Privacy Policy
Effective from Dec 21, 2023 FlyLux365 (“FlyLux365”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal information. This policy describes FlyLux365 practices regarding personally identifiable information or personal data (“personal information/PI”). This policy applies to our websites, applications, email, voice calls and text messages, and social media accounts (the “Platforms”). When you use the Platforms, you agree to the terms in this policy.
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to provide you with information on how FlyLux365 collects and processes your PI, including any PI you may provide through the Platforms, when you purchase a product or service or sign up for our newsletter.
It is important that you read this privacy policy together with any other privacy policy, notice, or fair processing policy we may provide on specific occasions when we are collecting or processing PI about you so that you are fully aware of how and why we are using your PI. This privacy policy supplements other notices and privacy policies and is not intended to override them.
CONTACT DETAILS
FlyLux365 is the company (business) responsible for your PI. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO using the details set out below.
Full name of legal entity: FlyLux365 LLC
Email address: support@flylux365.com
POLICY AMENDMENTS
We keep our privacy policy under regular review, updating it at least once every 12 months. FlyLux365 might make minor amendments to this Privacy policy which shall not adversely affect your privacy, except if laws set otherwise. In case of material changes, FlyLux365 will definitely publish such amendments and the amended policy on our website and, as far as possible, notify you either by email or by pop-up windows when you are using our Platforms next time. Amendments shall enter into force on the Effective Date. The actual version of the Privacy policy is published on our website.
DATA ACCURACY
When you provide us with PI, you are telling us that the information is true, accurate, complete, and current. You are also telling us that you have the authorization to provide it to us. It is important that the PI we hold about you is accurate and current. Please keep us informed if your PI changes during your relationship with us.
THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We may collect, use, store, and transfer different kinds of personal information (PI) about you, which we have grouped together as follows:
Identifiers or Identity Data: This includes your first/middle/last name, alias, postal address, unique personal identifier (cookie), date of birth, online identifier, Internet Protocol (IP) address, or other similar identifiers.
Contact Data: This involves your billing address, delivery address, email address, and telephone numbers.
Commercial Information: This comprises requested price quotes, products or services purchased, or other purchasing or consuming histories or tendencies. It also includes Financial Data (bank account and payment card details) and Transaction Data (details about payments to and from you and other details of products and services you have purchased from us).
Network Activity Information: This includes Technical Data (your login data, browser type and version, browsing history, search history, time zone setting and location, browser plug-in types and versions, operating system and Platform, and other technology on the devices you use to access our Platforms), and information regarding your interaction with our Platforms (Usage Data).
Geolocation Data: This involves information about your country, state, or city.
Audio and Electronic Information: This encompasses call records and email threads.
Inferences: This consists of conclusions drawn from any of the PI collected by FlyLux365, including Profile Data (your preferences, characteristics, psychological trends, behavior, attitudes, intelligence, feedback, and survey responses) and Marketing Data (your preferences in receiving marketing from us and our partners and your communication preferences).
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your PI but is not considered PI in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Network Activity Information to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your PI, so that it can directly or indirectly identify you, we treat the combined data as PI, which will be used in accordance with this privacy policy.
Customer Support: If you choose to contact our customer support services, we will collect any inquiries, complaints, or other information that you may submit to our support team.
We do not collect any Special Categories of PI about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
CHILDREN
FlyLux365 does not knowingly collect PI from minors, except if the minor is one of the travelers. If we become aware that a minor is attempting to submit PI, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us PI, please contact us so we can delete it.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we collect PI required by law or under the terms of a contract, and you fail to provide that PI when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
HOW WE COLLECT YOUR PERSONAL INFORMATION
At FlyLux365, we employ various methods to collect Personal Information (PI) from and about you, including:
PI You Provide Directly:
We collect PI directly from you through live chat, online forms, or voice calls/messenger.
Any contact data (emails, phones, etc.) provided by you during interactions will be treated as your personal contacts and saved in your profile for future communications, unless specifically requested not to be stored (one-time communication only).
Examples include providing PI when applying for our products or services, subscribing to our service or publications, requesting marketing, giving feedback, or contacting our customer support.
In case of interruptions or closures in chat (e.g., WhatsApp, Facebook, SMS), we may contact you later via automated phone, text messages, or email (if available) to restore communication initiated within the chat. No purchase necessary. Opt-out from further communication is available by replying to SMS/email or notifying us during the phone call.
Voice Calls: Voice calls are a primary method to ensure you've chosen the best option, providing immediate customer support and disclosing additional product features. We typically call back on your request. Opt-out of this communication is available at any time by contacting us via phone or email.
Passive Collection of PI:
We collect your PI passively, such as information about you over time and across different websites when you visit our Platform.
Tracking tools like cookies and beacons are used. As you interact with our Platforms, we automatically collect Network Activity Information about your equipment, browsing actions, and patterns.
PI Received from Service Providers:
PI is collected using service providers, including instances where you log in using a service provider platform, like Facebook.
Integration of service providers' software may occur for information collection related to security.
Location Information:
Our Platform features may leverage your device attributes and settings to determine your physical location (country, state).
Technologies, including IP address mapping, may be used for this purpose. We utilize this information to enhance your experience, personalize it, and provide offers and services of interest. We recommend enabling location services on your device for optimal use of location-based features.
Note: For details on the categories of PI collected, disclosed, or sold for a business purpose in the preceding 12 months, please refer to the relevant section
FOR WHAT PURPOSE WE USE YOUR PERSONAL INFORMATION
At FlyLux365, we utilize your Personal Information (PI) for various purposes aimed at enhancing your experience and ensuring the efficient delivery of our services. Here's an overview of the key purposes:
Improving Our Services:
To provide and enhance our Platforms and services.
Better understanding the users of our Platforms.
Protecting our property and preventing damage.
Regular Customers:
If you've requested a price quote or purchased our services, you are considered a Regular (loyal) Customer.
Benefits include becoming an expert in using our services and receiving the most relevant price quotes.
We may contact you as a Regular Customer via email/phone saved within previous requests and transactions. If you wish to opt-out, please contact us.
Bookings:
Processing your bookings and storing itinerary information where applicable.
Marketing Activities:
Sending marketing emails and/or text messages from FlyLux365 regarding our services or those of our partners, if you've opted-in or transacted with us. You can easily unsubscribe at any time.
Displaying relevant advertising and recommendations, based on collected information, on our Platforms and third-party platforms.
Administering promotional activities if you choose to participate.
Communicating with you for various purposes, including booking confirmations, alerts, notifications, reviews, updates, customer support, and information about services believed to interest you.
Legal Purposes:
Handling and resolving legal disputes.
Regulatory investigations and compliance.
Enforcing the terms of use of the service.
Performance of a Contract:
Necessary use of PI to perform requested services and provide products.
Membership Management:
Offering the ability to manage all booking information within an online account.
Access to historical data, referral discounts, and other bonuses as per account terms.
Option to delete the account at any time.
Consent:
Relying on your consent for certain direct marketing purposes.
You can withdraw your consent at any time by contacting us.
For a detailed description of all the ways we plan to use your PI, refer to the table format below.
I apologize for any confusion. Here's the revised text tailored for FlyLux365 LLC:
CHANGE OF PURPOSE
We will only use your PI for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
YOUR CHOICES
As a customer-oriented business, we respect and value your expectations. Consequently, you can make announcements and queries at any time regarding your concerns in privacy matters. Each of our marketing emails has an opt-out button, and you can unsubscribe from such communication at any time. However, you cannot unsubscribe from servicing emails and administrative messages.
HOW WE SHARE YOUR PERSONAL INFORMATION
Corporate affiliates and change of control: We may share your PI with our corporate affiliates, and if FlyLux365 itself (or part of its business) is sold or otherwise changes control, owners would have access to your PI for the uses set out herein.
Service providers: We may share your PI with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information.
Payment service providers and travel vendors: If you book through the Platforms, we may share your PI with the payment service providers, acquirer banks, and the travel vendors you have booked with. This can include online travel agencies, hotels, airlines, car rental companies, and travel insurance providers. These third parties will process your PI as data controllers in accordance with their own privacy policies. If you contact our customer support, they may need to share information about your request with the relevant travel vendor to assist you.
Business partners: We may share your PI with various business partners. Some of these business partners may use your PI for fraud detection, including but not limited Identifiers, Contact Data, and Network Activity Information, also to detect, prevent, or otherwise address fraud, security, or technical issues. We may also share your PI to ask our partner to create a survey, form, application, or questionnaire, so we know the degree of your satisfaction with our services. Some of these business partners may use your PI for online behavioral advertising purposes or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. We may also share anonymous aggregated usage information with partners.
We enter into confidentiality and PI processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards, and we regularly review these standards and practices.
Trips shared by you: If you use or have itineraries as part of our Service, you can send or grant access to your itinerary to anyone you choose. Your itinerary may contain enough details (for example, booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. If you choose to display your itinerary on publicly-viewable web pages (Facebook, for instance), that information may be collected and used by others.
Information shared in public: If you provide us a review of your trip, you authorize us to publish it on all our Platforms under the screen name you provided. You also authorize us to aggregate it with other reviews.
Authorities: We may disclose PI if required by law, for example, to law enforcement or other authorities. This includes court orders, subpoenas, and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your PI if the disclosure is necessary for the prevention, detection, or prosecution of criminal acts or to prevent other damage or in response to a legal action or to enforce our rights and claims.
We may also share anonymous aggregated usage information with others.
All the above categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.
HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION
Our servers and data centers are located in the U.S, and our service providers may be located there and in other countries. By providing us PI, you agree that your PI may be transferred to and stored in these countries. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your PI may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries. Subject to the applicable laws of such countries, we will provide the necessary safeguards to maintain protections of your PI, e.g., by obtaining from the PI recipients contractual commitments based on the EU model clauses.
FlyLux365 has a security program intended to keep the PI stored in our systems protected from unauthorized access and misuse. Our systems are configured with data encryption or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the PI you send over the Internet. PI may only be accessed by persons within our organizations or our service providers to carry out the uses indicated in this Privacy Policy.
We have put in place appropriate security measures to prevent your PI from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your PI to those employees, agents, contractors, and other service providers who have a business need to know. They will only process your PI on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected PI breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
RETENTION PERIODS
We will only retain your PI for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your PI for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.
To determine the appropriate retention period for PI, we consider the amount, nature, and sensitivity of the PI, the potential risk of harm from unauthorized use or disclosure of your PI, the purposes for which we process your PI and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
OTHER WEBSITES
If you click through to third-party websites or other platforms, FlyLux365 LLC’s privacy policy does not apply.
REQUESTS AND COMPLAINTS
Under certain circumstances set by applicable law, you are entitled to:
Request access to your PI (commonly known as a “data subject access request”). This enables you to receive a copy of the PI we hold about you and to check the correctness and integrity of PI. The disclosure might be limited to the 12-month period preceding the receipt of verifiable requests. You may also request us to furnish you with:
the categories of sources from which PI is collected;
the business or commercial purposes for collecting PI;
the categories of third parties with whom we share your PI;
the categories of PI we have disclosed for a business purpose.
Request correction of the PI that we hold about you. This enables you to request any incomplete or inaccurate PI to be corrected, though we may need to verify the accuracy of the new PI you provide to us.
Request deletion. You are able to submit a verifiable request and ask us to delete your PI. Please be aware, there are some cases when we might reject your request.
Request to opt-out from PI sales/sharing. Such requests shall be submitted through the “Do Not Sell/Share My Personal Information” website.
Due to the remote nature of our services, it is important for us to keep communicating through the same email (Verified Email), which was used by you to request a price quote or purchase air tickets and other related services. The Verified Email is the key communication channel for us, so we can give quick answers and not divulge your data to any malicious person. You might also submit a request through a voice call, but still, we must use the Verified Email to reply, due to law requirements and to protect our legal claims. If you submit your request through the authorized agent or by using a third-party service, we will ask for additional verification by contacting you via Verified Email.
NONDISCRIMINATION:
We shall not discriminate (deny services, charge different prices, provide different levels of quality) against you because you exercised any of the rights set herein. This right might be limited if the difference in prices or levels or quality is reasonably related to the value provided to you by your PI. We might obtain your opt-in consent and provide you with financial incentives, so you agree to provide additional PI or not to request the deletion of your PI.
FEES and DENIALS:
You will not have to pay a fee to access your PI (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive (more than twice in a 12-month period), or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We might also refuse to act on your request when we are not in a position to identify you and verify your request or the requested fee was not paid. We may need to request specific information from you to help us confirm your identity and ensure your right to access your PI (or to exercise any of your other rights). This is a security measure to ensure that PI is not disclosed to any person who has no right to receive it. We may also contact you (via email, phone, or messenger) to ask you for further information in relation to your request to speed up our response.
Due to law limitations, we might deny your request to know if you are asking us to disclose high-risk data (e.g., SSN, driver's license number, financial account data, passwords, etc.). In such cases, we will inform you that we have collected such types of information unless prohibited from doing so by law.
TERMS:
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. The maximum response time shall not exceed 90 days.
CONTACTS:
You can submit your complaint/request to the DPO email (see above).
HOW FlyLux365 LLC RESPONDS TO “DO NOT TRACK” SIGNALS
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.
FlyLux365 LLC COOKIE POLICY
Cookies are a small piece of data sent from the Platform and stored on your device (computer, smartphone, etc.) by your web browser while you are browsing our Platforms and sometimes down the line. Without Cookies, it would be impossible to provide you information and services you are requesting through the Internet. Cookies remember stateful information (such as items added to the shopping cart in an online store) or record your browsing activity. They can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords, and billing addresses.
By using the Platforms, you agree to the use of any of the cookies and tracking tools mentioned in this policy unless you opted out (available only for some cookie types). Additional information about cookie purposes can be found here or you can send a request to us.
CATEGORIES OF COOKIES USED BY FlyLux365 LLC
Technical and strictly necessary Cookies
In most cases, our Platforms use cookies to ensure technical feasibility to connect our Platform with your device and provide services requested by you. This cookie is integrated by default into our Platforms. In case you try to block/turn off any of such cookies, you might not receive some essential parts of services requested by you. Some examples of such cookies are:
1. User input cookies (session-id):
Used when filling an online form (ticket buying, making payment, etc.).
2. Authentication cookies:
Used for authenticated services, e.g., when logging into your online account within any information systems integrated with our Platform.
3. Security cookies:
Used to detect authentication abuses and prevent malicious attacks.
4. Multimedia content player session cookies:
Such as flash player cookies.
5. Load balancing session cookies:
Used for faster processing of your requests.
6. Third-party social plug-in content sharing cookies:
Functionality and Preferences Cookies:
These cookies help us optimize and make our Platforms more user-friendly, enhance security levels, facilitate faster and more convenient use of Platforms, and receive valuable statistics in an anonymized way, including, but not limited to:
Making aggregated statistics on new visitors to the Platforms.
Helping us recognize your browser and its previously configured settings, such as language preferences, font size, etc.
Managing contractual relationships with partners when you book on partner websites.
Helping improve our Platform offering and for capacity planning purposes.
We or our service providers may set analytics cookies to gather aggregated or segmented information about the types of visitors accessing our Platforms and the pages and advertisements they view. This information, including pages visited and links clicked, is not used to personally identify you. If we collect Cookies for statistical purposes, we commit to applying a "functional separation" principle to ensure that the results of processing have no negative impact on your privacy, and no decisions are made against you. The retention period of Functionality Cookies is usually very short. Under strict supervision, we might allow service providers to collect Functionality Cookies on our Platforms to provide us with aggregated statistics, requiring them to aggregate or erase data obtained from your device.
Advertising and Targeting Cookies:
We and our third-party vendors, including Google and Facebook, use Advertising cookies to serve ads based on your prior visits to our Platforms. For example:
Making use of cross-device tracking to optimize advertising activities.
Working with online advertising companies to display targeted advertising on our Platforms and third-party platforms that you visit.
Using Google Analytics to collect demographic and interest data about you (such as age, gender, and interests).
Using information collected about you for Google services such as Remarketing with Google Analytics and Google Display Network Impression Reporting.
Choices you make are browser and device-specific. Some aspects of our site use cookies to function, and you may not be able to use these features if you set your device to block cookies. We anonymize IP addresses in Google Analytics. We and our advertising partners may also use web beacons (single pixel GIF images) placed in the code of a web page or an email newsletter to track your activity on partner sites within our mobile applications.
OPT-OUT FROM COOKIES
Your browser gives you the ability to control cookies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. Your opt out choice is stored in opt out cookies only in that browser, so you should separately set your preferences for other browsers, computers, or devices you may use. If your browser blocks cookies, your opt out preferences may not be effective. Deleting browser cookies can remove your opt out preferences, so you should visit this page periodically to review your preferences. If you block or delete cookies or opt out of online behavioral advertising, not all of the tracking that we have described in this policy will stop. Please also note that opting out of a third party cookie does not mean that you will no longer receive or be subject to online advertising or marketing. It means that the third party service from which you opted out will no longer deliver ads tailored to your web preferences and online behavioral. You may also opt out of third party cookies by visiting opt-out website like https://optout.aboutads.info/?c=2&lang=EN or https://www.cookiesandyou.com/disable-cookies/windows/chrome/
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