out choice is stored in opt out cookies only in that browser, so you should separately set your preferences for other browsers, computers, or devices you may use. If your browser blocks cookies, your opt out preferences may not be effective. Deleting browser cookies can remove your opt out preferences, so you should visit this page periodically to review your preferences. If you block or delete cookies or opt out of online behavioral advertising, not all of the tracking that we have described in this policy will stop.
Please also note that opting out of a third party cookie does not
mean that you will no longer receive or be subject to online
advertising or marketing. It means that the third party service from
which you opted out will no longer deliver ads tailored to your web
preferences and online behavioral.
You may also opt out of
third party cookies by visiting opt-out website like
AboutAds or
https://www.cookiesandyou.com/disable-cookies/windows/chrome/