1. BACKGROUND
Sky Maxxi (“Sky Maxxi SIA” or “we” or “us”) (registered Brivibas 389, Riga, Latvia; registration number: 40103416234) pays special attention to data protection. Data processing by Sky Maxxi SIA complies with the relevant Hungarian data protection laws and is carried out in accordance with this Policy.
2. THE INFORMATION WE ASK FOR AND USE OF YOUR DATA
2.1 Personal data
This Policy applies to all personal data you provide us or we collect and process in association with your relationship with Sky Maxxi SIA. For the purposes of this Policy “personal data” means any information relating to you from which you are or can be identified, directly or indirectly (in particular your name, address, phone number, e-mail address, credit or bank card number, information on special care) and any reference drawn from such information pertaining to you.
2.2 Collection of your personal data
Whenever you use our services or services offered by third parties on our website (e.g. you proceed with a booking for a flight or air transport service or any related activities) we collect personal data about you either provided by you to us (or our agent) directly or collected by us when you used our services or booked third parties’ services on our website. However, Sky Maxxi SIA is not responsible for third parties’ use of your data, where such use is permitted, for their own purposes. In such cases please consult their privacy policies for further information. You can find more information about the data transfers to third parties in section 3 below.
2.3 Information we collect and process:
– information about you,
– information about the services you purchased (whether directly provided by us or by our agent),
– the details of your travel arrangements (for instance the details of your booking and the additional services we provided),
– details of your use of our website (including but not limited to your historical bookings which you did not finish), call centers or mobile applications and
– information about communication you have with us and our staff.
By providing us with your personal data, you acknowledge and explicitly consent to Sky Maxxi SIA processing your personal data in accordance with this Policy and the relevant laws and regulations, including utilization of the data by Sky Maxxi SIA employees and the transmission of the data within or outside Hungary as specified herein.
In certain cases we also need to process your sensitive personal data (as defined in Section 3.3 of the Info Act) when you request special assistance from us and/or an airport operator (such as the provision of oxygen), or when you provide us with information about your fitness for fly (for instance if you are pregnant).
By providing any personal data that, is or could be considered to be, “sensitive personal data” you explicitly agree that we may collect, use, share with third parties (such as the departure or the destination airport or ground handling companies at such airports or our call center) and transfer outside the European Economic Area this personal data, as described in this Policy.
If you withdraw your consent or do not provide a data, it may mean that we will not be able to provide all or parts of the services you have requested. Please note that in these circumstances you will not be able to cancel or obtain a refund of any fees you have paid.
2.4 Use of your personal data
The purposes for which we use your personal data are:
a.) to deliver the services you have purchased from us or to facilitate the purchase of third parties’ services or products on our website, via our application or through our call center (data used for this purpose includes all of the data collected during the booking process: such as passenger name, nationality, gender, phone number, e-mail address;
b.) to provide services, offers and reminders tailored to your requirements (we use for this purpose personal data such as name and contact details, details of your historical searches);
c.) to communicate with you (for instance to send you reminder emails, or notifications about any flight disturbance) (we use for this purpose personal data such as name and contact details, flight);
d.) to communicate with you to carry out customer satisfaction survey for analytics purposes, for quality improvements, for service developments, to improve the performance of the website, to measure the success of our advertising campaigns or to tailor services to your needs (we use for this purpose your name and contact details and historic booking details)
e.) to support other administrative purposes (including but not limited to accounting and billing, auditing, credit or other payment card verification, anti-fraud screening (including the use of credit reference agency searches and payment card validation checks), immigration and customs control, safety, security, health, administrative and legal purposes and systems testing, maintenance and development) (we may use any of the data that we collected from you, as appropriate).
3. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
3.1 Your personal data may be shared within the Sky Maxxi SIA. In addition disclosure of your data to other parties may be necessary to ensure the smooth provision of the products, services and information you request.
3.2. We may also disclose your personal data to third parties for the purpose described in this Policy:
– travel agents and other third parties who you book travel or other services through;
– third party service providers whose services you purchased (such as insurance, transfer services) on our website, in our application or via our call center;
– our partners in loyalty schemes that you have joined;
– ground handling companies and airports to provide the service you requested;
– credit card companies, payment service providers to process the payments you initiated on our website, in our application or via our call center;
– third parties running customer surveys on our behalf;
– other third party service providers involved by us for – inter alia – data processing;
– third parties, such as law firms and law courts, in order to enforce or apply any contract with you;
– government authorities or enforcement bodies such as the police and regulatory authorities, upon their request and only as required by the applicable law or to protect our rights or the safety of our customers, staff and assets.
3.3. Travel agents and other third parties. When you purchase any service at our ticketing agent at an airport you hereby expressly consent to the processing of your personal data by the ticketing agent in accordance with this Policy. Please click here to see which legal entity will process your personal data.
3.4. Third party service providers. When you purchase the service of a third party service provider on our website, in our application or via our call center we transfer your personal data to facilitate the purchase.
The data processing of such third parties may also be governed by their own privacy policies. Please review the privacy policies on the website of such third parties directly for more information about their data processing practices. In certain cases, both our and such third party’s terms and conditions and privacy policies shall be accepted to obtain the relevant service.
Furthermore, we also receive information about you from third parties, for instance when you participate in a loyalty program.
For more information about the data transfer to/from third parties, please click here.
3.5. Call center. We engage third party suppliers for the provision of call center services for us. You can find more information about these suppliers here. The call center is processing your personal data in accordance with this Policy. The call is being recorded and may be connected with other reservation data to ensure quality and for possible future complaints handling. Complaints submitted electronically, via post or via email are also archived, and may be connected with other reservation data for possible future complaints handling.
3.6. Border police and immigration authorities. In certain countries, Sky Maxxi SIA is required by law to give border control agencies access to booking and travel information. Therefore, any information we hold about you and your travel arrangements may be disclosed to the customs and immigration authorities of your place of departure or your destination.
In addition, laws in several countries require Sky Maxxi SIA to collect passport and associated information for all passengers prior to travel to or from those countries. When required, Sky Maxxi SIA will provide this information to the relevant customs and immigration authorities.
4. SECURITY
4.1 We take appropriate technical and organizational measures to ensure the protection of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.
4.2 If we transfer data to a country outside the European Union in accordance with this Policy we cannot guarantee that the data will be protected in accordance with EU data protection laws and regulations.
By continuing to use our services and by providing us with any personal data, you expressly consent to such transfers, storage and processing of your personal data outside the country in which you are located and outside the European Economic Area, including to countries where under local law you may have fewer legal rights.
5. MISCELLANEOUS
5.1 If you register on our website, we assume that you are happy for us to process your data given to us during the registration process and you will not have to provide your data again when making further bookings.
5.2 When you make a booking you will be given a confirmation code. This appears in the confirmation email you receive after the booking. We advise that your confirmation code should be kept confidential at all times. Disclosure of your confirmation code to others may allow them to access your booking details and itinerary through our system.
5.3 Your personal data and the contracts concluded by and between you and Sky Maxxi SIA are kept in our reservation system.
5.4 As regards any data processing falling under the scope of the Info Act, you are entitled to the following rights and remedies:
You have the right to request information on the data processing, and to request the rectification, erasure or blocking of the personal data. If it is allowed under the applicable law, you can also object to the data processing. In the unexpected case when the rights related to the personal data are breached, you may e-mail us at: info@skymaxxi.com.
5.5 If we change this Privacy Policy, we will publish the updated version of it on our website, skymaxxi.com.
6.6 We process your personal data for the time required for the performance of the above purposes or for the period of limitation prescribed in the relevant laws.
6.7 The skymaxxi.com website provides links to other websites for your convenience and information. Please be aware that these sites may be owned and run by other companies and organizations and have different security and privacy policies. Sky Maxxi SIA has no control over and takes no responsibility for any information, material, products or services contained on or accessible through those websites.
6.8 This Privacy Policy is effective from 25 February 2016.