NON-DISCLOSURE POLICY
INTRODUCTORY ARTICLE
By providing personal data to AirRefund, you agree that we can collect and process such data in accordance with the following non-disclosure policy.
Subject to legal and contractual expectations, you can decide to reject or cancel your consent atany time simply by following the steps outlined below. Collecting and processing your dataisneeded in order for us to execute our service correctly.
The following non-disclosurepolicy sets out the processes we will undertake with regards to your personal data and in accordance with your right to confidentiality.
1. Legal terms.
AirRefund is a company established in Switzerland and abides by the following legal regulations:
• Federal laws regarding data protection from the 19thJune 1992 and which came into effect on the 1stJanuary 2014;
• The recommendations of the official Swiss Federal of Data Protection and Transparency.
Please note, that due todecision n°2000/518/CE on the 26th July 2000, regarding the remarking in accordance with the 95/46/CE Personal Data Protection Directive, the Commission confirmed that Swiss rules do provide the same level of protection as expected and in line withthe European Union.
AirRefund ensures to respect the prior declaration required by the CNIL (declaration number: 1909840) for companies established abroad which require data transfer means located in France after appointing a French representative.
2. Collected data content.
The personal data processed by AirRefund on its miniwebsite is as follows:
A passenger’s first and last name; their email address and the email address of any sponsor;their flight details (departure and arrival airport including transfers, flight number and flight date);the name of the airline; andthe type of Visa card used to purchase the flight.
Upon commencing a claim and upon success of said claim, the additional personal data processed is a passenger’s phone number and address; bank details and details regarding optional donations to a Charity.
3. Data collection tool.
Your personal data is collected through an online form which has been createdspecifically to register your claim and emails through a partnership agreement related to data transfer.
4. Data protection: private life and liberty.
Purpose:
Personal data which is collected is only recorded, processed and transferred to third-parties involved in handling claims (airline customer service departments, legal departments and our legal partners) in order to (i) follow-up on an individual claim, (ii) transfer data related to our service and (iii) set-up a KPI which will enable us to improve our service.
This data will never been shared, sold or rented for money or for free to another third-party.
Deletion:
We store personal data only during the execution of the AirRefund service and retention will notexceed (12) months from the moment the claim has been closed.
Right to access, correction and conflict:
Each passenger has the right to access all personal data upon request. This right enables the passenger to control and ensure their data is accurate. AirRefund confirms it will explain all aspects of the data and provide such personal data when the passenger requests it.
Each passenger has the right to correct and/or modify their personal data. AirRefund confirms it will amend personal data within (2) working days upon request.
Each passenger has the right to prevent AirRefund from using their personal data as mentioned above. For example, you can request that your personal data is not included on our mailing list. AirRefund confirms it will delete personal data from all systems within (2) working days upon request.
Each request related to the use of personal data, access, correction, conflict or deletion may be done by email to contact@airrefund.com.
5. Data Protection: security and integrity
AirRefund guarantees in will only provide secure access to personal data to authorize dindividuals.
When a provider involved in processing data is located in a country outside of the European Union which may not have the same data protection policies, AirRefund guarantees it will control all personal data transfers in order to continue to provide the upmost protection in accordance with the European Commission regulation.
Data storage:
Personal data is stored with HEROKU and SALESFORCE data centres which are respectively based in Dublin (Ireland) and London (United Kingdom). Such centres are secure and can only be accessed by AirRefund.
Air claim management software:
We mainly use SALESFORCE as our CRM (Customer Relationship Management) software which ensures a secure environment by implementing firewall protection, intrusion system alerts, SSL encryptions and a secure product for owners.
November 2015 Edition