Protecting personal data is a core part of how we run our business. This Privacy Statement, and the way we work day to day, aim to ensure that personal data is handled lawfully and appropriately and that its confidentiality, integrity and availability are preserved.
This Privacy Statement covers www.flyclaim.eu and every other FlyClaim domain. These domains are owned and run by Sky Services and Partners S.R.L. (IDNO 1026023133791), which trades under the name FlyClaim. Throughout this Privacy Statement, “FlyClaim”, “we”, “us” and “our” mean the entire group of companies or any single company within it, depending on the context.
This Privacy Statement is our complete online privacy policy for everything we do. It sets out which kinds of information we collect and how we use, share and protect the information you give us. It also explains the options you have to control how your personal data is used, to access it and to have it corrected.
We process your personal data in a lawful manner. In providing our services, we are bound by the laws on data privacy and data protection that apply to us (together, the “Data Protection Laws”). Depending on the situation, the relevant Data Protection Laws may be the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados or LGPD) and any other laws and regulations in force that give effect to Data Protection Laws.
Because it decides why and how personal data is processed, Sky Services and Partners S.R.L., trading as FlyClaim, acts as the data controller.
Key terms
Unless this Privacy Statement gives a term its own definition, each capitalised term used here carries the meaning given to it in our Terms and Conditions.
What counts as personal data
Personal data is any information that relates to a natural person who is identified or who can be identified. It covers every kind of information that points to a person, whether directly or indirectly — for example a name, a date of birth, a postal address, an email address or a telephone number.
Why we process data and on what legal basis
The sections below set out how far our data processing extends, what it is for and which legal bases support it. As a general rule, the legal bases we may rely on when processing data are these:
Our data protection principles
This Privacy Statement rests on the data protection principles listed below:
- Personal data is processed lawfully, fairly and in a transparent manner.
- Personal data is collected only for purposes that are specified, explicit and legitimate, and is not processed later in any way that conflicts with those purposes.
- The personal data collected is adequate and relevant, and is restricted to what the purpose of the processing actually requires.
- Personal data is kept accurate and, where needed, up to date.
- We take every reasonable step to make sure that personal data found to be inaccurate, having regard to the purposes of the processing, is corrected or deleted without delay.
- Personal data is held in a form that allows a person to be identified only for as long as the purpose of the processing requires.
- Personal data is treated as confidential in every case and is stored with an appropriate level of security.
- Personal data is passed to third parties only where that transfer is needed for FlyClaim to provide the services set out in the agreement.
- You may ask for access to your personal data, for its rectification or erasure, or for processing to be restricted; you may object to processing; and you have the right to data portability.
How we collect and use personal data
When you want to use our services and send us information, we may ask you for personal data so that we can run and improve our business and our services. You can give us personal data through our website, by email, through other electronic or software tools we support, by post or by telephone. All personal data is collected as the applicable Data Protection Laws require. Personal data is processed only to the extent required by a purpose that is specified, explicit and legitimate, or as far as a purpose imposed by law in the countries where we operate requires.
The personal data we mainly collect consists of names, dates of birth, postal and email addresses, telephone numbers, passports or ID documents, and national identification numbers. We use it to deliver our Eligibility Service, our Information Service and our Compensation Service, as well as any other Services provided under the agreement. Delivering these is FlyClaim’s core business activity.
We also collect personal data for further purposes, namely statistics; administration and communication; management of IT and security; physical security; authentication and authorisation systems; support systems; cooperation on internal projects; and our organisational teams and activities.
We buy flight data from third parties, such as details of flights that were delayed or cancelled within a particular period. Although this information is not personal data, we combine it with personal data. The Eligibility Service serves only to tell you how likely it is that you have an eligible Claim. For Eligible Claims, our Compensation Service is available on request.
If you give us personal data belonging to Fellow Passengers, it is your responsibility to make sure that each Fellow Passenger has expressly consented to their personal data being shared with our organisation, as data protection rules require. You must also give the Fellow Passengers access to our privacy policy, so that they are fully aware of how we process their data.
We may request further information or documents concerning Fellow Passengers. Should you or the Fellow Passenger not supply that information and/or those documents, we cannot offer our services to the Fellow Passenger in question. In that case we will have to delete that Fellow Passenger’s personal data from our databases and will be unable to provide our Services to them.
If you get in touch with us, for example through the website, by email or by phone, we process the data you give us (such as names, email addresses and phone numbers) so that we can reply to your questions. We rely on our legitimate interest in answering the enquiries sent to us as the legal basis for this processing. Once storing the data collected in this way is no longer needed, we delete it; where statutory retention obligations apply, we restrict its processing instead.
We use AWS Bedrock and other artificial intelligence (AI) tools to analyse the documents you submit, so that we can improve our services and sort documents efficiently. We carry out this processing on the basis of our legitimate interest in optimising our service and/or, where relevant, your consent.
If you begin a claim application without finishing it, or if we still need documents or a signature to pursue your Claim, we may email you service reminders (and, if you have given us a phone number and chosen the relevant preferences, send them by SMS/WhatsApp). Such messages are transactional: they are needed to carry out pre-contractual steps and to provide the Services you asked for.
Service messages and how we handle Claims
To run your Claim from start to finish, we process your personal data because it is contractually necessary and because we have a legitimate interest in delivering an effective Compensation Service (Art. 6(1)(b) and Art. 6(1)(f) GDPR). This covers checking eligibility, preparing Forms (for example a power of attorney or an assignment), requesting and keeping supporting documents, contacting you about steps you have not yet completed, and keeping you informed of your claim’s status.
You acknowledge that any communication reasonably required for processing your Claim may be sent to you by FlyClaim, such as reminders to supply flight details, to sign authority documents, to upload identity documents or boarding passes, confirm your payment details, and reply to requests from the Airline or from authorities.
We may also pass your personal data and documents relating to your Claim to Airlines and their claims handlers, to courts, Lawyers and national enforcement bodies, and to payment processors, storage providers and identity-verification providers, but only as far as necessary to submit, pursue or settle your Claim, or to pay it out. Where the law requires it, these transfers are protected by appropriate safeguards.
The service messages covered by this section are separate from marketing. Service messages needed to handle your Claim may still reach you after you have unsubscribed from marketing.
How personal data is used
Personal data is used for the purpose for which we collected it and is not kept longer than that purpose requires. We may hold your information while your account remains active, or for as long as we need it to provide services, to meet our legal obligations or to serve any of the purposes described above. Only staff of FlyClaim and of the subsidiaries and affiliates it controls may access personal data, and only if they are duly authorised under a binding corporate agreement with FlyClaim and have a clear business reason to need that data.
Automation and profiling
FlyClaim does not make use of automated processing within the meaning of Article 22 p. 1 GDPR, and we do not use your personal data for profiling. Your data will be used for such purposes only if we expressly tell you otherwise, and then only with your separate consent.
We may, however, automate some processes using our own technology and technology supplied by our partners. Doing so lets us provide you with quicker, higher-quality Services.
To make sure these automated processes do not affect you negatively or unfairly, our teams check their accuracy on a regular basis. This applies both to existing processes and to those introduced in the future.
You can send any questions about your data or about automated processes to our Data Protection Officer (“DPO”) at support@flyclaim.eu.
Transfers of data beyond the European Economic Area (EEA)
Where your data goes to a service provider or any other third party based outside the EEA, we protect it through several mechanisms:
Security measures for processing
We take the protection of your personal data seriously. We process personal data securely, and we apply and maintain technical and organizational measures that meet appropriate, generally accepted standards in order to protect personal data from being destroyed accidentally or unlawfully, lost accidentally, altered, or disclosed or accessed without authorization — particularly where processing involves transmitting data over a network — as well as against any other unlawful form of processing. Any questions about how personal data is kept secure can be sent to the DPO at support@flyclaim.eu
Your rights regarding your data
At any time, you may request access to your personal data, its rectification or erasure, or the restriction of its processing, and you may object to processing; you are also entitled to withdraw any consent you have given and have the right to data portability.
Please let us know about any changes or inaccuracies so that we can keep personal data up to date.
If you would like to see and/or change personal data, find out how long we intend to keep personal data, raise other questions about access to personal data, or ask us to tell you whether we hold any of your personal data or process it for a third party, please contact the DPO at support@flyclaim.eu. You will receive our reply within a reasonable period.
You are also entitled to lodge a complaint about how we process your personal data with a data protection supervisory authority. You can find the contact details for each data protection supervisory authority at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
How long we keep data
Except where this Privacy Statement expressly provides otherwise, we delete the data we store as soon as it is no longer needed for its intended purpose, provided that no legal retention obligations stand in the way of deletion. If data is not deleted because it is needed for other, legally permissible purposes, its processing is restricted — meaning the data is blocked and not processed for any other purpose. This is the case, for example, for data that must be kept for reasons of commercial or tax law.
Job applications
Open roles are advertised on our website, on pages connected to it, or on external websites. To manage incoming applications, we rely on a recruitment tool supplied by a third party.
If you apply for a role at FlyClaim, FlyClaim is the party that processes and controls your personal data. Applicant data is shared with the HR staff responsible for the vacancy, with the data processors who support our recruiting, and with any other employees taking part in the application process.
Please leave details of your religious beliefs, political opinions and other similarly sensitive matters out of your CV and cover letter, as an application does not need them. Should an applicant include such details anyway, we have no way of stopping them from being processed together with the CV or cover letter, and that processing then also rests on the applicant’s consent.
Applications are kept no longer than needed and are not disclosed to any third party. Where an applicant has given consent, we also process their data for subsequent application procedures.
With your explicit consent, an AI notetaker (for example Metaview) is used during interviews so that our team can concentrate on the discussion. This means the names, email addresses, voice and video of both candidates and employees are processed. You may decline this tool, and doing so has no effect on your application.
To exercise your rights of access, rectification, erasure, restriction of processing, objection to processing or data portability, write to the DPO at support@flyclaim.eu
Marketing messages and ad preferences
Once you have given your consent, we may send you marketing messages by email, WhatsApp, SMS (Short Message Service) or RSC (Rich Communication Services). That consent must be unambiguous, informed, specific and freely given, which is the case when you opt in, meaning you actively agree to receive marketing messages.
If you consent, we also send interested readers a free newsletter. Information you give when signing up is used solely to deliver the newsletter. By subscribing, you consent to this processing (Art. 6 para. 1 s. 1 lit. a GDPR). On the strength of that consent, we may also track how often our newsletters are opened and clicked, so we can judge how relevant they are to readers.
Relying on our legitimate interest, we may also tell existing customers about our offers by email or through other channels, unless they have objected.
You may object at any time, free of charge and simply by asking, to the use of your personal data for direct marketing, without giving any particular reason. To stop marketing messages, use our unsubscribe page, click the “Unsubscribe” link in any email we send you, or write to support@flyclaim.eu. Once you object, we stop processing your personal data for direct marketing.
These messages carry content we believe may interest you, for example the newest information about our products and services.
A third-party partner helps us show adverts on our website or run our advertising on other websites, social media platforms among them. This partner may rely on cookies or similar technologies to serve you ads that reflect your browsing activity and interests. You are free to decline interest-based advertising; note that generic ads will still be shown to you.
We rely on Google services to run and enhance what we offer, including personalised advertising shown to you. Details of how Google handles your personal data for that purpose are set out in Google’s Business Data Responsibility.
Customer feedback surveys
On the basis of our legitimate interest, we occasionally ask customers to take part in surveys so that we can understand them and what they want more clearly. We collect whatever data the survey in question asks for and erase it once the survey results have been evaluated.
Preventing fraud
Once you have uploaded your bank details and/or other required documents, we check your identity and other details against a valid identity document as part of our KYC (Know Your Customer) process.
This involves taking photos and, where needed, video recordings of your identity document, with close attention paid to its integrity, authenticity and security features.
In particular, we process the following personal data internally:
- General personal data: given name and surname, gender, date of birth, personal identification number or code, citizenship and nationality, location (street, city, postcode, country);
- Identity document data: document type, issuing country, number, expiry date, security features, MRZ (Machine Readable Zone), and any information stored in the document’s barcode (this depends on the document);
- Facial image data: pictures of the face (selfies included), a photograph or scan of the face shown on the identity document, video and audio recordings;
- Biometric data: features of the face;
- Contact details: address, phone number, email address, IP address;
- Technical data: date and time of, and activity in, the services; domain name and IP address; attributes of the software and hardware (type and name of camera); general location of the individual’s device (e.g., city, country);
- A unique identifier (Applicant ID), generated only to link the individual with their personal data in the information system;
- Further personal data supplied by the individuals themselves.
During identity verification we also check your information, payment and bank account details included, against sanctions lists, watchlists and Politically Exposed Persons (PEP) lists.
FlyClaim carries out this processing on the basis of its legitimate interest in using identity verification to prevent fraud in connection with our services and to protect our customers against fraudulent acts. Biometric data is processed on the basis of your consent, which you may withdraw at any time with effect for the future, for example by writing to support@flyclaim.eu.
Who is responsible
Our Legal Team owns this Privacy Statement and bears overall responsibility for making sure it is complied with. Day to day, the DPO checks that the Privacy Statement is followed and is involved in every matter concerning the protection of personal data.
We are responsible for, and able at any time to show, our compliance both with the Data Protection Laws and with the principles this Privacy Statement lays down. We maintain records of all processing activities for which we are responsible, containing whatever information the Data Protection Laws require, and where applicable provide them to the supervisory authority upon request.
Questions about this Privacy Statement may be sent to the DPO at support@flyclaim.eu
Complaints
You are entitled to complain about how we process your personal data. The DPO deals with all queries and complaints promptly, following our internal procedures. Please send complaints to the DPO at support@flyclaim.eu.
Art. 77 GDPR additionally entitles you to bring a complaint before a data protection supervisory authority, especially in the Member State of the EU/EEA where you have your habitual residence or place of work, or in the one where the alleged infringement occurred. A list of every EU/EEA supervisory authority is published by the European Data Protection Board: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
Updates to this Privacy Statement
We may revise this Privacy Statement from time to time, for instance when the relevant legislation changes or our corporate structure is modified. Before any material change takes effect, we will tell you about it by email or through a notice on the website. Please check this page regularly to stay informed about how we handle privacy.
Contact details
Sky Services and Partners S.R.L. t/a FlyClaim
bd. Mircea cel Bătrân, nr. 11, bl. 4, apt. 126, MD-2044, mun. Chișinău, Republic of Moldova
Email: support@flyclaim.eu
Phone: +37378810245
Social media platforms and your data
We run profiles on social networks to introduce our organisation and services to their users. The companies operating these networks routinely use their users’ data for advertising. Among other things, they build profiles from users’ online behaviour and use them, for instance, to display ads matching users’ interests both on the networks and elsewhere online. For this purpose, the network operators place cookies on users’ computers that record how those users behave. Operators may also link this information to other data; that possibility cannot be ruled out. The privacy notices of each operator, listed below, give further details and explain how users can object to processing by those operators. The operators, or their servers, may also be based outside the EU, in which case data is processed there. This can create risks for users, for example because their rights are harder to enforce or because government agencies may access the data.
Where users of these networks contact us through our profiles, we process the information they send us in order to answer their enquiries, relying on our legitimate interest.
FlyClaim has profiles on the social media platforms below. Each platform’s own privacy policy explains in detail how it handles data and protects privacy: