PRIVACY POLICY
Effective date: January 1st, 2024
1. Introduction
Welcome to the VIPFARES Privacy Policy.

Herein, terms such as "VIPFARES," "we," "our," or "us" refer to VIPFARES. We deeply value your privacy and are committed to protecting your personal information. This policy outlines our practices concerning personally identifiable information or personal data. Its applicability spans across our websites, applications, email, voice calls, text messages, and social media accounts. All the information you are about to read, generally applies to all of these platforms. This single privacy statement applies to any kind of customer information we collect through all of the above platforms or by any other means connected to these platforms. Your use of the Platforms implies agreement with the terms articulated in this policy.
2. Objectives of this Privacy Policy
The primary objective of this privacy policy is to furnish you with insights into how VIPFARES collects and manages your personal information. This encompasses any personal information you furnish through all platforms when making a purchase or subscribing to our newsletter.

It is important that you use this privacy policy in conjunction with any other applicable privacy policy, notice, or fair processing policy we may provide on specific occasions. This ensures a comprehensive understanding of the reasons behind and methods used in processing your personal information. This privacy policy complements other notices and privacy policies and is not intended to override them.
3. Contact Information
VIPFARES LLC registered in Delaware, USA controls the processing of personal data, as described in this Privacy Statement, except where explicitly stated otherwise. If you have any questions about this Privacy Statement, or about our processing of your personal data, please contact our Data Protection Officer:

Full name of legal entity: VIPFARES, LLC
Email address: dataprotection@vipfares.com.
4. Policy Modifications
We regularly review and update our privacy policy, with a minimum frequency of once every 12 months. VIPFARES may introduce minor changes to this Privacy Policy that do not adversely impact your privacy, unless directed otherwise by applicable laws.In the event of significant alterations, VIPFARES will explicitly publish such amendments and the revised policy on our website.

Additionally, we will strive to notify you through email or pop-up windows during your subsequent use of our platforms mentioned above. These amendments shall be effective as of the specified Effective Date. The latest version of the Privacy Policy is available on our website.
5. Data Accuracy
By providing us with your personal information, you affirm the accuracy, completeness, and currency of the information. Moreover, you declare that you possess the necessary authorization to share this information with us. Maintaining the accuracy and currency of personal information we hold about you is crucial. Kindly keep us informed of any changes in your personal information throughout our association.

Thank you for entrusting us with your privacy.
6. Categories of Personal Information Collected
We may gather, utilize, store, and transfer various types of personal information about you, which we have categorized as follows:

Identifiers or Identity Data:
This includes first/middle/last names, aliases, postal addresses, unique personal identifiers (cookies), date of birth, online identifiers (Internet Protocol address), passport/ID data (number, expiry, country of issuance, nationality), or other similar identifiers.

Contact Data:
This includes billing addresses, delivery addresses, email addresses, and telephone numbers.

Commercial Information:
This includes requested price quotes, purchased products or services, or other histories and tendencies related to purchasing or consuming. It also involves Financial Data (bank account and payment card details) and Transaction Data (payment details and other information regarding products and services acquired from us).

Network Activity Information:
This involves Technical Data (login data, browser type and version, browsing history, search history, time zone setting and location, browser plug-in types and versions, operating system, ip addresses and other technological details from devices used to access our platforms). It also includes information on your interaction with our platforms (Usage Data).

Geolocation Data:
This covers country, state, or city information.

Audio and Electronic Information:
This pertains to audio data (e.g., call records) and electronic data (e.g., email threads and chats).

Inferences:
This includes conclusions drawn from collected personal information, such as Profile Data (preferences, characteristics, psychological trends, behavior, attitudes, intelligence, feedback, and survey responses) and Marketing Data (preferences in receiving marketing, communication preferences).

Additionally, we collect, use, and share Aggregated Data, which refers to statistical or demographic information for various purposes. Although derived from your personal information, Aggregated Data is not legally considered as personal information since it does not directly or indirectly disclose your identity. However, if we combine Aggregated Data with your personal information, treating the combined data as personal information, it will be handled in accordance with this privacy policy.
7. Customer Support
Should you opt to contact our customer support services, we will collect any inquiries, complaints, or other information submitted to our support team.

We do not gather any Special Categories of personal information, such as details about religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, or genetic and biometric data. Furthermore, we do not collect information about criminal convictions and offenses.
8. Children
VIPFARES does not knowingly obtain personal information from minors, unless the minor is one of our travelers. If we discover that a minor is attempting to submit personal information, we will promptly remove this information from our records. If you are a parent/legal guardian of a minor who has provided us with personal information, kindly contact us so we can proceed with its deletion.
9. If you do not provide personal information:
In cases where the collection of personal information is mandated by law or stipulated in a contract, and you fail to furnish the required personal information upon request, we may be unable to fulfill the contract we have with you or are attempting to establish (for instance, providing goods or services). Consequently, we may need to cancel a product or service associated with you, and we will inform you promptly if such a situation arises.
10. How your personal information is collected:
Various methods are employed to collect personal information from and about you, which include:

Personal Information Provided by You:
We directly collect personal information from you through channels like live chat, online forms, or voice calls/messenger. Any contact details (emails, phones, etc.) provided during interactions will be considered your personal contacts and stored in your profile for future communications, unless expressly instructed not to be stored (for one-time communication only). Examples include when you provide personal information while requesting a quote, registering, booking travels, or contacting our customer support. This encompasses details obtained when you:
  • Apply for our products or services.
  • Subscribe to our service or publications.
  • Request marketing materials.
  • Provide feedback or reach out to us.
In cases where a chat is inadvertently closed or removed, experiences interruptions, or faces slow internet connections, we may contact you later via automated phone calls, text messages, or email (if available) to resume the communication initiated during the chat. No purchase is necessary, and you can opt out of further communication by replying to SMS/email or notifying us during a phone call.

Voice Calls:
A key collection method involves voice calls, emphasising our commitment to ensuring you choose the best option. Voice calls offer immediate customer support and the opportunity to highlight additional product features that may not be apparent on the website. Typically, we initiate call-backs based on your request. Unfinished conversations related to current flights (resulting from misunderstandings in live chat, email system errors, poor internet connections, etc.) that necessitate prompt responses may also occur. We do not engage in unwanted telemarketing robocalls or annoying advertising campaigns, and you can opt-out of this communication at any time by contacting us via phone or email.

Passive Collection of Personal Information:
Personal information is also collected passively, including the gathering of information over time and across different websites when you visit the platform. This involves the use of tracking tools such as cookies and beacons. As you interact with our platforms, we automatically collect Network Activity Information about your device, browsing actions, and patterns. The collection is facilitated by using cookies and similar technologies. Refer to our Cookie Policy for additional details. Platform features may utilize your device attributes and settings to determine your physical location (country, state). While we recommend enabling location services on your device for location-based features, VIPFARES lacks control over your device settings.

Personal Information from Service Providers:
We obtain personal information through service providers, which may involve logging in using platforms like Facebook. Additionally, we integrate software from service providers to enhance security and collect user information.

To explore the categories of personal information VIPFARES has collected, disclosed, or sold for a business purpose in the preceding 12 months, you can find the information below:

Collected:
1) Identifiers
2) Contact Data
3) Commercial Information
4) Network Activity Information
5) Inferences
6) Audio and electronic information
7) Geolocation data

Disclosed for a business purpose:
1) Identifiers
2) Contact Data
3) Commercial Information
4) Network Activity Information
5) Inferences
6) Audio and electronic information
7) Geolocation data

Available to certain 3rd parties in order to receive valuable services (Sold):
1) Identifiers
11. Purpose of Utilizing Your Personal Information
We utilize your personal information for the following purposes:

Performance of a Contract:
Your personal information is utilized to perform services and provide products requested from us, such as completing a booking on our platform.

Bookings:
Your personal information is used by us and our travel partners to process bookings and store itinerary information where applicable.

Marketing Activities:
We employ your information for marketing, including sending marketing emails and/or text messages, displaying relevant advertising and recommendations, and administering promotional activities. Opt-out mechanisms are provided.

Legal Purposes:
In specific instances, your information may be used to handle legal disputes, regulatory investigations, compliance, or to enforce terms of service.

Improving our Services:
To provide and enhance our platforms and services, better understand platform users, and safeguard our property to prevent damage.

Regular Customers:
If you have requested a price quote or purchased our services, you are considered a Regular (loyal) Customer, enjoying benefits such as becoming adept at using our services and receiving the most relevant price quotes. According to our policy, we may contact you as a Regular Customer via email/phone saved within previous requests and transactions. Opt-out options are available upon request.

Membership Management:
If you book air tickets or related travel products using our services, we offer you the ability to manage all your booking information within an online account. You have the option to delete the account at any time.

Consent:
Your consent may be relied upon for certain direct marketing purposes, and you can withdraw it at any time by contacting us.

12. Change of Purpose
We will utilize your personal information only for the initially intended purposes, unless we reasonably deem it necessary to use it for an alternative reason that aligns with the original purpose. If you seek an explanation regarding how processing for the new purpose aligns with the original one, please reach out to us.

13. Your Choices
As a customer-centric business, we honor and value your expectations. Consequently, you have the freedom to make announcements and inquiries at any time concerning your privacy concerns. Each marketing email we send includes an opt-out button, allowing you to unsubscribe from such communications at your convenience. However, it's important to note that you cannot unsubscribe from servicing emails and administrative messages.
14. How We Share Your Personal Information
Corporate Affiliates and Change of Control:
We may share your personal information with our corporate affiliates, and in the event of a change of control, new owners would have access to your personal information for the purposes outlined herein.

Service Providers:
Your personal information may be shared with suppliers performing services on our behalf who have agreed in writing to protect and not further disclose your information.

Payment Service Providers and Travel Vendors:
When you book through our platforms, your personal information may be shared with payment service providers, acquirer banks, and the travel vendors you've booked with, such as online travel agencies, hotels, airlines, car rental companies, and travel insurance providers. These third parties will process your personal information as data controllers following their privacy policies.

Business Partners:
We may share your personal information with various business partners for fraud detection, security measures, and online behavioural advertising purposes. Some partners may use this information to offer services or products they believe you may be interested in. Confidentiality and personal information processing terms are established with partners to ensure compliance with high levels of confidentiality and privacy and security standards.

Trips Shared by You:
If you have itineraries as part of our service, you can send or grant access to them to anyone you choose. However, you should only share this information with trusted individuals, as it may contain details allowing modifications to your booking.

Information Shared in Public:
If you provide a review of your trip, you authorize us to publish it on all our platforms under the screen name you provided. Additionally, you allow us to aggregate it with other reviews.

Authorities:
We may disclose personal information if required by law, including court orders, subpoenas, and orders arising from legal processes, or in response to legal actions to enforce our rights and claims.

All the mentioned categories exclude text messaging originator opt-in data and consent, ensuring this information remains confidential and is not shared with any third parties.

14. How We Store and Protect Your Personal Information
Our servers and data centers are situated in the U.S. and Germany, and our service providers may also operate in these and other countries. By providing us with personal information, you consent to the transfer and storage of your data in these countries. It's important to note that these countries may have different and potentially less strict privacy and data protection rules than your own. Consequently, your personal information may be subject to access requests from governments, courts, or law enforcement in those countries, adhering to their respective laws. Within the applicable laws of these countries, we ensure the necessary safeguards to uphold the protection of your personal information, such as obtaining contractual commitments based on the EU model clauses from the recipients.

VIPFARES implements a comprehensive security program to safeguard the personal information stored in our systems from unauthorized access and misuse. Our systems are configured with data encryption and scrambling technologies, as well as industry-standard firewalls. Additionally, Secure Socket Layer (SSL) technology is employed to protect the personal information transmitted over the Internet. Access to personal information is restricted to individuals within our organizations or our service providers, who are authorized to carry out the purposes outlined in this Privacy Policy.

Appropriate security measures are in place to prevent accidental loss, unauthorized access, alteration, or disclosure of your personal information. Access to your personal information is limited to employees, agents, contractors, and other service providers with a business need to know. They process your personal information solely based on our instructions and are bound by a duty of confidentiality. Procedures for handling suspected personal information breaches have been established, and we commit to notifying you and relevant regulators of any breaches as required by law.

15. Retention Periods
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, meeting legal, regulatory, tax, accounting, or reporting requirements. In cases of complaints or the anticipation of litigation related to our relationship with you, we may extend the retention period. The determination of the appropriate retention period considers factors such as the amount, nature, and sensitivity of the personal information, potential risks, purposes for processing, and legal, regulatory, and other requirements.

16. Other Websites
If you navigate to third-party websites or other platforms, VIPFARES's privacy policy does not apply.
17. Requests and Complaints
Under circumstances outlined by applicable law, you have the right to:

  • Request access to your personal information.
  • Request correction of your personal information.
  • Request the deletion of your personal information.
  • Request to opt out from personal information sales/sharing.
Requests can be submitted through the "Do Not Sell/Share My Personal Information" website. Communication should be maintained through the same email (Verified Email) used for requesting a price quote or purchasing air tickets and related services due to the remote nature of our services. Requests made through an authorized agent or third-party service may require additional verification through Verified Email.

We commit not to discriminate against you for exercising any of the rights mentioned herein. However, this right may be limited if differences in prices or quality are reasonably related to the value provided by your personal information. We may provide opt-in consent for financial incentives related to the provision of additional personal information or refraining from requesting deletion.

Fees are not applicable for accessing personal information, but a reasonable fee may be charged for unfounded, repetitive, or excessive requests. We reserve the right to refuse requests in cases of inability to identify and verify or unpaid requested fees.

We may need specific information to confirm your identity, and you may be contacted via email, phone, or messenger to speed up the response. Law limitations might lead to denial of requests involving high-risk data, with proper notification to you unless prohibited by law.

Response to legitimate requests is aimed within one month, with a maximum response time not exceeding 90 days. Complaints/requests can be submitted to the DPO email provided.

18. How VIPFARES Responds to "Do Not Track" Signals
We currently do not have mechanisms in place to respond to "Do Not Track" signals from browsers, as these features are not yet uniform.


VIPFARES COOKIE POLICY

Cookies are small pieces of data sent from the platform and stored on your device (computer, smartphone, etc.) by your web browser while you browse our platforms and sometimes beyond. Without Cookies, it would be impossible to provide you with information and services requested 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 our platforms, you agree to the use of any of the cookies and tracking tools mentioned in this policy, unless you opt 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 VIPFARES
Technical and Strictly Necessary CookiesIn most cases, our Platforms use cookies to ensure the technical feasibility to connect our Platforms with your device and provide services requested by you. This cookie is integrated by default into our Platforms. If you try to block or turn off any of such cookies, you might not receive some essential parts of services requested by you. Examples of such cookies include:

  • User input cookies (session-id), e.g., when you are filling out an online form (ticket buying, making payment, etc.).
  • Authentication cookies used for authenticated services, e.g., when you are logging into your online account within any of the information systems integrated with our Platforms.
  • Security cookies used to detect authentication abuses and prevent malicious attacks.
  • Multimedia content player session cookies, such as flash player cookies.
  • Load balancing session cookies for faster processing of your requests.
  • 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, e.g., language preferences, font size, etc.
  • Managing contractual relationships with partners when you book on partner websites.
  • Helping improve our Platforms offering and for capacity planning purposes.
We or our service providers may set analytics cookies, allowing us to gather aggregated or segmented information about the types of visitors accessing our Platforms and the pages and advertisements they view. In case we collect cookies for statistical purposes, we commit to applying a "functional separation" principle, ensuring the results of the processing have no negative impact on your privacy or lead to decisions against you.

The retention period of Functionality Cookies is usually very short. If longer periods apply, we assess the risk level of such processing to avoid adverse effects on your privacy. Under strict supervision, we may 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 our advertising activities. As part of cross-device tracking, VIPFARES may combine information collected from a particular browser or mobile device with another computer or device linked to the computer or device from which the information was collected.
  • Working with online advertising companies to display targeted advertising on our Platforms and third-party platforms that you visit. This targeting may be based on information collected by us or third-party platforms. It may also be based on your activities or behaviors on our Platforms or those of third parties. We may also obtain information about your browsing history from our business partners.
  • Using Google Analytics to collect demographic and interest data about you (such as age, gender, and interests), including through Google Analytics Demographics and Interest Reporting.
  • Using the information collected about you through Google Analytics 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. When you access a partner site within our mobile applications, we may track your activity on that site.

OPT-OUT FROM COOKIES
Your browser gives you the ability to control cookies. How to do this varies from browser to browser, and 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.

Blocking or deleting cookies or opting out of online behavioral advertising may not stop all tracking described in this policy. Please 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 behavior. You may also opt out of third-party cookies by visiting opt-out websites like aboutads.info or cookiesandyou.com.