Section 1: Data Processor
The Data Processor as defined by law is
Click2Refund Inc.
1 King Street West Suite 4800-200 Toronto, ON, M5H 1A1
Phone: +1 416-525-4764
E-mail: [email protected]
We are always prepared to answer any questions relating to data protection, so we ask that you don't hesitate to contact us.
Section 2: Data Protection Officer
Our data protection officer is responsible for the oversight of all processes involving data handling in our organization. The officer can be reached via regular email through the above-mentioned address.
Section 3: Subject-matter of our data processing and protection
We process and protect personal data on our website, and you hereby understand and accept that personal data is an umbrella terms for any piece of information relating to a natural person whether identified or unidentified (the so-called “data subject”), and may include without limitation information such as inter alia, names, e-mail addresses, telephone numbers.
We also collect additional information about users who use our services that are not personally identifying and which may include information such as the individual’s beginning, end and extent of use of our webpage or of third-party services for marketing purposes. The latter may be to determine the reach of our page and/or services in general.
You understand and accept that we may also collect and process data relating to details of your trip (e.g. flight dates, disruptions) and details of financial transactions in case of compensation (e.g. payment details such as methods, dates, amounts, banking details) due to the very peculiarities of our offered services. This information is necessary for the conduct of our services and will only be used for the purpose for which we obtained them from you.
Section 4: When do we process data
As a matter of policy, we only process data with legal permission, especially as it applies to situations in which the processing of the data is necessary for the delivery of our services (online or contract). That may include cases of a legally necessary consent or if we have a legitimate interest in the processing.
Instances in which we may process your data are:
Section 5: Processing data when visiting our webpage
We, among other things, process data when you visit our webpage even if you do so for informational purposes only and do not make a request for any service other than the information publicly provided on the webpage. In doing so, we process data provided by your browser to our server(s) and that is necessary from a technical point of view to actually display our webpage with all its functions and for security and stability reasons. This may include the creation of anonymous user profiles to better our services. Data collected under this category includes:
To allow us to make images, audio and video content available on our webpage in an interactive way, we make use of the Pageflow software as well as external service providers who process your personal information when this content is accessed. You understand and accept that these service providers are restricted in their use of such personal information by our instructions.
Section 6: Cookies
Click2Refund uses "cookies" to help us personalize and maximize your online experience. Due to this use of cookies, we are able to deliver faster and more focused results as well as a more personalized site experience. You may however choose to accept or decline cookies. Please note that opting to decline cookies may hinder our website performance on your device and negatively impact your experience on the Click2Refund website.
Cookies are small files that are saved to your device via your web browser.
Categories of cookies
We use cookies with different functions for a variety of purposes. Moreover, we differentiate between cookies, depending on them being mandatory from a technical perspective (meaning that they are required to ensure function), the length of their storage and usage (known as the retention period) and whether they have been put in place by our webpage itself or by a third party and, if so, by whom (i.e. which cookie provider).
Technical requirement
Technically mandatory cookies: We deploy certain cookies because they are compulsory requirements to make sure that our webpage and its functions can work in a legally compliant manner. Such cookies are automatically set when the webpage or a specific function is accessed, unless you have disallowed the setting of cookies via your browser settings.
Technically non-mandatory cookies: Non-mandatory cookies are set to improve, for instance, the performance and convenience of our webpage or to save certain settings made by you. We also make use of technically non-mandatory cookies to gather information on the frequency with which some parts of our webpage are used, so that they can be tailored more closely to your needs when next you use our services. We do not store technically non-mandatory cookies except you have clicked the relevant box, which confirms that you have read our cookie policy, and continue to use our webpage.
Retention period
Session-cookies: Many cookies are only needed for as long as you access the current page and for as long as you continue your session. They lose their validity or are erased immediately you leave our webpage or when your current session expires (these are so-called session cookies). Session cookies are for instance used to store some specific information during your session.
Permanent cookies: Some cookies are occasionally saved for a longer period and are used to recognize you when you access our webpage again sometime in the future. This means that you are able to call up saved settings again to ensure faster access to our webpage and more convenience and you don't have to confirm certain settings again, e.g. specify your preferred language. Permanent cookies are deleted automatically upon the expiry of a specific period of time following the date that you visited the domain or page where the cookie was set.
Cookie providers
Third party cookies: These are set and used by other webpages or providers, for example by operators of web analysis tools. You can find below in this policy further details on web analysis tools and range measurement. Third-party providers can also utilize cookies to display adverts or to integrate their social media content, e.g. social plugins.
Objection to and erasure of the use of cookies As previously stated, the acceptance of cookies is not mandatory in the use of our webpage. If you do not want cookies saved to your device, you have the rights to disable the relevant option via the system settings of your browser. You can also delete saved cookies via the system settings in your browser at any time. You however understand, that if you do not accept cookies, the functionality of our services may be limited.
Section 7: Processing of data to execute the contract
We process your data when you retain us to enforce your compensation against an airline. This personal information includes without limitation our communication with you, the details of your journey and your contact. Our contractual services and, therefore, our contractual relationship with you in case of assignment are described in full in our click2refund.com/Home/Terms
It is mandatory that you make this information available if we are to enforce your compensation in this way, and you understand and accept that we cannot enter into a contract with you without this information that are mandatory to verify and collect your compensation are released to us.
You also understand that we may pass your data on to service providers (e.g. providers of web services) to enforce your compensation. We will also share your data with the airline(s) involved in your case to make them aware of and enforce your compensation. In some cases, it may also be necessary to pass on your data to our contractual lawyers and/or public institutions to enforce your compensation. We will always try to limit the amount of data shared with these third parties but the nature of our contract may require full disclosure if your compensation claim has to be verified.
Payment data will only be collected when a payment is due to be made to you.
Section 8: Social media plug-ins
This webpage uses social plug-ins from social media pages such as Facebook, Google+ and Twitter. Here are the relevant addresses:
Facebook Inc., 601 S. California Ave, Palo Alto, CA 94304, USA.
Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA.
Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
You will find three buttons on our webpage, enabling you to share content on Google+, Facebook, and Twitter, so that you can recommend our webpage to friends on your preferred social media platforms. We have also implemented a Shariff solution on our webpage. This is a social media button that allows you access these social media pages without compromising your privacy. When you call up our webpage, data is not automatically sent to the relevant social media.
You however understand and accept that when you click on a social media button, your browser utilises this social plug-in to make a direct connection to the server of the respective social network. We have absolutely no influence and will under no circumstances not be responsible as to the scope of your personal information that is collected by the social media operators in this way. You also understand that the operators process the information that you have called up our webpage. If you are also plugged into one of such social media platforms at that time, the operator of that site is able to match up your account with the respective social media site, and may be able to process your information if you interact with the social plug-in by clicking “Like” or “Share”.
You understand and accept that these social media platforms can still again access to your IP address through this social plug-in and may then store this information even if you are not a registered user of the platform.
We advise that you read each company’s data protection policy to find further information about the scope and purpose for which personal information is collected, processed and used by Facebook, Twitter and Google, as well as your legal rights in this respect and the setting options. Here are the links:
www.facebook.com/policy.php
www.twitter.com/privacy
www.whatsapp.com/legal/
www.google.de/intl/de/policies/privacy/
If you do not want social media platforms to collect data via our webpage, do not click on the respective buttons. Additionally, you can block social plug-ins through add-ons in your browser.
Section 9: Bing Ads
Our website utilises the conversion tracking of Bing Ads made available by Microsoft Corporation, with the address - One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft “). To do this, Microsoft Bing Ads stores a cookie on your computer or accessing device when you have been linked to our website via a Microsoft Bing ad. Microsoft Bing and Flighright can thus recognize that someone clicked on an ad, was linked to our website and, as a result, has attained a previously determined target site (conversion site). These numbers let us know the total number of individuals who clicked on a Bing ad and have because of that being linked to the conversion site. If you have so clicked, be assured that your personal information and your identity will not be disclosed.
If you want to decline to participate in this tracking process, you can reject the required storing of cookies in your browser settings by deactivating the automatic storage of cookies. For further information on data protection and the cookies that Microsoft Bing uses, please refer to Microsoft's privacy policy.
Section 10: Google Analytics
This webpage uses Google Analytics, a web analysis service of Google Inc to analyze the use of our webpage and to improve it at regular intervals. The numerical data that we receive in this way helps us to improve our webpage and to make it serve you better as a user.
The information created by cookies on your use of our webpage is usually forwarded to a Google server in the US, and this is where it is then stored. If you have however activated IP anonymization for this webpage, your IP address will not be sent as is. First, it will be truncated by Google within the Member States of the European Union and/or other parties to the Agreement on the European Economic Area. It is only in exceptional cases that the full IP address will be sent to a Google server in the US and then truncated there. Acting on behalf of the website operators, Google will make use of this information to analyze your usage of the webpage, to create reports on webpage activities for us as page operators and to provide us with other services connected with webpage and internet use. The IP address that Google Analytics sends through your browser will not associated with any other data Google may have.
For extraordinary cases where personal data is transferred to the US, Google subjects itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). If you also wish to prevent the gathering of data generated by cookies as related to your usage of the webpage and you wish to opt out of such information being processed by Google, you may download and install a browser plug-in from the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
The opt-out cookies stop any future collection of your information when visiting this webpage. To stop collection via Universal Analytics across multiple accessing devices, you must implement the opt-out on all the systems you use. You can click here to set the opt-out cookie: Deactivate Google Analytics.
For the general protection of our users, our webpage uses Google Analytics with the extension “_anonymizeIp ()”. This does the job of truncating IP addresses before any further processing, so that the information cannot be related to any particular person. If the data that is collected about you automatically allows conclusions about you as an individual, this is immediately prevented and the relevant personal data is thus erased immediately.
Further details about Google and the way it uses personal data can be found on the following addresses:
Section 11: Facebook-Custom Audiences and Facebook-Marketing-Services
Due to our interest in the analysis, optimization as well as the economic operation of our online offers and for the purposes within the meaning of Art. 6 (1) f. of the GDPR we make use of the "Facebook pixel" of Facebook, a social network platform that is operated by Facebook Inc., with its registered address at 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook pixel to display our Facebook Ads only to Facebook users who have shown an interest in our webpage or who have specific characteristics (such as interests in certain products or topics as determined by the websites they visited) that we make available to Facebook (so-called "custom audiences"). With the assistance of the Facebook pixel, we are able to make sure that our Facebook Ads are in line with the interest of potential users and do not constitute a nuisance effect. Using the Facebook pixel, we can also track the effectiveness of Facebook Ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook Ad (so-called "conversion").
The Facebook pixel is directly integrated into our web pages by Facebook and can store a so-called cookie, i. e. a small file, on your device. If you then log in to Facebook or visit Facebook when you are logged in, your visit to our online offer will be noted in your profile. The data collected about you is anonymous for us, i. e. it does not allow us to draw conclusions about the identity of the users. However, the data is stored and processed by Facebook so that it can be linked to the respective user profile and used by Facebook as well as for its own market research and advertising purposes. If we transfer data to Facebook for comparison purposes, it is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done with the sole purpose of matching the data encrypted by Facebook.
Facebook's processing of the data is governed by Facebook’s Data Usage Policy. For specific information and details about the Facebook pixel and how it works, please visit the Facebook Help Center.
You may object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set what kind of ads you see on Facebook, you can go to the page set up by Facebook and follow the instructions on how to set up use-based advertising.
Section 12: YouTube
Our webpage contains embedded video clips from YouTube. YouTube is the portal of YouTube LLC, which is a subsidiary of Google Inc. To offer our users yet another layer of data protection, we as a matter of policy do not integrate the video clips directly into our webpage but have deactivated them by default. This means that no data will be transmitted to Google when you access our webpage. For that reason, we will only allow you to preview an image of the video clip on our webpage. You must personally activate the video clip by clicking on the preview image so as to watch the video. Only after you have so activated the video that a connection is established to Google’s servers and data is transferred to Google. You understand and accept that we have no control over the scope of personal information collected in this process. Please read the data privacy policies of Google for further clarification on the purpose and degree to which personal information is collected, processed and made use of by Google, as well as your rights concerning this and the setting options for protecting your privacy. Go to:
https://www.google.de/intl/de/policies/privacy/
Section 13: Google Dynamic Remarketing
We make use of the remarketing or “similar target group” function that is made available by Google LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google “) on our webpage. This enables us to send users of our webpage targeted advertising through the display of personalized and interest-based advertisements when they visit other webpages in the Google Display Network.
Google makes use of cookies by saving a small file with a sequence of numbers to your browser in order to analyze website usage and this forms the basis for the release of interest-based advertisements. This number is used to record the visits to the webpage and anonymized data on website usage. However, the personal information of visitors to the website is not saved. If you thereafter visit another website in the Google Display Network, that webpage will display advertisements that are likely to include products and information that you have accessed before.
You can permanently disable Google’s use of cookies by downloading and installing a browser plug-in. You can find more information about Google Remarketing in Google's privacy policy.
Section 14: Map service
Our webpage makes use of Google Maps, operated by Google Inc., with an address at Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Anytime that you access a page which includes Google Maps, your browser automatically connects with the Google servers. This allows the map content to be transmitted directly to your browser and to be integrated into the webpage by Google through its iFrame. If you are against Google collecting, processing or using data about you through our webpage, you can disable JavaScript through your browser settings. You however understand that you will not be able to use the map display if you do so. Further details about the processing of data by Google can be found in the Google Privacy Policy: https://policies.google.com/privacy.
Section 15: Google AdWords Conversion-Tracking
We make use of the online advertising program called "Google AdWords" as well as conversion tracking as part of Google AdWords. Google Conversion Tracking is an analytical service made available by Google LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google “). Anytime that you click on a Google ad, a cookie for conversion tracking is automatically stored on your computer, and will expire after 30 days. These cookies do not contain personal information and cannot be used to identify you.
If you click on certain pages of our webpage and the cookie has not yet expired, Google ad can detect that you clicked on the ad and were so re-directed to this page. Every Google AdWords customer gets a different cookie so it is impossible to track cookies through the websites of AdWords customers. The information gathered by the conversion cookie is used to form the basis of conversion statistics for AdWords customers who use conversion tracking. With a conversion tracking tag, customers are able to see the total number of users who clicked on their ad and were then re-directed to their page. They however, do not receive information that can personally identify such users.
For more information on the Google data privacy agreement, please visit: https://policies.google.com/technologies/ads, https://policies.google.com/privacy.
Section 16: Linked sites
You may find certain links to other website/apps on the Click2Refund website/app. It is important to know that these website/apps may have privacy policies that are different from our own. We are in no way liable for the activities, practices and/or privacy policy of these website/apps. Make is a personal policy to always read, review and be on board with the privacy policy of any website/app that you link through our website/app.
Section 17: How do we protect your private information?
We take steps to safeguard your private information in agreement with the Data Protection Regulation and established guidelines for the security of information. This means that we have specific routines and rules on the protection of data and we ensure that our staff only have access to the data that they need to perform their work.
Section 18: Storage time
Please note that our policy is to maintain information collected for commercially reasonable periods of time or in accordance with specific policies, except where prohibited by law.
Contact details such as name, phone number and e-mail address, that you have provided to us are stored in our database, and will delete such with a three-month period after you notify us that you no longer wish to use our services.
Section 19: Your rights under the data protection legislation
Click2Refund is a GDPR compliant website.
This means that you have the right to instruct us not to process or use your personal information in certain circumstances, such as for marketing purposes.
You have the right to withdraw your permission where the processing of your personal information is based on your approval, subject to contractual or legal limitations.
You have the right to change and update your personal information if you believe it is inaccurate or has been removed under certain circumstances. You also have the right to place restrictions on the manner in which we process your private information.
You have the right to disagree with and object to Click2Refund’s processing of your personal information, under certain conditions.
You have the right to instruct Click2Refund to transfer the information that we have obtained to you or to another organisation under certain circumstances.
You have the right to ask Click2Refund for copies of your personal information.
You have the right to instruct Click2Refund to delete your personal information, in certain circumstances.
You have the right to instruct Click2Refund to limit the processing of your personal information, under certain conditions.
Should you wish to use any of your rights, please contact us.
You can also learn more about the Data Protection Legislation and your rights by clicking on this link:
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679
Section 20: Final provisions
As mentioned above, the integrity and safety of your data is important to us. Thus, we may need to improve related protective measures from time to time. This can, consequently, lead to an amendment of our Data and Privacy Policy. We will notify you of any changes on our webpage. In case of no objection against the changes, they will come into effect four weeks of receipt of the notification. In case of an objection, we might have to terminate our contractual relationship with you and reserve the respective right.