The conditions of online purchase and sale of passenger tickets through the online passenger tickets booking system of JSC aviation company Transaviabaltica (registry code 159973821, located at Karmelava, Kaunas dist. LT-54460, Republic of Lithuania), hereinafter referred to as “Air Carrier“, have been established according to the Consumer Protection Act, the recommendations of Estonian and Lithuanian Chambers of Commerce and Industry, the codes concerning international e-commerce and the Air Carrier’s Conditions of Carriage for Passengers and Baggage. The sale of passenger tickets takes place within the framework of the project Saartelennuliinid and applies only to the flights of the Air Carrier. The sale and purchase service of the passenger tickets is organised and provided by the Air Carrier’s authorized representative and cooperation partner OÜ Razoone (registry code 11010237, located at Rõika 31a, Tallinn 10617, Republic of Estonia), hereinafter referred to as the “Seller “.
The Air Carrier’s application for the online purchase of passenger tickets through the online passenger tickets booking system https://sll.flights/ is managed by the Seller, who is also the provider of the web services.
- What personal information do we collect about you?
- When and why do we collect ‘sensitive personal data’?
- How will we use the information about you?
- What is the legal basis for collecting personal information?
- Who will receive personal information about you?
- How long will we keep your personal information?
- What are your rights?
- Security safeguards
- Other websites
- How to contact us
What personal information do we collect about you?
[AIRLINE] collect, use, disclose and store personal information to provide you with a safe, smooth, efficient and customized travel experience to meet your needs and requirements.
We collect personal information about you whenever you use our services (whether services provided directly by us or by other companies or agents acting on our behalf), when you reserve or book tickets through our systems, when you use our websites, or when you use our call centers.
We collect information about you when you use our contact form, register with us or place an order for products or services or subscribe to our newsletter. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in competitions. Website usage information is collected using cookies.
The types of personal information about you and your travel arrangements that we collect, use, disclose and store are:
- Telephone number
- Date of birth
- Passport no/ID no
- Credit information (always anonymized ‘xxxx xxxx xxxx 1234’)
We need your assistance to ensure that your personal data is current, complete and accurate in order to provide correct booking information or flight itinerary to the appropriate customs and immigration authorities as required by law. Please contact us if any updates are necessary.
When and why do we collect ‘sensitive personal data’?
Certain categories of personal information, such as that about race, ethnicity, religion or health, are considered ‘sensitive personal data’.
Generally, we do not ask for sensitive personal data. However, we may occasionally receive this data, because:
- you have requested specific medical assistance from us and/or an airport operator, such as the provision of wheelchair assistance or oxygen, or
- you have otherwise chosen to provide such information to us (or a third party such as the travel agent through which you made your booking)
In addition, you may have made other requests in regard to your travel arrangements that may imply or suggest that you hold particular religious beliefs or have a particular medical condition e.g. if you request a particular type of special meal this may imply or suggest.
|If you withdraw your consent, it may mean we will not be able to provide all or parts of the services you have requested from us. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Please be aware that in these circumstances you will not be able to cancel or obtain a refund of any fees you have paid.
You may at any time withdraw your consent by contacting: firstname.lastname@example.org
Seller cannot distinguish the age of persons who access and use our websites. If a minor (according to applicable laws) has provided us with personal information without parental or guardian consent, the parent or guardian should contact us to remove the relevant personal information and unsubscribe the minor.
How will we use the information about you?
Generally, Seller collects personal information, either directly from you or from your authorized representatives (i.e. persons whom you have authorized), from third parties (e.g., your travel agent or our service provider), and other channels including our ticketing counters and airport operations, in order to fulfil the following purposes, which include but are not limited to:
- Providing services to you such as processing a transaction (e.g., making a booking), providing technical assistance, assisting you in the transaction, providing flight alert messages, facilitating internet check-in and self-check-in, providing personalized services and responding to your enquiries or requests,
- Providing airport services such as processing information relating to connecting flights, arrangements at airports, and customs and immigration facilities,
- Providing baggage related services such as processing of any baggage related queries, including mishandled or missing baggage claims,
- Providing in-flight catering and other services that best meet your preferences and needs (which we may collect during our interactions with you),
- Marketing and communicating with you in relation to products and services offered by Seller or appointed agents,
- Contacting you for product or customer satisfaction surveys,
- Research and analytics purposes, including market research; and
- Safety, security and legal compliance.
The personal information is further used to provide information, news, and other business-related activities in your service.
What is the legal basis for collecting personal information?
The handling of personal information is in accordance with EU General Data Protection Regulation (GDPR) as stated in REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL and applicable national law.
We only collect necessary information to provide you with the services you request from us, to perform according to a contract or prepare for doing so, to pursue legitimate interests or requirements needed according to law. If we don’t get access to your information we may not be able to provide you with our services.
Who will receive personal information about you?
Transfer of your personal information will only be for specific purposes to provide a seamless customer experience. In order to facilitate your travel arrangements, we will often need to share your personal information to and with our subsidiaries and affiliated companies as well as third parties including other airlines and airport operators, security personnel and travel agents involved in making your travel arrangements. We also share your personal information with third parties needed to deliver services you have requested from us, such as companies that provide airport assistance or transfers.
Seller may also disclose your personal information to law enforcement agencies and government for security, customs and immigration purposes. For example, airlines are required by laws in the United States of America and other countries to provide border control agencies with access to your booking information or flight itinerary. Accordingly, relevant personal information (known as Passenger Name Record (PNR) or Advance Passenger Information (API)) may be disclosed to the appropriate customs, immigration, and/or any other relevant authorities as required by law. Please be informed that the initial recipients of such information may share your PNR and API data with other government agencies or enforcement authorities.
Seller may also use and disclose your personal data to persons who have been validly identified as being you or your authorized representative(s) for the purpose of the relevant transaction or enquiry. In particular, each of the passengers who are grouped under the same Passenger Name Record (PNR) number shall be deemed to be authorized representatives of each of the other passengers under the same PNR number, for the purposes of disclosure identified in this policy, regardless of the number of persons within each group.
We share your personal information with World Ticket and other technical service providers, who are providing and hosting our ticket system. The hosting is provided Softlayer (Europe/USA/China) Itadel (Denmark) [http://www.softlayer.com/].
How long will we keep your personal information?
We only keep your personal data as long as it is necessary to fulfil the purpose for which it was collected e.g. to fulfill the obligations to deliver your travel services, the legal or business purposes of Seller, or as required by relevant laws. We will as a general rule, delete data after 5 years, unless there are specific reasons for keeping them for a longer period.
Personal data in connection with surveys, competitions etc. will be deleted within 1 month after the result has been announced.
What are your rights?
You have the following rights regarding your personal data:
- Access to your data
- Have incorrect data corrected
- Have your data deleted
- Withdraw a consent
- Have your data transferred to you in an accessible format.
- Right to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. While such a request is processed we are restricted in the use your personal information.
There may be restrictions or limitations to these rights which will be considered in the specific circumstances.
Please contact us email@example.com if you want to use any of your rights. In certain cases, Seller reserves the right to charge a reasonable administrative fee for this service according to applicable laws.
Seller has implemented appropriate technical as well as organizational measures in order to safeguard the processing of your personal data. We have e.g. safeguards against loss or theft as well as unauthorized access and undue disclosure of personal data.
Examples of technical safeguards include encryption, ’firewalls’ and Secure Socket Layer (SSL). See further details of these technical safeguards for personal data collected through our website here.
As an example of a procedural safeguard, Seller has implemented various authentication procedures internally and with our external service providers that may involve us requesting various personal particulars from you in order to verify your identity before we process your request for a particular service, product or transaction. Seller also monitor network traffic with a view to identifying unauthorized attempts to upload or change personal information, perpetuate fraudulent or illegal activities or otherwise cause damage.
If you have any concerns about security, you should contact us: firstname.lastname@example.org.
We would like to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt out later. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the Seller family of cooperation. If you no longer wish to be contacted for marketing purposes, please write here: email@example.com.
We don’t transfer or sell your personal information to any other third parties.
Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org.
The first time you land on our website you will see a box with information on cookies. If you don’t accept cookies, there will be no cookies for statistics, but there will be a cookie remembering this choice. If you don’t want our website to leave any cookies at all, you will have to turn cookies off in your browser. It will then also not be possible to use any other features that requires that the website remembers your choices.
How to contact us
Att: Privacy and Data Protection Complaints
[SLL/Razoone/DPO/specific contact information]
Rõika 31a, Tallinn 10617
Reg. Nr. 11010237
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Estonian Data Protection Agency, [Contact information: www.aki.ee information no. +372 56202341, e-mail: firstname.lastname@example.org]
OÜ Razoone, Rõika 31a, Tallinn 10617, Estonia
VAT: EE100874631/ Register no. 11010237
Customer service: +372 58856336 e-mail: email@example.com www.saartelennuliinid.ee
e-money institution: Paysera LT IBAN: LT87 3500 0100 0208 1736