Privacy Policy

In this section, we have outlined our Privacy Policy. Please take a moment to acquaint yourself with it, since our services require the collection of Personal Data. In all events, we take extreme care in handling your personal information and we fully comply with the applicable EU and national law.

 

I. Definitions

“Personal Data” means any information relating to a natural person who is identified or can be identified directly or indirectly on the basis of this information which may be comprised of name, identification number, address, location, online identification, device type (desktop or mobile), redacted IP address, etc.

“Privacy Policy” means the present privacy policy of SkyRefund.

“Processing of Personal Data” means any operation or set of operations which may be performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, rendering, alignment or combination, blocking, erasure or destruction.

“SkyRefund” means Sky Refund OOD, a company duly incorporated under Bulgarian law, registered with the Commercial Register to the Registry Agency of the Republic of Bulgaria with Company No 204419250. SkyRefund is a controller of personal data registered in the Bulgarian Commission for Personal Data Protection with an identification number: 427699.

For more definitions of the defined terms in this Privacy Policy, please refer to Section I “Definitions” in our Terms and Conditions.

 

II. Purposes for Processing Your Personal Data

  1. The purposes for processing your name, national identification number, date of birth, nationality, gender, address, place and country of residence, passport details, flight details, banking details, email, device type (desktop or mobile), and redacted IP address are:

    1. to claim and receive on your behalf amounts, due by airlines as a result of the Flight Disruption that you experienced;

    2. to transfer to you the amounts that we received on your behalf;

    3. accountancy purposes;

    4. marketing;

    5. statistics, company organization and administration, and the improvement of SkyRefund’s services.

  2. The purpose for processing your email, password and account information is to maintain your user account.

  3. The purpose for processing data stored in cookies is to make the use of our website much easier for you. For more information, please see our Cookies Policy.

 

III. Legal Basis and Rules for the Processing of Personal Data.

  1. SkyRefund processes Personal Data only in the instances in which the Client has given explicit consent and on the basis of imperative legal obligations.

  2. The processing of Personal Data is carried out in compliance with:

    1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);

    2. Art. 4, paragraph 1, item 2 and 3 of the Bulgarian Protection of Personal Data Act, promulgated in State Gazette, Issue 1 on 4.01.2012, including all subsequent amendments.

  3. The processing of Personal Data is carried out in accordance with the principle of transparency. This is your Data and you have a right to know how and for what reason it is used.

  4. SkyRefund does not collect or process more Personal Data than necessary for the successful delivery of the company’s services and the claiming of your compensation.

  5. The processing of Personal Data is carried out under adequate technical and organizational security conditions. This ensures a very high level of protection against loss, unlawful and unauthorized use of the Data. The access to Personal Data is restricted to SkyRefund’s team and those Third Parties with which sharing of the Data is necessary for the successful claiming of the compensation.

  6. In case the provided Personal Data is incorrect or incomplete, SkyRefund adopts the measures appropriate for the rectification or erasure of the Data whenever such measures are necessary.

  7. In line with the principle of accountability, SkyRefund may always demonstrate compliance with the standard of data protection enshrined in the Privacy Policy and the General Data Protection Regulation.

  8. SkyRefund’s legal team is responsible for the correct application of the Privacy Policy as well as for its compliance with the General Data Protection Regulation.

 

IV. Transfer of Personal Data to Third parties

  1. We may send your Personal Data to airlines, alternative dispute resolution bodies, administrative bodies (such as national enforcement bodies), courts and other entities which SkyRefund works with to perform its obligations under the Agreement with the Client (e.g. lawyers and law firms), or cooperates. For information about the recipients of data stored in cookies, please see our Cookies Policy.

  2. In case we need to send your Personal data to third parties, they can process this information only to the extent of the purposes of the Agreement with the Client and cannot use it for their own marketing or other reasons.

  3. Personal Data may be transferred to third parties only in the instances of:

    1. A valid Agreement with the Client.

    2. An imperative legal obligation or requirement.

    3. A necessity for SkyRefund to protect its rights and take measures against the Client, in case the Client fails to uphold his or her contractual obligations.

  4. SkyRefund uses the services of its IT partners to ensure the appropriate standard in the storage of your Personal Data.

 

V. Transfer of Personal Data to Countries That Are Not Member States of the EU/EEA

  1. Your Personal Data may be transferred to a country that is not part of the European Union (EU) or the European Economic Area (EEA), in case the performance of our services under the Agreement requires contact with any entities mentioned in Article 1, Section IV “Transfer of Personal Data to Third Parties”, located in such a country.

  2. If there is neither an adequacy decision of the European Commission, nor appropriate safeguards for protection of Personal Data with regard to the particular non-EU/EEA country, the possible risks for your Personal Data could be loss, unallowed access, alteration, dissemination or disclosure of Personal Data or any other forms of unlawful processing of Personal Data.

  3. SkyRefund may transfer Personal Data to Third Countries only in case this is necessary (e.g. if the airline, obliged to pay your compensation, is based in a Third Country) for the purposes of the Agreement with the Client.

 

VI. Duration of Personal Data Storage

  1. We will store your Personal Data for a period of 5 years from last time you accessed your account. This is done to ensure that if you decide to use SkyRefund’s services again, you will not be required to create a new account.

  2. If you use the services of skyrefund.com to check whether you are entitled to compensation for a particular flight, the information you have submitted will be stored and processed in anonymized form and may be used only for statistical purposes and for the analysis of SkyRefund’s performance.

  3. We will store firstparty persistent cookies for a period of one year.

 

VII. Other Personal Data Aspects

  1. You provide us with your Personal Data voluntarily. There is no statutory or contractual requirement for providing us with your Personal Data and you are not obliged to provide us with it in any way.

  2. Providing us with your Personal Data is essential for entering into an Agreement and to the performance of our services under the Agreement. It is necessary for the creation of a user account and submitting a claim in our website.

  3. SkyRefund protects your Personal Data using trustworthy security measures and fulfils the applicable legislative requirements.

  4. This Privacy Policy is an integral part of the SkyRefund's Terms and Conditions.

  5. The Client understands that the information, falling under the notion of Personal Data, must be submitted to SkyRefund correctly. The submission of wrongful information constitutes a reason for which SkyRefund may terminate the contract. You may always contact us in case you would like to rectify the submitted information.

  6. SkyRefund uses the services of Google Analytics (property of Google Inc). This means that visiting our website causes Google to store a “cookie” on your computer which contains your IP address as well as information about your behavior on our website. Google stores this information on one of its servers in the USA. Before being sent to the USA, the IP address related to the cookie is anonymized. As a result of this, the information contained in the cookie cannot be identified as belonging to a particular person. There may be extraordinary situations in which Google, acting in accordance with the law, transmits the full IP address without anonymization.

  7. We at SkyRefund use the information collected and analyzed by Google to monitor the activities on our website. You can read more about the way we and Google process this data here. The information in question is not merged with that of other users. If you would prefer Google to not collect this information about you, you may 1) set your browser in a way which does not share this information; or 2) install this plugin. Doing this, however, may restrict you from making full use of SkyRefund’s services.

  8. In alignment with our commitment to uphold your privacy and in adherence to our existing data protection practices, we integrate Google's Enhanced Conversions for Web feature to improve the efficacy of our advertising campaigns while ensuring the confidentiality and security of your personal data. Further details you can find here.

  9. We use Facebook cookies to tailor ad displays for our users. These cookies help us identify users who are already familiar with our services and manage how ads are presented. You can review Meta's privacy policy here.

  10. We utilize Bing cookies to customize ad displays for our users. These cookies assist in identifying users who already use our services and in managing how ads are shown. You can access Microsoft's privacy policy here.

 

VIII. Right of Access, Rectification, Erasure, Restriction, Objection, Portability with Regards to Personal Data and Withdrawal of Consent

  1. You have the right of:

    1. access to your Personal Data,

    2. rectification of your Personal Data,

    3. erasure of your Personal Data,

    4. restriction of Processing of Personal Data,

    5. objection to Processing of Personal Data,

    6. data portability (i.e. the right to receive your Personal Data which you provided us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from SkyRefund),

    7. withdrawal of consent for Processing of Personal Data.

  2. If you wish to exercise any of the abovementioned rights, please contact us at [email protected].

IX. Job Applications

Personal Data, submitted as part of the procedure for a job application, shall be processed only for the purposes of the application and shall be stored for no more than six months after the completion of the procedure. The data may be used during the storage period in case the application procedure is resumed.

 

X. Right to Complaint

  1. You may submit a complaint with SkyRefund in case you believe that your rights as enshrined in the Privacy Policy and the General Data Protection Regulation are violated. Please contact us at the following email address: [email protected].

  2. You have the right to lodge a complaint with a supervisory authority dealing with Personal Data protection at any time.

  3. The supervisory authority of SkyRefund’s activity as a controller of personal data is the Bulgarian Commission for Personal Data Protection, address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Republic of Bulgaria, website: cpdp.bg.