Flight Reclaim is registered under the Data Protection Act 1998 (the, “DPA”) and the Information Commissioner’s Office (the, “ICO”) under registration number ZA132108 and operates in accordance with these laws, as well as The Privacy and Electronic Communications (EC Directive) Regulations 2003 (the, “Directive”), and the General Data Protection Regulation 2018 (the, “GDPR”).
This policy sets out the basis on which any personal data Flight Reclaim collects from you, or that you provide to Flight Reclaim, will be processed by. Please read the following carefully to understand Flight Reclaim practices regarding your personal data and how we will treat it.
What is in a cookie?
A cookie is a simple unique text file stored on your computer or mobile device by a website server. Only that website’s service is able to retrieve or read the contents of the cookie. It will contain some information such as the URL of the website, a unique identifier and some digits and numbers.
What to do if you don’t want cookies to be set
Some people find the concept of cookies intrusive. If you prefer, it is possible to block cookies or even to delete cookies that have already been set; but you need to be aware that you might negatively affect the manner in which this website responds to you and may prevent you from using certain parts of the site.
Should you wish to control the manner in which Cookies are handled on your computer, we suggest consulting the Help section of your browser.
We use Google Analytics to analyse how website visitors interact with our website. We use this information to identify trends and help us improve our website. The cookies collect information in an anonymous form about visitors to the site, including what pages they visited, how long they stay on each page for and the number of clicks.
Client information collected by Us
- The information collected by our website may include:
- Any personal details you enter and submit, such as name, address, email address, etc.
- Your IP address, referrer, web pages that you visit and any other data normally stored in website logs.
- Session information stored in cookies that are used to ensure accurate data is extracted from our systems. These cookies do not include any personal data.
- Under no circumstances will we hold any form of banking or financial details in our database.
- In order to improve our service telephone calls may be recorded and/or monitored.
How we handle the collected client information
Any information we collect will be used in accordance with applicable laws for the following purposes:
- To comply with legal requirements such as the General Data Protection Regulation.
- In certain cases, we may use your email address to send you information about our products and services. In such a case, you will be offered the option to opt in/out.
- We may use personal information to provide our service.
- We may use personal information for auditing, research and analysis to operate and improve our technologies and services.
- We may share aggregated non-personal information with third parties.
- We may share information with third parties in limited circumstances, including when complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network and services.
- When you send email or other communication to us, we may retain those communications in order to process your enquiries, respond to your requests and improve our services.
- All your data you hold with us is backed up at separate physical premises with technical and organisational measures equal to the premises where the original data is held. This is to ensure that your data is not lost or destroyed should the original be destroyed without your instructions.
Except as described herein, we do NOT disclose your information to nor share your information with third parties.
General Data Protection Regulation
We will do our utmost to ensure our requirements pursuant to the GDPR (including any statutory modification or re-enactment) are fully complied with at all times. As is necessary for the purposes of legitimate interests, we will use your data (Data) in the progression of your matter and will act as a “data controller” (for the purposes of GDPR) of your data. Specifically we will use your data for the purpose of progressing your claim including through Court, Counsel, Arbitrators, National Enforcement Bodies and Solicitor Agents and any other search in the progression of your matter.
We comply at all times with our obligations under GDPR, including but not limited to, taking appropriate technical and organisational measures against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal or special personal data. When considering what measures are appropriate, we shall have regard to the state of good practice, technical development and the cost of implementing any measures to ensure a level of security appropriate to the harm that might result from such unauthorised or unlawful processing or accidental loss or destruction, and to the nature of the data to be protected.
We will do its utmost to store your data within a Member State of the European Union. However some of your data may be transmitted to a country not providing adequate protection within the meaning of Directive 95/46/EC. If data does leave the EU, we will do its utmost to ensure equivalent levels of protection and security for your data. Examples of when and how data under our control may travel outside of the EU is if your data is stored within Google Web Service hosted environment.
You have the right to access any information we hold about you in a common machine readable format free of charge, unless your request is excessive or repetitive. We will process your request without undue delay.
You have the right to ensure your data is rectified and/or erased as per the GDPR. To inform us of your desire to implement either of these rights, please contact us using the details below. We will make sure we comply with your request with the relevant time period allowed by law, whilst not contravening any other Regulatory body under which they operate.
Flight Reclaim endorses and makes concerted efforts to comply with the rights of subjects as identified in GDPR, including:
4.1 the right to be informed;
4.2 the right of access;
4.3 the right to rectification
4.4 the right to erasure
4.5 the right to restrict processing
4.6 the right to data portability
4.7 the right to object
4.8 rights in relation to automated decision making and profiling
Individuals wishing to invoke any of their above rights should do so using the contact details in the Key Contact Details section below.
Information security and communication from us to clients
We maintain a strict “no-spam” policy. Your email address will not be sold to a third party.
We may automatically add your email address to our mailing list to which we may send emails containing news, announcements, new feature information and other business related information. You can at any time unsubscribe to this mailing list by selecting the unsubscribe option within the email.
Because some communication with our clients is necessary to adequately provide our services, clients cannot opt-out of receiving administrative emails related to their matters. Such email may include confirmation of a registration or purchase, account status emails, or communication during the process.
We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorised access to systems where we store personal data.
We restrict access to personal information to our employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
When we receive formal written complaints posted using our contact page, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between us and an individual.
Telephone Preference Service (TPS)
If you no longer wish to receive information directly from Flight Reclaim, then you are able to simply withdraw your consent. This can be done by emailing email@example.com with the email subject header “Withdrawing Consent”.
Under GDPR you also now have the right to be forgotten, this consists of Flight Reclaim ceasing contact with you and deleting your information from their records. This can be done by emailing firstname.lastname@example.org with the email subject header “Right To Be Forgotten”.
If you believe we have mistreated your information/data and wish to lodge a complaint you can do it in the following ways: You can register a complaint directly with us by email via email@example.com with the email subject header “Complaint”. We will respond to your inquiry within 48 hours. You can register a complaint directly with the ICO via following this guide https://ico.org.uk/concerns.
Key Contact Details
Registered Data Protection Officer: Omid Azizi-Torkanpour contactable via firstname.lastname@example.org with the subject header “Data Protection Officer”