Privacy policy

The Privacy and cookie Policies will automatically come into effect for all existing users of AVIASALES on JULY 01, 2020 and, once in effect, your continued use of our services will be subject to this new Privacy Policy.

Privacy policy

Your privacy is important to us. This privacy statement explains:

What personal data is collected by the owner of this web-site or provided by you, through our interactions with you and your use of our web-site AVIASALES.

How your personal data will be used, where it is held, how long it will be kept and your rights.

Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Data controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

“You”, “your” or “data subject” means: 

• - Users of our web-site
• - Subscribers to any service we offer through our web-site
• - Prospective or existing clients corresponding with us by e-mail or otherwise

Data controller, “Rightholder”, “we”, “us” and “our” means:

Go Travel Un Limited, its subsidiaries and its data processors;

Personal data means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people. The definition incorporates, where applicable, the definitions provided in General Data Protection Regulation.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy from time to time. Please review this policy periodically for changes. If you do not accept the amended Policy, please stop using this web-site.

Who we are (Identity of the data controller)

Go Travel Un Limited, a Hong Kong Corporation, number 1658681, having its registered office at Suite 1504, 15/F, Chinachem Tower, 34-37 Connaught Rd Central, Hong Kong doing business as Aviasales, its subsidiaries and its data processors (collectively referred to as Aviasales), who operate this web-site and allowing you to search for airline tickets, hotel rooms, travel insurance and car rentals.

Go Travel Un Limited and its data processors.

Personal data we may collect from you

We may collect and process the following data and personal information about you:

Personal Data you provide us voluntarily

We collect the information provided by you to operate effectively and provide you the best experiences with our web-site, products and services. You provide some of this information voluntarily, this includes information you provide if you subscribe to our newsletter, register to use the web-site, enter into any transaction on the web-site, send us a query or feedback, participate in discussion boards or other social media functions on our web-site, promotion or survey, or when you report a problem with our web-site. 

This information may include your:

Travel destination, travel dates, class and number of passengers, how many people will accompany you, your children ages.

You may choose to subscribe to our mailing list to receive alerts about cheap prices; we’ll also collect your email address for this purpose. You can unsubscribe at any time and you won’t receive any emails from us.

Your profile

You may decide to get to know our cheap fares and hotel rooms search engine a bit closer and register for an account in our system. This will allow us to personalise your search results and collect information about your purchases in order to reward you for your repeated business with us.

The Rightholder does not acquire, store, transmit or process any additional user’s personal data except the specified below. Most of the User’s personal data entered in the program are stored locally on the user’s device. Whereas a user makes a payment on the website of a travel agency, an air company or any other person carrying out air ticket sales, the Rightholder does not receive any information as for an air ticket bought, a route, a buyer, a number of a credit card etc., excluding depersonalized information as for a cost and a transaction’s identifier.

Transmission of the above mentioned user’s personal data by means of the functional of the Program to third persons is authorized and carried out by the User directly. The User undertakes to take due measures to ensure safety of his/her own personal data.

The Program can transmit the following technical data to the Rightholder:

• IP-addresses,
• date and time of use,
• type and version of the operational system,
• producer and model of the User’s mobile device,
• data of the locale of the device,
• version and identifier of the Program,
• statistics of use of different functions of the Program,
• data of a documents (first and last name, gender, dob, nationality, passport number, expiration date) if User enters this data into his/her personal account for the purpose of the subsequent autocomplete.

WHAT INFORMATION WE DON’T COLLECT ABOUT YOU

Personally identifiable information

We don’t need and hence don’t collect any of the following information about you: your name, age, email address (unless you subscribed to our email list or created an account into our web-site), phone number, passport details, home address, etc.

Most information in our systems is non-personally identifiable, which means that even we can’t match specific records to specific individuals, unless they signed up for an account. In this case, we treat this information with utmost respect and care.

Order and payment information

Because you pay to an airline, hotel or travel agency directly, we have no visibility of your order information, including, but not limited to: specific ticket bought, price paid, credit card number, etc, first name, surname, e-mail address, phone number, date and place of birth, family, lifestyle and social circumstances.

Children

We do not sell any products or services for purchase by children. If you are under 16, you may use our web-site only with the involvement of your holder of parental responsibility. We do not knowingly collect personal information from children below 16 without the consent of the child's holder of parental responsibility.

Information you provide about others

In providing personal data about other individuals (such as someone in whose name you are registering an account or subscribing to our marketing promotions), you represent that you have notified them of (i) the purposes for which information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information.  You further represent that You have obtained all necessary consents from them.

INFORMATION WHICH MAY BE MADE AVAILABLE TO US, OR COLLECTED AUTOMATICALLY WITH THE USE OF COOKIES OR ANALYTIC TOOLS

We might get some information from our users by recording how they interact with our web-site with the use of cookies, analytics tools or obtain data from third parties.

TECHNICAL INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION:

Device and connectivity information such as IP (Internet Protocol) address, unique device identifiers (such as the IMEI for phones, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting "Device Information";

Configuration data such as browser type, version and language setting, time zone setting, browser plug-in types and versions.

Details of how you used our web-site, such as your search queries. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our web-site (including date and time); products you viewed or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page:

Log information, such as error reports, download errors, any problems you experience using our web-site.

We do not match information collected automatically through cookies and analytics tools with other personally identifiable information you may have provided to us when you registered for our Products or submitted a form through our web-site.

When the User goes to partners (an airline, hotel or travel agency), we may collect data entered by the user in the email input field. Obtained data (input field values) we can use solely for the purpose of retargeting and collecting internal analytics of the service.

COOKIE POLICY

A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites or apps. Cookies allow a website or apps to recognise a user’s device.

Why does AVIASALES use cookies?

Cookies allow us to improve the site's content, functionality and speed, while their tracking ability also helps us to understand your likes and dislikes, which means we can respond quickly and adapt the web-site accordingly.

We might use cookies to recognize you when you use our web-site, remember your preferences, and give you a personalized experience:

Authentication cookies. If you're signed in to our Services, these cookies will help us show you the right information and personalize your experience.

Session cookiesThese cookies store the ID of a user’s session. The cookie is set when a user signs in and is used to restore the session without entering the personal data.

Security cookies. We use cookies for our security features, and to help us detect malicious activity.

Preferences, features and services. These cookies help us to customise your preferences, such as which language you prefer and what your communications preferences are or to fill out forms on our faster.

Performance, Analytics and Research. These cookies help us to analyse our web-site performance. We use cookies to improve our products, features, and services, including to create logs and record when you use our web-site.

Third-party cookies. In addition to the cookies AVIASALES delivers to your device, certain third parties may deliver cookies to your device for a variety of reasons for more targeted advertising experience. We are working with online advertising companies to display online behavioral advertising on our web-site and third party sites that you visit. This targeting may be based on information you submit on our web-site or third party platforms. Your search parameters (origin, destination, travel dates, class and number of passengers) could be used for advertising purposes.

The purpose of this data processing is to track conversions and to allocate them to proper affiliates. It is necessary for the performance of a contract with third parties (our affiliates) that make use of our services, Art. 6 sec. 1 lit b) GDPR. The lawful basis for such processing is our legitimate interests. Please note what we are not sharing Personally identifiable information to third parties.

We use the following session, permanent and third-party marketing cookies, including cookies from our partners and service providers:

What information we collect with cookies?

Whether it’s your first visit or not, and whether you used our web-site directly or via a link or search form published by one of our partners, cookies allow us to understand your search history: origin, destination and travel dates.

What can you do if you don't want cookies to be set or want them to be removed?

Most browsers accept cookies automatically, however some people prefer not to allow cookies. You may change the security settings of your web browser in order to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites you trust, or to be notified before receiving cookies. You may also delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. However, that these settings may have negative effects on the web sites usability.

Browser manufacturers usually provide help pages relating to cookie management in their products. Please see below for more information:

• Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Safari (Desktop):https://support.apple.com/kb/PH5042?locale=en_US
• Safari (Mobile): https://support.apple.com/en-us/HT201265
• Android Browser: https://support.google.com/nexus/answer/54068?visit_id=1-636585517588941681-639659396&hl=en&rd=1
• Opera: https://www.opera.com/help
• Opera Mobile: https://www.opera.com/help/mobile/android#privacy

For other browsers, please consult the documentation that your browser manufacturer provides. You may opt-out of third party cookies from Google Analytics on its website.

You can opt out of interest-based targeting provided by participating ad servers through via the next link: aboutads.info

SOCIAL MEDIA FEATURES AND WIDGETS

Our web-site might include certain Social Media features and widgets, such as the “Facebook Like”, “Facebook Share”, “Facebook Pixel”, “Twitter Tweet”, features, buttons or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our web-site, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our web-site. If you “LIKE”/”SHARE”/”+1” us (or perform a similar action) in social networks, we may obtain your first and last name.

Please be aware that if you choose to interact or share any Personal Information via such widgets, you are in fact providing it to these third parties and not to us. Your interactions with these third parties are managed by these Social Media policies and not ours. For example, you will not be able to use the “Facebook Like” button if you are not logged in to your Facebook account. Once you use the button this will be associated with your Facebook history, but we will not process this information.

Information we might obtain from third parties

We might obtain some non-personally identifiable information from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of data. 

We might insert advertising on our partner websites, social networks or Advertising networks who might categorize website visitors with similar characteristics or interests into non-personally identifiable data segments and offer these segments to their own clients, visitors and subscribers. For example, if a person expresses an interest in cryptocurrency or beauty products, they might see an advertising banner linking to similar service provider company web site. 

We might obtain and record information that an ad was requested or shown, how many times, the target geography of the ad (which will not include an IP address or specific personally identifiable location) and any user interactions with the ad or the page where the ad appears. This information is used for analysis, reporting and troubleshooting.

We do not perform any visitors profiling activities.

Where Do We Store Your Information?

We take Client confidentiality and security very seriously. We are committed to protecting the Personal Data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. 

The data processing consisting in hosting provider services (storage and maintenance of databases containing your personal data, protected by password) is performed on our behalf under written confidentiality agreements by our authorized data processor

Amazon Web Services, Inc. (“AWS”), which is part of a global organization with local operating companies in a number of countries worldwide. All information is stored on Amazon Web Services data centers in United Kingdom. AWS participates in the EU-US Privacy Shield framework. Please find more information here https://www.amazon.com/gp/help/customer/display.html?nodeId=468496

The written agreements with the data processor guarantees that the requirements of the GDPR will be met and the rights of data subjects are protected. The Data Processor will only act on behalf of our documented instructions, have direct responsibilities under the GDPR and may be subject to fines or other sanctions if they don’t comply.

Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or jurisdictional responsibilities.

Data Retention

Unless otherwise specified, where you have indicated to us that you are happy for us to send you the information about products or services we offer and we feel may interest you or similar to those that you have already purchased or enquired about do so, we assume you are happy for us to keep your collected personal data. We may retain your Personal Information (contact details) for as long as your User Account is active or as otherwise needed to provide you with information about our Services. As the data subject you have rights related to processing of your personal data and the option of withdrawing your consent to receive promotions at any time. Please see paragraph “Your rights”.

If you and us enter in any type of contractual relationship, we might keep your data during the performance of the contract and as long as it is necessary as for our legitimate interests. Please see paragraph “LAWFUL BASIS AND THE USES MADE OF YOUR PERSONAL INFORMATION”.

LAWFUL BASIS AND THE USES MADE OF YOUR PERSONAL INFORMATION

We use the data we collect for the following basic purposes, described in more detail below:

To take steps at the request of the data subject prior to providing you with the requested service:

During the purchase process, we ask you only for the personal data that we need to provide you with our mediation services to contract travel products, as well as to attend you and solve any post-contractual query, claim or request, and therefore the lawful basis is Contract and our Legitimate interests.

We will use the provided information to operate effectively and do our best to respond to your enquiry. Once you enter into a business relationship (oral or written contract)  with us, we will invoice our services and offer you post-sales service and loyalty if required.

We might hold your information for as long as is necessary to comply with our legal obligations and in accordance with our legitimate interests as a data controller after the contractual relationship between you and us elapses. The lawful basis for such retention is Legal obligation. As the data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.

When you choose to subscribe to our mailing list to receive alerts about cheap prices, to send you communications, including promotional communications and advertising with your explicit consent or allow you to participate in interactive features of our service, when you choose to do so. The lawful basis for such processing is Consent.

If you wish not to receive such promotional e-mails, you may withdraw your consent at any time by contacting us as described in paragraph “Your rights” or follow the “unsubscribe” or instructions contained in the promotional communications you receive.

Web-site improvement

We might use your automatically collected data such as IP address and browser data for our web-site improvement, such as:

4.1 To administer our web-site and for internal operations, including data security, troubleshooting, testing, statistical and survey purposes;

4.2 To ensure that content from our web-site is presented in the most effective manner for you and for your device. The lawful basis for such processing is Legitimate interests.

Disclosure of information to third parties

We do not rent, sell, or share personal information about you with other people or non-affiliated companies without your consent except to provide products or services you've requested, when we have your permission, or under the following circumstances:

We provide the information to trusted partners who provide us services under confidentiality agreements, specified in Paragraph “Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data”. These companies do not have any independent right to share this information.

We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.

In the event we are acquired by or merged with a third party entity or undergo another change of control, we reserve the right to transfer information, including any PII and non-PII, to a successor entity. In this event, we will notify you by electronic means before information about you is transferred and becomes subject to a different privacy policy. 

International transfers

You can find detailed information related to data location in paragraphs 'Where Do We Store Your Information?' and 'Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data'

Law Enforcement, Legal Requests and Duties:

We may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention and national security.

Your rights

You have the following rights in accordance with the General Data Protection Regulation:

The right to be informed. In this privacy statement we supply you detailed information related to your personal data storage, maintenance and processing.

The right to access information held about you

The right to rectify your personal data if it is inaccurate, incomplete or out-of-date

The right to erasure (delete or remove) your personal data

The right to restrict (block) processing. When processing is restricted, we will store your personal data, but not further process it. 

The right to data portability which allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

Rights related to automated decision making including profiling

We are not making any decisions which might produce a legal effect on you based on automated processing.

The right to withdraw your consent (object) to direct marketing

You can exercise your rights by contacting us at legal@aviasales.ru

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with your local supervisory authority if you have a concern about our information rights practices.