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 which is identified or can be identified directly or indirectly by an identification number or by one or more specific factors.

“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 and email 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.
  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. Regulatory Compliance

  1. SkyRefund’s Privacy Policy is in compliance with:
    1. Art. 7, subparagraphs a) and b) of Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the Protection of Individuals with Regard to the Processing of Personal Data and on the Free Movement of Such Data;
    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.


IV. Categories of Recipients of Your Personal Data

  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). For information about the recipients of data stored in cookies, please see our Cookies Policy.


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 “Categories of Recipients of Your Personal Data”, 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.


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


VII. 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


VIII. Right to Complaint

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


IX. Miscellaneous Provisions

  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.