Flagito

Privacy Notice

General
1. With this privacy notice (“Notice“), we disclose how Flagito OÜ (“Flagito” or “We“) processes your personal information, including the policies that Flagito follows in collecting and using the information when you browse the website www.flagito.ee (“Website“), use our services (“Service“) or contact us via online devices, including the social media site https://www.facebook.com/Flagito /.
2. Flagito will process your personal data in the manner set out in this Notice and in accordance with applicable law, in particular the General Data Protection Regulation of the European Union (“GDPR“).
Data Controller
1. For the purposes of the processing of personal data described in the Notice, the controller of your personal data is:Flagito OÜRegistry code: 14275048
  Address: Tähe tn 34, 11619 Tallinn, Estonia
  
  Email: info@flagito.eu
2. If you have any questions about the processing of your personal data, please contact us by email: info@flagito.eu.
Categories and Sources of Personal Data
1. Personal data is information which makes it possible, directly or indirectly, to uniquely identify you as a natural person (“Personal Data“). The source of the Personal Data collected depends on how you use our Websites and Services.
  1. If you fill in the form on our website or notify us of any issues with your flight by email, we will process the following Personal Data: first name, last name, date of birth, personal identification number, email address, residential address, signature, assignment of claim agreement and / or power of attorney (“General Data“). You will disclose this information to us.
  2. If you send us additional documentation about any issues with your flight, we may process the following Personal Data: details of the flights in question, booking confirmation, boarding pass, correspondence with e.g. an airline, travel agent, agency platform. You will disclose this information to us (“Flight Data”).
  3. If we have to take your claim to court, to an out-of-court authority (including a consumer protection authority) or at the request of an airline, we may process the following Personal Data about you: a copy of your birth certificate, a copy of your identity document (“Additional Data“). You will disclose this information to us.
  4. When you contact us via email or social media, we process the following Personal Data: email address, public social media account details, message content (“Communication Data“). You will disclose this information to us when you contact us.
  5. In order to fulfil our accounting obligations, we will process the following Personal Data: payment details, bank account number (“Accounting Data“). You will disclose this information to us.
  6. When you browse the Website, we process the following information about you: the device’s IP address, the log file with the time and date of your visit to the Website, browser version, the device’s operating system, the URL from which you accessed the Website (“Technical Data“). This data is automatically collected from your device by our web server when you browse the Website.
  7. We use cookies on the Website to optimise your user experience. Cookies may collect Personal Data (“Cookie Data“). See the Cookie Notice for more information.
2. If you do not provide us with the requested Personal Data, we will not be able to provide you with the service you have requested or enter into a corresponding contract with you, such as submitting your request to an airline or contacting you.
Purposes and Legal Grounds for Processing Personal Data
1. The legal grounds for processing Personal Data depends on the purposes for which and the purposes in relation to which Flagito collects Personal Data. We may process your Personal Data on the following legal grounds:
  1. Performance of the contract, i.e., we process your Personal Data for the performance of the contract we have concluded with you, i.e., for the performance of the Terms and Conditions to which you agreed when you completed the online form on our website to report an issue concerning your flight;
  2. Flagito’s legitimate interest, i.e., we process your Personal Data on the basis of Flagito’s legitimate interest where our interest outweighs your interests or fundamental rights and freedoms;
  3. Compliance with legal obligations, i.e., we process your Personal Data if we are required by law to process it;
  4. Your consent, i.e., we will only process your Personal Data if you have given your consent.
2. We may process your Personal Data for a variety of purposes. The following is an indicative list of the purposes for which Personal Data will be processed:
3. Drawing up an assignment of claim agreement and / or power of attorney;
4. Submitting a claim to an airline, its agent or professional adviser;
5. Submitting a claim to a travel agency and / or agency platform;
6. Using additional means of legal redress against the airline (e.g., bringing a claim before a court or consumer protection body, bringing a claim before a bailiff);
7. Holding compromise negotiations with the airline;
8. Paying the compensation into your bank account;
9. Responding to inquiries and feedback, communicating via email and social media;
10. Storing and managing feedback from you;
11. Bookkeeping;
12. Diagnosing and fixing errors on the Website and with the Service;
13. Improving, adapting and developing the Website and the Service;
14. Analysing the statistics relating to the use of the Website and the Service;
15. Managing the given consents;
16. Backing up data and materials;
17. Disclosing Personal Data to our third-party service providers;
18. Disclosing Personal Data to public authorities and law enforcement;
19. Disclosing Personal Data to qualified advisers.
Transfer and Recipients of Personal Data

1. Your Personal Data is processed by our authorised employees and members of the management body, who have the right and need to process Personal Data due to their job responsibilities.
2. Only where necessary, we will disclose your Personal Data to the following categories of recipients of your Personal Data who process your Personal Data as separate controllers: public authorities and law enforcement bodies, professional advisers (subject to confidentiality obligations under the law), airlines, their agents and professional advisers, travel agencies, agency platforms;
3. We may engage and use authorised processors for the processing of Personal Data, who will have access to your Personal Data solely for the purposes of performing a contract with us and will implement appropriate organisational and procedural protective measures for the processing of Personal Data. The processors involved fall into the following categories: IT service providers, accounting service providers, third-party service providers.
4. We may, in certain cases, transfer Personal Data about you outside the European Union or the European Economic Area if necessary support services are provided outside the European Union or the European Economic Area. We use a variety of security measures necessary to protect Personal Data in order to ensure the security of the Personal Data we collect about you. You have the right to access or obtain information about the transfer of your Personal Data outside the European Union or the European Economic Area and the security measures used in this regard by contacting us at the contact details set out in section 2 of the Notice.

6. Retention of Personal Data

1. We will retain your Personal Data for as long as reasonably necessary to fulfil the purposes set out in Section 4 of the Notice, unless otherwise provided by applicable law or as set out below:
  1. We will retain the General Data, Flight Data and Additional Data for up to 3 years from the beginning of the year following the resolution of the issue with your flight;
  2. If you have assigned your claim to Flagito or given us a power of attorney, we will keep the Communication Data for up to 3 years from the beginning of the year following the year in which the issue with your flight was resolved. We retain other Communication Data for up to 1 year from the beginning of the year following the end of the respective communication thread;
  3. We retain Accounting Data for up to 7 years from the end of the financial year in which the transaction was recorded in our accounting system;
  4. We retain Technical Data for 30 days from the date of collection.
2. After the end of the retention period set out in section 6.1 of the Notice, we may retain your Personal Data for longer if it is necessary to comply with a legal obligation or claim, to resolve a legal dispute or to enforce a contract with us.
3. At the end of the retention period for the Personal Data set out in section 6.1 of the Notice, or if the legal ground relating to the purpose for which the Personal Data is processed ceases to exist, we may store materials containing your Personal Data in backup systems from which they will be deleted at the end of the backup cycle. We will take appropriate measures to ensure the security of the backed-up material during the backup period. Backed-up materials will be discarded, not processed for any purpose and will be deleted at the earliest opportunity, i.e., at the end of the backup cycle.

7. Your Data Protection Rights

1. You have the following rights in relation to our processing of Personal Data:
  1. Right of access to Personal Data;
  2. Right to the amendment of Personal Data;
  3. Right to the deletion of Personal Data;
  4. Right to withdraw consent;
  5. Right to object;
  6. Right to transfer Personal Data;
  7. Right to request restriction of the processing of Personal Data;
  8. Right to apply to the Data Protection Inspectorate.
2. To exercise the above rights, please contact us using the details provided in section 2 of the Notice.

8. Changing the Notice

1. We may change the Notice from time to time to accurately reflect our processing of your Personal Data. In the event of a significant change, we will notify you via the Website. We encourage you to read the Notice again before disclosing your Personal Data.

Last updated: March 2022