PRIVACY POLICY
WHAT DATA DOES ASAPTICKETS COLLECT ABOUT YOU?
WHY DO WE NEED YOUR DATA?
OPT-OUT FROM COMMUNICATION ON YOUR CURRENT ENQUIRY
IF YOU FAIL TO PROVIDE PERSONAL DATA
DISCLOSURE AFTER COLLECTING
SECURITY MEASURES
YOUR RIGHTS
HOW WE COLLECT YOUR PERSONAL INFORMATION
RESTRICTIONS OF YOUR RIGHTS AND PRINCIPAL PROVISIONS
DATA TRANSFERS TO THIRD COUNTRIES AND INTERNATIONAL ORGANIZATIONS
HOW DOES ASAPTICKETS TREAT YOUR REQUESTS?
ASAPTICKETS CONTACTS
AMENDMENTS AND EFFECTIVE DATE
ASAPTICKETS.CO.UK PRIVACY POLICY
ASAPTICKETS processes your personal data in order to:
The purpose of processing | The legal basis of processing | Data Storage Period (criteria) |
---|---|---|
to assist in purchasing air tickets and related travel products (car rentals, hotel booking etc.) - MAIN ACTIVITY; | contractual obligations | not more than 6 years after the flight date/ car drop-off date/ hotel check-out date |
to render other services related to the MAIN ACTIVITY (customer support, concierge services, route changes, refunds, chargebacks, fraud prevention and bank card verification etc.); | legitimate interest (fraud prevention) and contractual obligations | not more than 6 years after the flight date/ car drop-off date/ hotel check-out date |
to provide customer support related to the MAIN ACTIVITY (to answer your inquiries, restore data entry ( auto-save tool ), etc.); | legitimate interest (provision of customer support) |
|
to render web-based services upon your request (newsletter subscription, price quotes, itinerary review etc.); | consent | until the consent was withdrawn, except evidence of consent and its withdrawal used for our legal claim protection |
to provide you with value added advertising related to the MAIN ACTIVITY, including our newsletters and advertising on third party websites and social media platforms; | legitimate interests | until opted out or turned off personalised advertising, except evidence of opting out used for our legal claim protection |
to communicate with you sending booking confirmations, alerts etc.; | contractual obligations | not more than 6 years after the flight date/ car drop-off date/ hotel check-out date |
to ensure the security of our services, property and your data, including troubleshooting, data security analysis, error testing, system maintenance, support, reporting and hosting of data; | legitimate interests | no longer that it is necessary to investigate the incident, no longer than for preventing or remediating any negative consequences, as well as protecting/ exercising ASAPTICKETS’ legal claims |
to enhance the quality of our services and customer experience, e.g. conducting surveys, improving staff communication culture, sending holiday greetings; | legitimate interests |
- until opted out, except evidence of opting out used for our legal claim protection; OR
- no longer than it is necessary to resolve issues related to the customer experience |
to exercise and protect ASAPTICKETS’ and our partners’ legal claims; | legitimate interests | not more than 6 years after the flight date/ car drop-off date/ hotel check-out date OR the opt out OR the end of business relationship |
to fulfill the requirements of international agreements (e.g. passengers data (PNR) on fighting serious crime and terrorism); | legal obligations | not more than 6 years after the flight date |
to comply with the requirements of LAWS, e.g. regarding taxes, accounting, consolidated accounting, regulatory matters etc.; | legal obligations | According to the current accountancy (including consolidated part) and tax legislation, but not more than 10 years |
to comply with the requirements of the data subject request regarding objection to process personal data for direct marketing purposes (maintenance of Unsubscribe list) | legal obligations | not more than 6 years after the receipt of data subject request |
to improve border controls (security) and to combat illegal immigration (e.g. EU; USA; Canada; UK ); | legal obligations | not more than 6 years after the flight date |
to achieve internal administrative purposes (maintenance and security of ICT resources; management of data protection systems etc.); | legitimate interests |
no longer than:- it is necessary to investigate the incident, AND/ OR
- for preventing or remediating any negative consequences, AND/ OR - as well as protecting/ exercising ASAPTICKETS’ legal claims |
to maintain backup and archive systems and restore data (if necessary); | legitimate interests | no longer than the backup or archived system is restored to an active system or next processed for the performance of the MAIN ACTIVITY (commercial purposes) or shared with third parties |
to use it in aggregated form for statistical and analytical purposes, e.g. to improve our website, products/services, marketing, customer relationships and experiences. | legitimate interests | no longer than the statistical/ analytical report was created |
WHAT DATA DOES ASAPTICKETS COLLECT ABOUT YOU?
We are collecting different categories of data depending on your request of services, requirements of LAWS and our legitimate interests conducting our business.
When you provide to us your data, 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.
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).
ASAPTICKETS does not aim any of our products or services directly at children and we do not knowingly collect personal data about children, except in cases where it might be indirectly implied by nature of services (e.g. the air ticket booked for a passenger who is a child)
We collect your data from third parties. In addition, we also integrate third party software that collects information about users for security reasons.
Separately from other data, there is a specified category of data as cookies. We are using cookies when you are using our Platform (e.g. browsing websites, applications of ASAPTICKETS, sending email and text messages, communicating through social media accounts). The cookies mostly relate to the necessity of providing services you have explicitly requested by You (e.g., to open a website or some section of it, mankind payments etc.) or your authentication during the login process.
Please find additional information on usage of cookies HERE.
WHY DO WE NEED YOUR DATA?
Depending on the relationship (client, partner agreement, website user etc.) ASAPTICKETS collects only the minimal personal data necessary for achieving processing purposes (e.g. assist in purchasing air tickets, make a payment, detect fraud, prevent identity thefts, send a newsletter, provide customer support etc.).
Main groups of processing purposes you can find HERE.
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:
- become experts of using our services;
- receive the most relevant price quotes.
According to our policy, we may contact you as a Regular Customer via email/phone saved within previous requests and transactions. Such cases may be, for example, when you have accidentally provided the wrong email/phone or when you cannot be reached via email/ phone left in the last request/ purchase. If you want to opt-out, please contact us.
We also might use your data in aggregated form * for security, statistical and analytical purposes, e.g. to improve our website, products/services, marketing, customer relationships and experiences.
Depending on the current purpose, we apply on the following lawful grounds: consent, performance of contract, legal obligation and/ or legitimate interests of controller or third parties.
Our legitimate interests, for which your data might be processed, are:
- customer support;
- fraud prevention;
- debt recovery;
- marketing of our services and products;
- communication with you;
- security of our services, property and your data;
- improvement of the quality of our services and customer experience;
- exercise and protection ASAPTICKETS’ and our partners’ legal claims;
- comply with the requirements of foreign (non-UK) laws and regulations;
- optimization of resources and increasing competitiveness;
- statistical and analytical services.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
When we chat with you (e.g. WhatsApp, Facebook, regular sms etc.) the chat 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/ email or notifying us during the phone call.
One of the main collection methods are VOICE CALLS, which may be recorded for the purposes set herein.
We have vested interest to ensure you have chosen the best possible option. Voice calls are an exclusive opportunity to provide You with immediate customer support and disclose additional product features, you might not notice on a website or within our price quote.
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 at any time by contacting us via phone or email.
Due to the importance of voice calls, we use validation services for fraud prevention and process optimization. Thousands of phone numbers daily shall be managed and filtered, so we also could notify you about possible communication errors and suspicious activities.
OPT-OUT FROM COMMUNICATION ON YOUR CURRENT ENQUIRY
If you submit price-quote request (PQ request) we will treat this activity as a request to start negotiations for sale. PQ request does not oblige you to make a purchase. After we receive a PQ request, we will contact you via automated phone, text message or email (if available) in order to arrange the best possible option for you. You can opt out from further communication by replying to chat message/ sms / email or notifying us about it during the phone call.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where ASAPTICKETS collects personal data to comply with LAWS or under the terms of a contract where you are a party to such a contract, and you fail to provide your data when requested, we may not be able to perform the contract (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.
DISCLOSURE AFTER COLLECTING
The only way ASAPTICKETS is doing so, when it has a legal basis and processing purpose for doing so. Disclosing your data, we require recipients to follow LAWS and data protection measures when they process your data.
Our Platform and services may contain links to third-party websites, products and services. We may also use or offer products or services from third parties − for example, a third-party app.
When you use a third party service or click a link to a third party website, our Privacy policy is not applicable. Please, contact the relevant third party to obtain their privacy rules.
Depending on processing purposes, we might share your data with associated companies of ASAPTICKETS, our services and goods suppliers, as well as other third parties. Other detailed information on our sharing practices you can find HERE.
SECURITY MEASURES
Considering the state of the art and costs of implementation, the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing,
ASAPTICKETS ensures and permanently improves security measures to protect your data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
To achieve the highest security level, we are performing organizational and technical measures. The most typical measures you could find HERE.
YOUR RIGHTS
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.
HOW WE COLLECT YOUR PERSONAL INFORMATION
The scope of your rights (as data subjects) is set under each current processing purpose and legal basis which will be informed to you when ASAPTICKETS collects / you are providing your data to us.
In case we are a processor, the main contact for data subjects should remain a data controller. In such cases we will definitely provide possible support in contacting the relevant controller.
Right to be informed
Every time we collect your data, ASAPTICKETS will inform you at least of the identity of a controller, the purposes of data processing and sources where to find additional information.
In the event we are collecting your data from other controllers (processors) you will also be informed in a timely manner.
So, our communication is made in an intelligible, plain and clear way, but the texts are not burdensome, we will not inform you on details you already know.
In case, the processing of your data is based on consent, you will definitely have the right to withdraw your consent at any time. Please, be informed that the withdrawal of consent is not affecting the lawfulness of processing based on consent before its withdrawal.
There might also be other cases where your rights to be informed are limited.
Right of access
You are entitled to receive a confirmation from ASAPTICKETS as to whether or not your data is being processed by us, and if so, you have a right to access the relevant data.
Right to rectify and add
You are entitled to obtain from ASAPTICKETS without undue delay the rectification of inaccurate personal data. Considering purposes of processing you are also entitled to supplement incomplete personal data.
Right to erasure ("right to be forgotten")
You are entitled to obtain the erasure of your data from ASAPTICKETS. In cases set by LAWS we shall delete your data.
Unfortunately, since the exceptional character of exercitation of such rights the LAWS set restrictions when your request might be refused.
Right to restriction of processing
In current cases you are entitled to file a requestto restrict you data processing.
Nonetheless the restriction of processing, we will still be entitled to:
- Store your data;
- Process your data in any manner, if:
- You have consented to it;
- We have to establish, exercise or defend our legal claims;
- The rights of another person shall be protected;
- There are reasons of important public interest.
Right to data portability
You are entitled to transmit your data, which you have provided to ASAPTICKETS, to another controller, where:
- the processing is based on consent or on a contract; and
- the processing is carried out by automated means.
Unfortunately, there might be cases when your data transmission to another controller is not technically feasible. In this regard we will try to do our best in providing maximum support, so another controller receives your data.
Right to object (opt-out)
In case ASAPTICKETS processes your data:
- the performance of a task carried out in the public interest, or
- in the exercise of official authority vested in us, or
- for the purposes of the legitimate interests pursued by us or by a third party, You are entitled to object to such processing, specifying in your request the particular situation (reason for objection)
In such cases we will not process your data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
There are also other cases set by LAWS, when you are entitled to object, as well as the conditions under which the right to object might be exercised.
Your rights regarding automated individual decision-making, including profiling
You are entitled not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where the decision:
- is necessary for entering into, or performance of, a contract between you and ASAPTICKETS; or
- is authorized by LAWS to which ASAPTICKETS is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
- is based on your explicit consent.
Right to lodge a complaint
If we are not able to resolve any dispute or claim arising from Your data processing under this Policy in an amicable way, You are entitled to lodge a complaint with a supervisory authority
RESTRICTIONS OF YOUR RIGHTS AND PRINCIPAL PROVISIONS
Please, be informed that each of your rights and some of the principal provisions set herein might be restricted due to legislative measures, mostly to the advantage of other natural and legal persons, as well as national interests and public security.
DATA TRANSFERS TO THIRD COUNTRIES AND INTERNATIONAL ORGANIZATIONS
ASAPTICKETS might transfer your data to third country providing safeguards and security measures, so the level of your data protection is not undermined.
Such transfers might take place in cases, if:
- we have to perform an agreement concluded between you and ASAPTICKETS;
- we have to carry out pre-contractual measures in order to prepare a contract;
- if you consented to the proposed transfer;
- transfer is based on an international agreement, such as a mutual legal assistance treaty, in force between the requesting third country and the UK (e.g. transfer of passenger name records to the United States Department of Homeland Security for the purposes of preventing, detecting and investigating terrorism offences and other transnational crimes);
- transfer is based on adequacy decision made by the UK Government or standard data protection clauses adopted by the relevant authority, e.g. when we share the data with associated companies located in Moldova, India, EEA and the Philippines or when we use data storage facilities of our partners operating in the USA under relevant safeguards;
- other cases may be applicable (you shall be informed prior to any such transfer).
HOW DOES ASAPTICKETS TREAT YOUR REQUESTS?
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 purchasing our services. The Verified Email is the key communication channel for us, so we can give quick answers and not divulge your data to any malicious person. You might also submit a 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.
Receiving your request on exercising your rights under this Privacy policy, we will process your request without undue delay and in any event within one month of receipt of the request, except in cases where we are not able to identify you (we are either not processing your personal data or it was anonymized/ erased) or the requested fee was not paid. One-month period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
In case, your requests are manifestly unfounded or excessive (e.g., repeats the substance of previous requests within period of time of 12 months or providing false or misleading information), ASAPTICKETS might refuse to act on the request explaining reasons or you might be charged a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested.
In case we have reasonable doubts concerning the identity of the natural person (also authorized representative) making the request, we may request the provision of additional information necessary to confirm the identity of such a natural person and/ or to prevent identity fraud.
You are entitled to receive one copy of your data free of charge. For any further copies we may charge a reasonable fee based on administrative costs. The right to obtain a copy shall not adversely affect the rights and freedoms of others.
ASAPTICKETS CONTACTS
The controller of your data is International Travel Network, LLC (Delaware, USA). The UK representative of the controller is TRAVELTECH ENTERPRISES LTD, having its registered address at 87 - 89 Baker Street, London, England, W1U 6RJ. In case you have any questions regarding your data processing by ASAPTICKETS, please contact us at: privacy@asaptickets.co.uk
AMENDMENTS AND EFFECTIVE DATE
ASAPTICKETS might make minor amendments to this Privacy policy which shall not leave negative impact to your privacy, except if LAWS set otherwise.
In case of material changes ASAPTICKETS will definitely publish such amendments and amended policy on our websites and, as far as possible, notify you either by email or by pop-up windows when you are entering our websites next time.
Amendments shall enter into force on the Effective Date.
Actual version of the Privacy policy is published on our websites.
ASAPTICKETS.CO.UK COOKIE POLICY
What is Cookies?
Cookie is a small piece of data sent from our Platform and stored on your device (computer, smartphone, etc.) by your web browser while you are browsing our website and sometimes down the line *. Without Cookies it would be impossible to provide you information and services you are requesting through the Internet. Cookies remember stateful information (such as the itinerary data when requesting a price quote) or record your browsing activity. They can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords, and credit card details.