Privacy Policy

Last Update: 2024-03-27 17:30:03

Keeping your personal data secure is a priority for us. Access to data is limited only to eLandFly employees who need it to do their jobs.

About this policy

This policy, as well as the Terms of Service and Cookie Policy, explains how we collect and manage your information on our websites, mobile applications and services. We review this policy regularly to ensure that we keep it up to date. Whenever we make any changes, we post the most recent version here. If we make significant changes, we will inform you about it the next time you access our services again.

The term "personal data" appears many times in this document and refers to any information that can identify you as an individual, such as your name, contact details, travel itinerary, Internet Protocol (IP) address, cookies and device IDs, as well as information that does not necessarily identify you as an individual, but that we store along with those identifiers, such as how you use our services or the country from which you use them.

We can only speak for ourselves, so this policy does not apply to how your information is collected or used by the airlines or travel agencies we display ("Travel Providers"). Therefore, each time you make a booking with a Travel Supplier, that Travel Supplier will treat your information in accordance with its own terms and conditions and privacy policy. You must read and agree to the Travel Supplier's terms and conditions and privacy policy.

Who is responsible for the data?

Who is responsible for the data? All data provided by you in any of the eLandFly WEBs or APPs are the responsibility of Álvaro Tomás Marín Vílchez with address at Calle virgen del coro, Madrid. The contact email address is [email protected]

Why and how do we use your personal data?

We only use your information where you have given us your consent, where it is necessary for us to provide the services you have requested, where it is necessary for us to exercise or comply with legal rights or obligations or for the normal business purposes described in this policy.

Where it is necessary to do so in order to provide you with our services or to assist you in performing a contract you have entered into or are about to enter into (such as, for example, when making a booking with a Travel Supplier).

See how we use personal data to perform contracts.

• To ensure that you can use our services on your device, for example, by tailoring the information we display to your device type.
• To generate results in response to your search queries, for example, by providing you with a list of flights that match your needs.
• In cases where you select a Travel Supplier with whom you want to make a booking, by redirecting you to the Travel Supplier's platform, along with such data as is necessary for it to recognize you and the travel option you have selected on eLandFly, including your browser or device data and your travel search details.
• To contact you with notifications, alerts or messages that are necessary to provide you with our requested services such as essential communications emails, including flight status alerts and notifications about changes or developments to our services or to this policy, the Cookie Policy or Terms of Service.
• To respond to communications you have sent to us, either through our customer service or social media.
• To display reviews, images and any other content and multimedia that you submit to eLandFly or upload to the eLandFly Websites or Applications ( "User Content"), and to provide you with the tools necessary to manage and remove this content.
• Where you have created an eLandFly account, we will process your data to maintain and administer it, and to ensure that it is kept up to date and accessible.

To improve or optimize our services, as well as to protect our legitimate interests. These include quite serious reasons such as fraud prevention and security, as well as more pleasant reasons such as product optimization in order to continue to offer the best version of eLandFly to our users.

See our legitimate interests.

• Security and fraud prevention reasons, (e.g., your IP address) to protect our services against misuse of our APIs or automated software searches. For these purposes, we may make automated decisions about you that may result in search blocking by us or by the Travel Supplier with whom you are booking.
• To identify and fix bugs in our services or enhancements using information such as your browser, operating system, language and location information, and general website activity, as well as any feedback you provide.
• To provide you with customer service or support in relation to any questions or problems you may have while using our services.
• To analyze and corroborate how, when and why users use eLandFly in order to evaluate, improve and optimize our services.
• To verify the volume of users who make bookings with Travel Suppliers or are redirected to their websites, as well as details related to selected travel options for business registration and business analysis purposes.
• Analyze the different groups of users who may view or click on our services to better understand which features are most used.
• Review and moderate User Content that you upload to the eLandFly Websites and Apps.
• Conduct tests that show alternative versions of our services to different groups of users in order to assess the positive or negative impact of these changes on the user experience.
• To measure the effectiveness of our communications by recording and analyzing whether you have opened the emails we have sent you.
• To personalize the experience on our Websites and Apps in order to ensure that it is as useful, effective and relevant as possible.
• We will use cookies to remember your language and location preferences or to personalize your experience. To do this, we highlight or recommend specific information or travel options that we think may be of interest to you based on your location, your eLandFly search history and general usage of our services.
• If you have asked us to send you newsletters or other marketing communications, we may tailor their frequency or content to reflect what we believe may be of interest to you.
• We may use your location information to predict which departure or arrival airport may be of most interest to you.
• We will show you relevant advertisements about our services or other services that we think may be of interest to you. For example, if you have recently searched for a flight to a specific destination, you may see a message from us asking if you would like to search for a hotel or car at that same destination.
• Providing you with a personalized experience involves creating a profile and a timeline of your activity on our services. However, we take due care to ensure that none of our activities involve obtaining information or making decisions automatically that may affect you legally or otherwise.
• We may use your data to improve our machine learning algorithms in order to personalize the Services. We will not use data that allows direct identification of the user, such as contact or other data, for these purposes.
• To make informed, strategic business-related decisions by creating aggregated, anonymized data sets that allow us to generate useful statistics and turn them into patterns or trends within the travel industry. For example, we may use search data to see demand for particular destinations and ensure that the fares and travel options we show users are available through our services. This information is also useful to Travel Suppliers, as it allows them to identify demand for new routes or destinations and to offer competitive fares.
• To contact you to invite you to participate in market research.

Where we need to process your personal data because of a legitimate interest, we will only do so if it is relevant and adequate, and limited to the requirements necessary for the purpose for which it is collected. Naturally, we will always ensure that our legitimate interests do not interfere with your own rights and freedoms.

When we have your consent.

We will ask for your consent for purposes such as:

• Sending you emails about services you request, such as price alerts.
• Send you marketing communications directly by email, push notifications or other means if you have given us your consent.
• Store certain cookies on your device.
• Record and evaluate feedback you send us if you agree to participate in our tests.

Where we process your personal data only with your explicit consent, you may withdraw your consent at any time by contacting us.

Where it is necessary for us to exercise or fulfill our own legal rights or obligations.

We may need to retain and use your information in connection with any legal claims or for compliance, regulatory and audit purposes. For example, we may retain certain information if required to do so by applicable law or if we are compelled to comply with a court order or regulatory agency. Also, if you exercise your applicable legal right to access, modify or delete your personal data, we may request identification and verification documents from you in order to confirm your identity.

What personal data do we collect?

We collect, store and process pieces of information from all users who use our services. However, we do not collect more information than we need.

Without information, we cannot help you plan and book your desired trip. Therefore, when you use our services, we must collect, retain and share some personal information and ask for your consent to do so in accordance with this policy. We may collect information in three different ways:

You provide it to us voluntarily.

The information you choose to provide to us may include a range of personal information that is required when you create your user account, such as names and contact details. It may also include content such as opinions or photographs that you choose to upload to our services for the purpose of sharing with other users. Importantly, it is always your choice whether or not to provide us with this information.

We automatically generate or collect it

Some information is automatically generated and collected from your computer or device while you use our services. This information includes information such as your IP address, information about the device and browser you are using to access our services, the URL of the website from which you are visiting us, and the third party websites you visit when you click on links and leave the eLandFly website. We also learn your approximate location from your IP address or mobile device. In this way, we can improve your experience and provide you with more relevant content.

We receive it from third parties

We sometimes obtain information about you from third parties depending on how you have interacted with us. For example, when you visit our website through a promotional partner or when you log in to your eLandFly account using the social media login feature. In addition, if you have made a booking with a Travel Supplier, we may collect information from them to find out whether you completed the booking process, what you booked and whether everything went smoothly. We may also collect data about you from the fraud prevention security service providers we work with to prevent misuse of your personal data.

Our services are not intended for children under the age of 16. In addition, no one under the age of 16 should provide any information on or through our services. We do not knowingly collect personal data from children under the age of 16, and we delete it if we become aware that we have done so or have received personal data from anyone other than the child's parents or legal guardians, or without their explicit consent.

Depending on how you interact with our services, we may collect or process the following categories of personal data in any of the three different ways explained above.

• Contact information:
  • Such as name, mailing address, email address, phone number and other similar information.
• Identifying information:
  • Such as a copy of your passport or other identification confirmation documents that may contain information such as your name, mailing address, gender, nationality and date of birth.
• Travel and booking information:
  • Such as your booking reference number, booking history and itinerary for a particular trip.
• Demographic data:
  • Age, gender, location and preferred language if you use our services.
• Device and location information:
  • Generic details of your device, such as IP address, type, make, model and operating system.
  • Specific location data based on your mobile device's GPS data (if you grant us access to this information in your device settings).
  • Undetermined location based on IP address.
• Usage and profile information:
  • Your eLandFly search history and travel preferences.
  • How you have interacted with our services, including the time you have spent on our website or app and the pages or features you have accessed.
  • The links you clicked to be redirected to or from our services to a Travel Supplier, including the identity of the Travel Supplier in question and the type of travel you selected.
  • When you are redirected to a Travel Supplier's website or application for the purpose of making a booking, we may collect certain information from that Travel Supplier about whether you completed that booking with them and what exactly you booked.
• Preference Information:
  • Selected preferences associated with your eLandFly account, including specific consents you have accepted or declined, email and notification preferences, and cookies containing your advertising preferences.
• Communications Information:
  • This includes communications you send to us, such as feedback, requests for help from the website or by email, as well as other electronic communication channels such as instant messaging or social media.
  • Metadata associated with such communications, such as date and time.
• Content generated or provided by users:
  • Content you upload to our services, such as comments, photos, videos, recommendations, preferences, opinions and metadata, such as the date and time associated with that content.
  • Any information you submit to us in the course of any correspondence you may have with us, such as signatures, photos and reviews.

How long do we store your personal data?

We only keep your data for as long as we need it or if required to do so for legal reasons. We then delete it or anonymize it. Your data is treated differently depending on its use, but you can ask us to delete it at any time.

Your personal data is kept for as long as we need it. This depends on why it was collected or whether we have a continuing legal basis for doing so (for example, to fulfill a contract between the parties, to provide a service you requested, or to meet our legitimate interests). We assure you that if we no longer have any reason or legal obligation to process your personal data, we will delete or anonymize it.

There are different data retention policies for different types of personal data taking into account the following:

• The purpose for which we have collected the personal data.
• The time needed to fulfill that purpose.
• Any overriding legal reason or obligation to retain the personal data for a particular period of time.

In addition, if you have an account with us, we will retain personal data such as your email address, name and other details to enable you to log in and access our services as long as you have an account. We may also retain other information indefinitely, such as website activity linked to an IP address, which we use to better understand users, improve our services and protect our business interests.

We may also delete User Content, such as personal data, in accordance with our Terms of Service.

Regardless of the length of the retention period, you may request that your personal data be deleted in certain circumstances. You can learn more about how we manage your personal data in the What are your choices and rights? section of this policy.

When do we share your information with third parties or do they collect it themselves?

We only share your information when you ask us to, when it is necessary to provide our services to you, or when it is required for legal reasons. Companies you book with through eLandFly (such as airlines) will collect your information online in accordance with their own policies. Sometimes companies that advertise through our services may also collect your information (see section Do we use cookies or other similar technologies).

Sharing your personal information with third parties who only process it in accordance with our instructions

We share information about our users with certain third parties whose services enable us to provide our services (hereinafter, "Third Party Data Processors"). These Third-Party Data Processors range from technical infrastructure providers to customer support services and authentication tools. All Third Party Data Processors who handle information on our behalf are bound by contractual terms, which require them to protect the information, to process it in accordance with applicable data protection legislation and to use it only as agreed and not for the Third Party Data Processor's own interests (unless you have given your explicit consent for them to do so).

Third Party Data Processors may be located or process your information in a country other than where you are located. Where our use of an External Data Processor involves the transfer of your personal data from European territory to a location outside the European Economic Area (EEA), we will take appropriate steps to ensure that your personal data is adequately protected at that location. To this end, in most cases, standard contractual clauses approved by the European Commission will apply, together with robust security controls.

External Data Processors with whom we may share some of your personal data include the following:

• Fraud prevention security service providers (for example, we use them to identify automated software agencies that may disrupt our services or to prevent misuse of our APIs).
• Providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services.
• Providers of tracking tools that we use to monitor those instances where users click on a link that directs to a Travel Provider's website and are redirected from the eLandFly platform to that Travel Provider's platform.
• Cloud storage service providers and other IT support services.

Share your data with third parties, or allow them to collect it, for processing outside of our control.

Before making any purchase, we encourage you to carefully read the privacy policy of the Travel Supplier that will be using your information.

To prevent and detect fraud, we may share information about you with fraud prevention security service providers with whom we collaborate ("Fraud Prevention Providers").

Travel Providers and Fraud Prevention Providers may be located or process your information in a country other than where you are located.

We share personal data with third parties when you explicitly authorize us to do so (for example, if we offer a promotion jointly with a partner and you instruct us to share your email address with that partner for the purpose of receiving promotional emails).

We may share personal data that is publicly accessible and forms part of User Content (such as your likes and content of reviews or posts), or we may make it available to certain third parties with whom we have a contractual relationship for display on their travel-related products and services.

We may share your publicly accessible personal information, such as name, profile picture, reviews, traveler photos and posts, or make it available to third parties with whom we have a contractual relationship.

In addition, other third parties such as advertisers, marketing networks or affiliates may also collect certain information, through cookies and similar technologies. For example, your IP address and certain events related to your activity, such as searches you have performed or pages you have viewed on eLandFly, may be collected and transferred to such third parties so that they can provide you with relevant online advertising. Information collected in this way will never include your name, contact details or any other information that would allow you to be identified in the real world.

Disclosing Information for Legal and Other Reasons

We may disclose your information as necessary to enforce our Terms of Service or other agreements, as well as disclose it to a prospective or ultimate purchaser in the event that eLandFly is sold. We may also disclose your data when necessary to prevent, detect or punish illegal or suspicious activities, including fraud, as well as to prevent other harm or to respond, where appropriate, to a legally binding request, legal action against us or to exercise our rights and claims.

How do we protect your personal data?

We care about your privacy, so we use a combination of industry-standard methods.

Protecting your personal data is one of our priorities. We limit access to those eLandFly employees who need to see your information to do their jobs and provide our services.

Unfortunately, no website or application can guarantee complete security. However, eLandFly has been created in a secure manner in order to protect your personal information as much as possible. We use a variety of technical, organizational and administrative security measures and best practices depending on the type of data being processed. For example, the computer systems we use to store your data are limited access and have cloud servers with encrypted disks. We use TLS and HTTPS encryption to protect your personal data when it is transferred over the Internet.

To ensure that the concept of "privacy by design" is respected, all eLandFly employees are thoroughly trained in data protection and privacy. Fundamentally, we develop our services with the aim of using as little personal data as possible, for example, with data minimization techniques such as anonymization. In addition, when we develop or update our services and the collection or use of new forms of personal data becomes necessary, privacy impact assessments will be conducted to understand and reduce the likelihood that you will be affected by mistake.

Where do we store your information?

Your data is securely stored in data centers around the world, the exact location depends on where you are when you access eLandFly. Your data will only be processed by providers who provide appropriate contractual safeguards for the information they process. At times, your data may be stored in countries with different levels of security, but we ensure that their standards are in line with ours.

Currently, we use servers located in France. These servers are provided or supported by third parties acting on our instructions.

If you have any questions about how we protect your data, please contact us.

How do we use your information for advertising purposes?

When you use our services, you will see advertisements, and you may also see advertising from eLandFly when you browse other platforms. The ads may be ours or from third parties, and can be customized to be more relevant to you. The information used to personalize the ads you see may include details about what you have searched for on eLandFly or general information about your location, such as city or airport, but will never include your name, contact details or other information that would allow you to be identified in the real world.

Advertisements using eLandFly

You will see advertisements while using our services. These advertisements may come directly from us or from third-party advertising solution providers ( "Advertising Agencies").

Many of these ads will be customized to be relevant and will fall into two different categories. On the one hand, advertisements customized for you based on information collected by us or an Advertising Agency while using our services, such as your general location (by city or country) and your search history on eLandFly ( "eLandFly Related Information"). For example, if you have booked a flight to Rome, you will see advertisements for hotels in Rome and not in Paris. eLandFly Related Information will never include your name, contact details or other information that would allow you to be identified in the real world. On the other hand, ads customized for you based on information over which we have no visibility or control and that other Advertising Agencies have collected while you were using other websites or platforms that do not belong to eLandFly. Collectively, we refer to these as "interest-based" ads.

Third Party Advertising Solutions store the information necessary to serve these interest-based ads along with your IP address or a cookie ID so that you can be shown ads without storing any real-world identifiable information, such as your name or address.

If you have enabled ad personalization, we may also use the information we collect through cookies and similar technologies to show you customized promotions, marketing and advertisements or to send you communications if you have opted in. For example, if we have redirected you to make a reservation on a partner site, we may use the information we collect through cookies and similar technologies to personalize the ads we show you or to send you marketing communications for the reservation based on information such as destination, travel times, services selected, or travel provider chosen. We may also use this information to provide you with relevant information about the destination you are traveling to, such as city guides and weather information, or to solicit reviews and recommendations about places.

Ads Viewable on Non eLandFly Platforms

You may see advertisements for our services after you leave our website and use different websites. For example, this would happen if you use an advertising agency that has advertising space available for sale and eLandFly or an advertising agency that we work with purchases that space. These ads, which are similar to the ads you see when using eLandFly, may be customized and served based on information that the Advertising Agencies have collected about you while using our services or other non-eLandFly Platforms. For example, if you have searched for a flight from Madrid to London on eLandFly or another non-eLandFly Platform and we have asked a third party Advertising Solution to show our ad to people who have shown interest in traveling to London, that Advertising Solution may classify you in that category and show our ad to you.

Do we use cookies or other similar technologies?

We use cookies and similar technologies to provide you with, improve, personalize and analyze our services, and for advertising purposes.

We use a combination of cookies and other technologies such as pixels or web beacons and tracking codes (explained below) to collect information and use it online for the purposes mentioned in this policy.

What is a cookie?

A cookie is a small data file that is stored on your computer or device. Cookies record information such as your preferences and settings, which allows us to obtain the information we need to provide you with the most consistent and relevant experience possible. We also use cookies to record information about experiments or new enhancements that we may test to track how you use our services and to test the effectiveness.

Cookies on our website may be our own, from third parties with whom we collaborate or from independent third parties (e.g., advertisers).

What are pixels or web beacons?

Pixels or web beacons are small transparent image files found within a web page or email. These beacons allow us to understand user interactions with our services or whether you have been redirected to the Travel Provider's website or application. The pixel can also be used to confirm whether a user has continued with the booking and to find out what they have booked. We also use pixels to collect information about activities such as whether users have opened an email, which allows us to improve the communications sent.

What are tracking codes?

Tracking codes are small codes that are placed on a page to evaluate metrics such as visits and interactions. Tracking codes are used to gather information about how you interact with our services, the ads you see, and how you use our services in general.

Please see our Cookie Policy for more information about the types of cookies and similar technologies we use.

What are your choices and rights?

If you have an eLandFly account, you can view, edit, request a copy of or delete key personal data associated with your profile at any time from the Profile section. From here you can also manage your subscription and marketing preferences.

You also have a number of rights regarding the personal data we store about you. These rights are detailed below. To exercise these rights, please contact us via the Help Center.

You have the right to ask us for a copy of your personal data; to edit, delete or restrict the processing of your personal data; and to obtain the personal data you have provided to us in a readable format on a computer. In addition, you may object to the processing of your personal data in certain circumstances (in particular, where it is not necessary to process it in order to comply with a contractual or other legal requirement). Where we have asked for your consent, you may withdraw your consent at any time. If you request to withdraw your consent to eLandFly processing your data, the data that has been processed to date will not be affected.

There may be limitations to these rights. For example, if completing a request involves disclosing personal data about another person, if you ask us to delete information that we are required by law to keep, or if it would harm your own legitimate and compelling interests.

If you cannot successfully exercise any of these rights through your Profile, you may do so through our Help Center.

If there is something that concerns you about this policy, you have the right to lodge a complaint with the competent data protection authority.