Privacy policy

What is Personal Data?

Personal Data is "any information relating to an identified or identifiable natural person. This includes, for example, name or address data, telephone number, mobile number, or online identifiers such as your device id and your IP address.

What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

Who is responsible for data processing?

The responsible party for data processing is FlySmartDeals LTD, 128 City Road, London, United Kingdom, EC1V 2NX (“FlySmartDeals”, “we”, “us”, “our”). If you have any questions or if you wish to exercise your rights, please contact us by email using info@flysmartdeals.com.

What law applies?

Our use of your Personal Data is subject to the UK's Data Protection Act (“DPA”), and the EU's General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.

What are the Legal Bases for processing Personal Data

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfilment of a contract / pre-contractual measures, c) the data is necessary for the fulfilment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Who is the competent data protection authority?

The supervisory authority in the UK is the Information Commissioner's Office (ICO). The ICO is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK or online at www.ico.org.uk. However, we would appreciate the opportunity to address your concerns before you approach the ICO or any other supervisory authority.

How long and where will you keep my data?

We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with the UK’s Commercial Law and Fiscal Code. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

In general, your data is saved and stored using our in-house servers. In addition, for optimal data management and support, we store the data related to your contract with us in our proprietary backend.

Technical Data

When you access our website, some access data is recorded automatically and stored in a log file on our website's server. This means if you browse and simply have a look at our website, we process a) the IP address of your computer, b) the date and time of your access, c) the name and URL of the accessed file, d) the browser used, e) the amount of bytes transferred, f) the status of the page request, g) the session ID and g) the referrer URL. The legal basis for processing is our legitimate interest.

Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the UK's Privacy and Electronic Communications Regulations (“PECR”) and the EU's Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

Cookie consent

Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

Economic analyses and market research

For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For further information, please refer to our Cookie Policy.

Fonts

We use Google Fonts by Google, on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google server is established when our website is accessed. The connection to Google established when you call up our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.

Contacting us

You can contact us in various ways and data is always collected in the process. You provide us with most of the data that we process when you contact us such as your name, and email address. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted again, provided that there is no legal obligation to retain it.

Register for an account

It is also possible for you to register for an account. For this purpose, you can choose a password and you provide us with your full Name, email address and password. Alternatively, you can sign in using the convenient sign-in feature of Google, or Facebook log in. The convenient sign-in and registration will ask you to provide your basic information (i.e. name, email address and picture) in connection with your account. If you comply with the prompt, your username and password will be automatically generated for you to enter the rest of the required user information. If you register using the Google or Facebook Connect feature, you agree to the relevant terms and conditions and consent to certain data from your respective profile being transferred to us.

Booking with us

We process various data as part of the provision of our services, bookings and for the initiation and fulfilment of the contractual relationship between you and us. If you have commissioned us to provide a booking service, we process your data (if provided: Name, contact details (email address and telephone number), address, and all travel and booking information required as part of the fulfilment of the services exclusively for the purpose of processing and handling the contractual relationship. This includes, in particular, our appropriate advice and support, correspondence with you, invoicing and the fulfilment of our accounting and tax obligations. Accordingly, the data is processed on the basis of a contract and to fulfil our legal obligations.

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

Internal

If necessary, we transfer your Personal Data within FlySmartDeals. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.

We may also share your Personal Data with our Business Partners (including subcontractors and freelancers, supplier, investors and project developers or other entities with which we have an ongoing business relationship to provide our services or information) for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customising our business to better meet your needs.

External bodies

Personal Data is transferred to our service providers in the following instances:

• in the context of fulfilling our contract with you,
• to use marketing services and to advertise our services online,
• to communicate with you,
• to provide our website, and
• to state authorities and institutions as far as this is required or necessary.

International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorised persons, we use appropriate technical and organisational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of mail or email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

General

We are present on social media on the basis of our legitimate interest (Facebook, Instagram, X (formerly Twitter), Pinterest and YouTube (Google)). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

Market research and advertising

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.

When you visit our profiles and interact with us and others

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website. The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

Privacy rights

Under the DPA and GDPR, you can exercise the following rights:

• The right to access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to object to processing
• The right to data portability
• The right to complaint to a supervisory authority