1. Definition and nature of personal data
The following terms and expressions, when used with capital initials, have the meaning assigned to them in the General Conditions of Use of the Flywallet Application and it’s Services.
When you use the https://flywallet.io site (hereinafter: the "Site") and the Flywallet application (hereinafter, the "Application"), we may ask you to provide us with personal data about you in order to use the services offered by Flywallet.
In the context of this charter, the term "personal data" designates all data which makes it possible to identify an individual, which corresponds in particular to:
- your passport number, date of issue, expiration date, nationality, date of birth, place of birth and country of residence (when you wish to go abroad);
- to your surname, first names, pseudonym, postal and e-mail addresses, telephone numbers, data relating to your transactions on the Site / Application, the history of your flight searches, the last 4 numbers credit card, geolocation data only for the purpose of allowing us to offer you flights from the nearest airport and any other information you choose to communicate to us about yourself.
2. Purpose of this charter
The purpose of this charter is to inform you about the means we use to collect your personal data, in the strictest respect of your rights.
We indicate to you on this subject that we comply, in the collection and management of your personal data, with law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, in its current version (hereinafter: the “Data Protection Act”), as well as regulation (EU) 2016/679 of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and to the free circulation of this data (hereinafter: the “GDPR”).
3. Identity of the data collection manager
The person responsible for collecting your personal data is Flywallet, a Delaware corporation (hereinafter: "We").
4. Collection of personal data
The legal basis for our collection of your personal data is as follows:
(i) The legitimate interest when you voluntarily provide us with personal data during your visit to our Site / Application, the data then being collected to allow us to better respond to your requests for information about our Services;
(ii) Your consent regarding social media cookies, advertising cookies and Google Analytics cookies referred to in Article 10 "Cookies".
(iii) this collection is necessary in order to execute the contract concluded when you use our Services on our Site / Application.
(iv) the processing of your data is necessary to comply with a legal obligation to which we are subject.
Your personal data is collected to fulfill one or more of the following purposes:
(i) Manage your access to the Services accessible on the Site / Application and their use,
(ii) Perform operations relating to customer management concerning contracts, invoices, loyalty programs, monitoring of customer relations,
(iii) Build a file of registered members, users, customers and prospects,
(iv) Send newsletters, solicitations and promotional messages. In the event that you do not wish this, we give you the right to express your refusal on this subject during the collection of your data;
(v) Develop commercial statistics and frequentation of our Services,
(vi) Organize contests, lotteries and all promotional operations excluding online games of chance subject to the approval of the Online Games Regulatory Authority,
(vii) Manage the management of opinions / testimonials from users of the Services,
(viii)Manage unpaid debts and possible disputes regarding the use of our Services,
(ix) Personalize the responses to your requests for information,
(x) Respect our legal and regulatory obligations.
We will inform you, when collecting your personal data, whether certain data must be completed or whether it is optional. Mandatory data is necessary for the operation of the Services. Regarding optional data, you are entirely free to indicate it or not. We also tell you what the consequences are.
5. Recipients of the data collected
The personnel of our company, the services responsible for control (notably the statutory auditor) and our subcontractors will have access to your personal data.
Public bodies may also be recipients of your personal data, exclusively to meet our legal obligations, judicial officers, ministerial officers and bodies responsible for collecting debts.
6. Transfer of personal data
Your personal data will not be transferred, rented or exchanged for the benefit of third parties.
7. Duration of storage of personal data
(i) Concerning the data relating to the management of customers and prospects:
Your personal data is kept for the period strictly necessary for the management of our commercial relationship with you.
Regarding any prospecting operations that may be intended for you, your data may be kept for a period of 3 (three) years from the end of the commercial relationship.
The data used to establish proof of a right or a contract, which must be kept for compliance with a legal obligation, will be kept for the period provided for by the law in force.
Personal data relating to a prospect, who is not a client, may be kept for a period of 3 (three) years from their collection or the last contact from the prospect.
At the end of this period of 3 (three) years, we can contact you to find out if you wish to continue receiving commercial requests.
(ii) Regarding identity documents:
In the event of the exercise of the right of access or rectification, the data relating to the identity documents may be kept for the period provided for in article 9 of the Code of Criminal Procedure, i.e. 1 (one) year. In the event of the exercise of the right of opposition, this data may be archived for a period of 3 (three) years.
(iii) Regarding data relating to bank cards:
Financial transactions relating to the payment of purchases and fees via the Site / Application are entrusted to Mangopay as a payment service provider who ensures their smooth running and security.
For the purposes of the services, this payment service provider may be required to be the recipient of your personal data relating to your bank card numbers, which it collects and stores in our name and on our behalf.
We do not have access to this data.
(iv) Regarding the management of opposition lists to receive prospecting:
The information allowing you to take into account your right to object is kept for at least 3 (three) years from the exercise of the right to object.
(v) Regarding cookies:
The shelf life of cookies referred to in Article 10 "Cookies" is 13 (thirteen) months.
We inform you to take all necessary precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and in particular, to prevent it from being distorted, damaged or that unauthorized third parties have access to it. . We will also use secure payment systems that comply with the state of the art and applicable regulations.
We inform you that your data is kept and stored, during the entire period of their conservation on the servers of the company Amazon Web Services, located in the United States.
The company Amazon Web Services has adhered to the “Privacy Shield”, which was deemed to offer an adequate level of protection by a decision of the European Commission of July 12, 2016 (Decision). To find out more about the protection offered by the “Privacy Shield”, you can consult its website.
Cookies are text files, often encrypted, stored in your browser / smartphone. They are created when a user's browser loads a given website / when your smartphone loads the Application: the site / Application sends information to the browser / to your smartphone, which then creates a text file. Each time the user returns to the same site / the same application, the browser / your smartphone retrieves this file and sends it to the website server.
We can distinguish different types of cookies, which do not have the same purposes:
- Technical cookies are used throughout your browsing, in order to facilitate it and to perform certain functions. For example, a technical cookie can be used to store the responses entered in a form or the user's preferences with regard to the language or presentation of a website, when such options are available.
We use technical cookies.
- Social network cookies can be created by social platforms to allow website designers to share the content of their site on these platforms. These cookies can in particular be used by social platforms to track the navigation of Internet users on the website concerned / the Application concerned, whether or not they use these cookies.
We also invite you to consult the privacy policies of the social platforms that are the source of these cookies, to learn about the purposes for using the navigation information they may collect through these cookies and the terms and conditions. exercise your rights with these platforms.
- Advertising cookies can be created not only by the website on which the user is browsing / the application on which you are browsing, but also by other websites / applications serving advertisements, announcements, widgets or other elements on the page. displayed. These cookies can in particular be used to carry out targeted advertising, that is to say advertising determined according to the navigation of the user.
We do not use advertising cookies. If we decide to do so later, we will ask for your consent before submitting them. You will also have the opportunity to inform yourself about their nature, to accept or refuse them.
- We use Google Analytics, which is a statistical audience analysis tool that generates a cookie to measure the number of visits to the Site / Application, the number of page views and visitor activity. Your IP address is also collected to determine the city from which you are connecting. This cookie is only placed if you give your consent. You can accept or refuse it.
- We also use geolocation cookies in order to allow us to offer you flights via the Site and the Application from the nearest airport. This cookie is only placed if you give your consent. You can accept or refuse it.
We remind you for all practical purposes that you can oppose the deposit of cookies by configuring your browser / smartphone. Such a refusal could however prevent the proper functioning of the Site / Application.
11. Access to your personal data
In accordance with the law n ° 78-17 of January 6, 1978 relating to data processing, the files and freedoms, and GDPR, you have the right to obtain the communication and, if necessary, the correction or the erasure data concerning you, through online access to your file. You can also contact: email@example.com.
Persons whose data is collected on the basis of our legitimate interest, as mentioned in article 4 "Collection of personal data", are reminded that they can object to the processing of data concerning them at any time. . However, we may be required to continue the processing if there are legitimate reasons for the processing which prevail over your rights and freedoms or if the processing is necessary to establish, exercise or defend our legal rights.
12. Right to define guidelines for the processing of data after your death
You have the right to define directives relating to the storage, erasure and communication of your personal data after your death.
These directives can be general, that is to say that they relate to all the personal data which concern you. In this case, they must be registered with a trusted digital third party certified by the CNIL.
The directives may also be specific to the data processed by our company. You should then send them to us at the following email address: firstname.lastname@example.org.
By transmitting such directives to us, you expressly give your consent for these directives to be stored, transmitted and executed in the manner provided herein.
You can designate in your directives a person responsible for their execution. This one will then have quality, when you will be deceased, to take cognizance of the said directives and ask us for their implementation. In the absence of a designation, your heirs will have standing to take cognizance of your directives upon your death and to request their implementation.
You can modify or revoke your directives at any time by writing to us using the contact details above.
13. Portability of your personal data
You have a right to the portability of the personal data that you have provided to us, understood as the data that you have declared actively and consciously in the context of accessing and using the services, as well as the data generated by your activity in connection with the use of the services. We remind you that this right does not relate to data collected and processed on any other legal basis than the consent or the execution of the contract binding us.
This right can be exercised free of charge, at any time, and in particular when your account is closed on the Platform, in order to recover and store your personal data.
In this context, we will send you your personal data, by any means deemed useful, in a standard open format commonly used and machine-readable, in accordance with the state of the art.
14. Introduction of a complaint before a supervisory authority
You are also informed that you have the right to lodge a complaint with a competent supervisory authority, (the National Data Protection Commission for France), in the Member State in which your usual residence is located, your place of work or the place where the violation of your rights would have been committed, if you consider that the processing of your personal data object of this charter constitutes a violation of the applicable texts.
This recourse may be exercised without prejudice to any other recourse before an administrative or jurisdictional court. Indeed, you also have the right to an effective administrative or judicial remedy if you consider that the processing of your personal data which is the subject of this charter constitutes a violation of the applicable texts.
15. Limitation of processing
You have the right to obtain the limitation of the processing of your personal data, in the following cases:
- During the verification period that we implement, when you dispute the accuracy of your personal data,
- When the processing of this data is unlawful, and you wish to limit this processing rather than delete your data,
- When we no longer need your personal data, but want to keep it to exercise your rights,
- During the period of verification of legitimate grounds, when you have objected to the processing of your personal data.
We reserve the right, at our sole discretion, to modify this charter at any time, in whole or in part. These changes will come into effect as of the publication of the new charter. Your use of the Site / Application following the entry into force of these modifications will constitute recognition and acceptance of the new charter. Otherwise and if this new charter does not suit you, you will no longer have to access the Site / Application.
17. Policy Update