Privacy policy

Last updated: 12 Jan 2018

1. GENERAL

1.1 This privacy policy (”Privacy Policy”), describes how Avionero AB, registration number 559016-2847, with its principal place of business at Baltzarsgatan 18, 211 36 Malmö, Sweden (“Avionero”), collects, uses, discloses, stores and otherwise process personal data.

1.2 We respect your right to privacy, and we are committed to comply with applicable data protection rules and to safeguard your rights. We want to make sure that you are aware of what types of information we collect or obtain from you via the website, how this information is used and how we protect it.

1.3 This Privacy Policy describes, amongst other things, which information we collect about you, how your personal data is processed and for what purposes we collect and use the personal data. This Privacy Policy also describes your rights and how you can contact us about the use of your personal data.

1.4 Avionero is the data controller responsible for processing your personal data in accordance with applicable data protection legislation.

2. WHAT TYPES OF DATA DO WE PROCESS?

2.1 Personal data means all types of information which can, directly or indirectly, be used to identify a living physical person (“Personal Data”).

2.2 Most of the information Avionero collects from you is linked to non-personal identifiers such as an anonymous User ID, or device ID and does not enable you to be identified as an individual (“Non-Personal Information”). Such Non-Personal Information includes, for example, full recordings of your behavior on the site, clicks and inferred demographic information;

2.3 Avionero also collects and processes Personal Data about you when you visit our website and use our service, including (i) information about how you in particular use our website and service; (ii) details of the queries you make; and (iii) technical data, which may include your IP address, unique device ID, network and computer performance, browser type, language and identifying information, geographical location and operating system;

2.4 The legal basis for the processing mentioned in Section

2.3 (i) – (iii) is that the processing is necessary for the purpose of the legitimate interests of Avionero, as described further in section 4.

3. HOW AND WHEN DO WE COLLECT YOUR DATA?

3.1 Avionero collects information that you voluntarily provide to us when using our service and website. This include information, such as the search queries you enter when searching for flights, as well as your IP address.

3.2 In addition to information that you voluntarily provide to us, we also collect certain Non-Personal Information directly from you as you use our services, as well as indirectly where it is provided to us automatically by the third party application, social networking site or another website that you connect to the Avionero website from.

3.3 Avionero uses Google Analytics third-party audience data such as age, gender and interests to better understand the behavior of our customers. Such third-party audience data cannot be linked to an identifiable person and is thus not Personal Data. However, such data help us to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on our website or other websites because we work with Google and other similar companies to target our ads based on information we or they have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

4. WHY DO WE PROCESS YOUR DATA?

4.1 Avionero collects Personal Data as well as Non-Personal Information relating to you for the following reasons: (i) to deliver the Avionero service and the specific features you request, such as generating search results matching your search criteria; (ii) to ensure the technical functioning of the website and the services; (iii) to enable integration with third party services; (iv) to analyse user behaviour on our platform to provide, personalise and improve your experience with the website and our services, e.g. through the use of cookies, SmartLook and Google Analytics; (v) to analyse your use of the website and our services in order for us to develop and improve the website and the services as well as developing new services and products; (vi) to contact you with for example newsletters or price alerts that you have requested and to respond to communications you have sent us via our customer service or on social media; and (vii) to market ourselves and our services. For example, we may use information, such as what you have searched for on the Avionero website to present you with relevant advertisements. As an example of this, Avionero may use third party advertisement retargeting services to send you an advertisement related to a destination you have searched for.

5. FOR HOW LONG DO WE STORE YOUR PERSONAL DATA?

5.1 Your Personal Data is stored only for as long as there is a need to keep the data in order to fulfil the purposes for which the data was collected in accordance with this Privacy Policy.

5.2 The Personal Data will be deleted if:

1 the purpose of collection and use of Personal Data has been achieved; 2. the provision of the relevant service is discontinued by Avionero; or 3. you withdraw your consent (if applicable) to the collection of Personal Data by contacting us (for contact information, please see Section 10 below).

6. HOW MAY THE DATA BE SHARED?

6.1 Avionero will not sell, trade or lease your Personal Data to third parties. However, Avionero may share Personal Data with our trusted subcontractors (including Internet service providers) in order to provide you with our services. They may need access to the Personal Data in their assignment for us, but they will not be allowed to use the Personal Data for any other purpose.

6.2 Personal Data may be disclosed by Avionero to comply with legal requirements or other requirements from official authorities, in order to safeguard Avionero’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.

7. PROTECTION OF YOUR PERSONAL DATA

7.1 You should always feel secure when you provide your Personal Data to us. We have employed a wide range of security measures to help protect your Personal Data against undue access, modification and deletion.

7.2 We protect your Personal Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction.

8. YOUR RIGHTS Corrections, additions or erasure

8.1 You are always entitled to access your Personal Data for viewing, and to request that we correct or update your Personal Data, or erase certain of your Personal Data. Restriction of use and data portability

8.2 Under certain circumstances, you may request that Avionero restricts the use of your Personal Data. If you have provided us with Personal Data, you also have the right to have your Personal Data resubmitted to you, in a structured and accessible format, for transfer to another user/processor. Requests and Complaints

8.3 If you wish to exercise any of the abovementioned rights or if you have any questions regarding Personal Data held by us or this online Privacy Policy, please do not hesitate to contact us (for contact information, please see section 10 below).

8.4 Should you be dissatisfied with our processing of your Personal Data, please let us know, and we will do our best to meet your complaints. Your integrity is very important to us, and we always strive to protect and secure your Personal Data in the best possible way. Should we nevertheless, in your opinion, fail in this ambition, please note that you are also entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or such other authority as may be determined in the future.

9. COOKIES AND OTHER SIMILAR TECHNOLOGIES

Avionero and our partners use various technologies to collect and store information when you visit our website and use our services, and this may include using cookies or similar technologies to identify your browser or device. If you want to learn more about how we use cookies and similar technologies, please read our Cookie Policy.

10. HOW TO CONTACT US

You can contact us at: Avionero AB, Baltzarsgatan 18, SE-211 36 Malmö, Sweden, or at our email: hello@avionero.com.