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1. Introduction and Legal Compliance

TTN Eesti OÜ, a legal entity with its registered office at: Jõe tn 3-302, Tallinn, Estonia, 10151 ("Agency") acts as a data controller and respects your privacy and adheres to the applicable Personal data protecting act ("PDPA"), the EU General Data Protection Regulation ("GDPR") and the Electronic communication act ("ECA"). In the following, you are informed which personal data we may gather, for which purpose it may be processed and what cookies may be employed during your visit and use of https://tickets.lt ("Website").

2. Integration with Terms of Service

This Privacy Policy on the protection of personal data by the Agency is an integral part of the Terms of Service, which is accessible by clicking on the following link.

3. Contact Information

In respect of all questions related to the processing, place of storage and use of the personal data, please contact the Customer Care Service or send your requests at the following postal address of the Agency: Tickets Estonia OÜ, Jõe tn 3-302, Tallinn, Estonia, 10151. You may also contact us at [email protected].

4. Definition of Personal Data

What is personal data? Personal data are any data concerning an identified or identifiable natural person, regardless of the form or format in which such data exist (e.g. your name, e-mail address, IP address or the feedback you provide on the Website).

5. Types of Personal Data Collected and Processed

What type of personal data about you we collect and process: We receive and store any information you enter on the Website and/or our mobile application (“App”), provide for the Customer Care Service and provide for the Agency in any other way to the extent necessary to provide the services or to execute the contractual relationship with you, only. Further, personal data might be automatically collected and processed when you are using this Website (e.g. though cookies).

5.1. Data Categories and Processing Activities

4) Payment Information, including:

• Payment card information, such as card number, expiry date, CVV/CVC code, Cardholder name and card name.
• Transaction details, such as the transaction amount, currency, date and time of the transaction, and transaction ID.
• Billing Information, such as customer billing address and contact information, such as email address and phone number, address used for payment confirmation and receipts.
• Authentication Data: Information used to authenticate the cardholder and prevent fraud, which may include 3D Secure data, one-time passwords (OTPs), and other security measures.

5) Travel and Booking Information, including:

• Information regarding the search request and potential booking, such as travel destination, dates, number of travelers, information regarding the travel tickets class (business, economy).
• Booking references or order numbers, ticket details, booking and purchase history, passenger name record, ID or passport information, expiry date, travel itinerary, and other related details and any additional services purchased.

6) Tickets Account Information, including:

• Customer identification and verification information: name / surname, date of birth, gender, citizenship, identity document number, expiry date of identity document.
• Avatar photo (profile picture).
• Contact details, such as email, phone number.
• Frequent flyer card information, such as airlines details and card number.
• Payment card information, such as card number, expiry date, CVV/CVC code, cardholder name and card name.
• Information about the customer's co-passengers, such as name / surname, gender, date of birth, citizenship information, identity document number, expiry date of identity document.
• Any other information that the customer gives us, when communicating with us, such as the details of your booking, any images shared, etc.
• Account information, such as internal ID account number, date of the account registration, account status, preferred account settings, language preferences, logins information and search history.

7) Technical Information, including:

• Technical information, including the internet protocol (IP) address used to connect to the internet, log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device, a unique device identifier (for example, the device's IMEI number, the MAC address of the device's wireless network interface), mobile network information, etc.
• Information about the user visit, including the links that have been clicked on, through and from the site (including date and time), services viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page, codes/tags that are used to identify human languages.

5.2. Sensitive Personal Data

5.3. Social Network Profiles

6. Processing Data of Third Parties

If you create a booking of services and/or pay on behalf of or for the benefit of third parties, the information you provide about those third parties shall be collected and processed by the Agency according to the same terms and conditions that apply to your personal data. By providing such information on third parties, you confirm that such third party is aware of these terms and understands its consequences, as well as gives their unconditional and full consent to the collection and processing of their personal data in accordance with these terms, and agrees that access to such information is possible from your My Account section.

7. Data of Minors

8. Cookies and Automated Data Collection

Cookies are small text files that can be stored on your computer (or any other device) during your first visit to the Website, allowing us to recognize your device during subsequent visits (for example, to remember your login details for the “My Account” section). We primarily use:

• Functional cookies that do not gather personal data;
• Cookies that help us compile aggregate data about user traffic and interaction to offer better Website experiences and personalized advertisements.

More detailed information about our use of cookies and other tracking technologies, may be provided by a separate policy.

9. Google Analytics

10. Social Media Plug-Ins

We use your personal data to:

• Provide the services ordered by you;
• Communicate with you concerning the ordered Services and send you confirmation of your Booking;
• Carry out, process and edit your Booking;
• Provide support and customer service in the use of the Website and the Website services;
• Provide information on existing and future services and offers, in case you have given your consent to this use;
• Improve the performance and quality of the Website;
• Provide answers to your requests and comments;
• Calculate bonuses if you take part in our loyalty programs;
• Encourage you to participate in our surveys and provide feedback;
• Find out the services which may be of interest to you;
• Satisfy your claims;
• Notify you of possible illegal or unlawful acts;
• Solve any issues which may arise under or in respect of the fulfilment of the conditions of the Terms of Service;
• For any other purposes necessary in order to fulfil our contractual obligations about which we will notify you prior to the new processing takes place. If required, we will seek your consent before commencing the new data processing activity.

Payment card data shall be used to confirm the payment for the Booking created by you on the Website. Please note that the provision of services might be impossible if some personal data have not been provided by you.

12. Profiling

Based on your consent we may collate and analyse your consumption and usage behaviour data to perform profiling in order to provide you with offers tailored to your needs, preferences and interests. Offers may include inter alia discounts on services. Offers means offers of the Agency or our business partners. Profiling is any form of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular to analyse or predict aspects concerning economic situation, health, personal preferences, interests, reliability, behaviour, location or movements of you.

13. Legal Basis for Data Processing

14. Data Retention Periods

Personal data will be retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws or regulations. The following retention periods apply:

14.1. Customer Data

The retention periods for customer data are determined based on the purpose of processing and legal requirements:

• Personal Identification Information: Retained for the duration of the customer relationship and for a period of 5 years after the end of the relationship to address any post-relationship queries, legal obligations, or disputes.
• Account Information: Retained for 3 years after account deactivation to allow for account reactivation, unless the customer requests immediate deletion.
• Transaction Data: Retained for 7 years to comply with financial and tax regulations, audit requirements, and to resolve any potential disputes or chargebacks.
• Communication Records: Retained for 2 years after the interaction to improve customer service, address complaints, and support quality assurance processes.
• Usage Data: Retained for 1 year to analyze and improve website functionality, user experience, and for security monitoring purposes.
• Marketing Preferences: Retained until the customer opts out of marketing communications or for 3 years from the last interaction, whichever is shorter.

14.2. Transaction Data, i.e. Data on Financial Transactions:Retained for 7 years to comply with tax and financial reporting regulations.

14.3. Communication Data, including Data re Customer Support Interactions:Retained for 2 years to ensure quality assurance and address customer complaints.

15. Data Storage

We store personal data we collect from you where we have an ongoing legitimate need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements) or for the period of limitation prescribed in the relevant laws. When we have no ongoing legitimate need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. In the case of consent-based data processing, personal data will be processed until the consent is withdrawn.
Customer data is stored in data centers located in Germany. The location of data storage may depend on the region from which the customer accesses our Website or App.

16. Transfer of Your Data

To the extent it is necessary for the proper provision of the services chosen and booked by you, we transfer your personal data to third parties as indicated below because the services could not be provided without such transfer. The Agency may share your personal data with the following entities, as far as it is necessary for the provision of the selected and booked services:

• Operators, e.g. hotel, airline carrier, global distribution systems (GDS), etc. which render the services you booked. All services on this Website, which are offered by third parties, are marked as such on our Website. We do not give your email address to operators, unless it is required for the performance of the services, which you booked through the Agency. They may only use such data for the purposes of rendering booked (or similar) services to you and other purposes, defined by the Operators. However, we recommend that you get acquainted yourself with the data protection policy of each operator, that performs services you booked on this Website. Such Operators may contact you in order to obtain additional information on you, help you with the booking of services, or answer your requests, as long as it is necessary for the provision of their services. Please note that we do not supervise the data protection policy of the Operators. In particular, you hereby give us your consent to transfer your email address and mobile phone number to airline carriers for the purpose of the airline carriers to contact you in an operational disruption;
• Independent operators (service providers), which offer services and act on our behalf, as well as operators, which process payment card data, business analytics, customer service managers, marketing consultants, experts, who distribute questionnaires or other offers and are in charge of prevention of payment fraud. We may as well allow independent operators to use personal data on our behalf if it is required for the proper functioning of our Website or sending of online messages, which may be of interest to you. Independent operators obtain access and collect information, which is required for their work. They are not allowed to share such data or use them for any other or their own purposes. They must, in the same manner as we, to abide by the same data protection terms;
• Business partners, with whom we jointly offer products and services or their products and services we offer on our Website, as far as you have given your consent to this use. You may see whether services, which you requested, belong to a certain independent company. In that case, only the business partner name is given or is accompanied by our name. If you accept their services, there is a possibility that we share your information with such business partner. Please note that we do not supervise the data protection policy of such business partners;
• We may also share your personal data with AIRHELP GERMANY GmbH for the purposes of provision of the AirHelp+ service if you order it. AIRHELP GERMANY GmbH may ask You to provide additional personal information about you. You can find more information on how AIRHELP GERMANY GmbH collects and processes personal data when providing its services here: https://www.airhelp.com/en/privacy/
• We also may share your personal data to affiliates of the Agency or group affiliates, representatives, officers, agents, employees, or partners as far as it is necessary for the provision of ordered services. If applicable, you agree that in order to render the services you are contracting, your personal data will be processed by the Spanish company Amadeus IT Group, S.A..

Further to the above, when you use the website, IntentGlobal, Inc DBA Intent (hereinafter referred to as "Intent") being a partner of Agency is powering online behavioural advertising ("OBA") and other analyses of your unidentifiable data (not the personal data) with the use of third party cookies. More detailed information regarding such operations you may find in the privacy policy of Intent at the following link: https://intentmedia.com/privacy-policy/. At any time you may opt-out of Intent’s third party cookies on the Intent's website available at the following link: http://www.intentmedia.com/opt-out and/or on the general online advertising industry opt-out website, such as, for example, the Network Advertising Initiative website (http://www.networkadvertising.org/), the Digital Advertising Alliance website (http://aboutads.info) or the European Digital Advertising Alliance website (http://www.youronlinechoices.eu).

17. Cross-border Transfer of Data

Therefore, the Agency, where applicable, will take all reasonable measures which in relation to the recipients of your personal data, is necessary to ensure an adequate level of protection as defined by the applicable data protection law, in particular through the application of the Standard Contractual Clauses issued by the European Commission or by a decision of the European Commission which states that the country in which the recipient of the transferred data is provides an adequate level of data protection. You are aware of and agree that based on chosen travel destination, your personal data may be transferred to countries (Operators’ country of registration/operation, airports, etc.), where an adequate level of protection of personal data cannot be ensured. Any cross-border transfer of data shall be limited to those data categories and recipients necessary to comply with the Terms of Service, these provisions, and to provide you with the ordered services.

18. How We Protect Personal Data

Taking into consideration special aspects and threats in the media and on the internet, the Agency cannot guarantee absolute protection of your personal data but will make every effort to protect your personal data at the highest possible level. We abide by the requirements of applicable personal data protection law, requirements for payments processing on the Website (according to market safety standards), and Agency’s internal privacy policies on data protection.

19. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right to Access: You have the right to request access to the personal data we hold about you. This allows you to receive a copy of the personal data we process and verify that we are lawfully processing it.
• Right to Rectification: You have the right to request the correction of any incomplete or inaccurate personal data that we hold about you.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal data when there is no compelling reason for us to continue processing it. This includes situations where the data is no longer necessary for the purposes for which it was collected, you withdraw consent, or you object to the processing and there are no overriding legitimate grounds for processing.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances. This means we can store your data but not further process it. This right applies in cases where you contest the accuracy of the data, the processing is unlawful but you oppose erasure, we no longer need the data but you require it to establish, exercise or defend a legal claim, or you have objected to the processing pending verification of our legitimate grounds.
• Right to Data Portability: You have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, and machine-readable format. This right only applies to data processed by automated means, based on your consent or in the performance of a contract.
• Right to Object to Processing: You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Right to Withdraw Consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

You have the right to (Art. 77 of GDPR) lodge a complaint with your National Data Protection Body, where you believe that your data is being processed in a way that does not comply with the applicable law and regulation. Contact information for these authorities can be accessed at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

20. Amendments

The Agency, at its sole discretion, may from time to time make amendments to this privacy policy. The Agency will publish amendments on the Website. The Agency is not obliged to notify you of any amendments made to these Terms, but to publish them on this Website. The amendments shall be deemed effective as of the date of their publication. You shall check for updates to this Website on your own and on a regular basis. You confirm and agree that your explicit acceptance of these provisions and/or the use of the Website after the date of publication of amendments shall be deemed to be your full and unconditional consent to the amended policy. If you do not accept the modified privacy policy, you shall cease to use the Website.
We review and update our Privacy Policy at least annually.

21. CONTACT INFORMATION

To exercise your rights related to your Personal Data Subject Request, please contact us at [email protected].