Privacy Policy

04 декабря 2020

Agreement on the Processing and Storage of Personal Data (Personal Data Processing Policy)

    Current version as of January 23, 2023

  • 1. General provisions

    This Agreement (hereinafter referred to as the "Agreement") is approved by Go Travel Un Limited, registered as a legal entity under the law of the Hong Kong Special Administrative Region on 18.08.2011, registration certificate No. 1658681, with its office registered at: Room 1504, 15/F, Chinachem Tower, 34-37 Connaught Road Central, Hong Kong (hereinafter referred to as the "Owner") and defines the procedure for collecting, processing, storing, and protecting personal data and other information of Users.

    Agreement – This document, along with all supplements, amendments, and binding instruments stated herein, shall be an integral part of the contract concluded with the User when using online resources and/or facilities of Aviasales in accordance with the Terms of Use of Aviasales.

    Aviasales (Service) – a multifunctional software product for travelers as defined in clause 1.2. of the Terms of Use.

    User – a legally capable individual who uses Aviasales using a personal computer and/or mobile device available to him/her, has his/her own e-mail address or other means of authorization on the Service (if applicable), and accepts the terms and conditions of the Agreement.

    Owner – Go Travel Un Limited, which organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data, either alone or in affiliation with other legal entities belonging to its group of entities or engaged in processing personal data on other legal grounds.

    Personal Data – any information (data related to events, facts, and circumstances of the subject's life) directly identifying the User and processed by the Owner on Aviasales automatically or provided by the User independently during authorization, for example, through the social networks VK, Facebook, Twitter, Ok.ru or accounts on Google, mail.ru, Yandex, Apple, Line, WeChat (if applicable), as well as during further use of other sections of Aviasales, including when entering into individual contracts or using individual Aviasales Services.

    Personal Account – the personal section of Aviasales that the User gets access to after authorization. An account is used to store User information for the convenience of subsequent use of the Service, create a personal profile, view and manage Aviasales features, and access individual features and Services.

  • 2. The Objectives of Processing Personal and User Data

    The Owner processes Personal Data and other User Data to perform its obligations to the User and other persons, to maintain the performance of the Service, and to ensure the legitimate interests of the Owner in accordance with the Terms of Use of Aviasales. In particular, the Owner processes Personal Data and other User Data in order to:

    • authorize the User on Aviasales by any means available, including for the purpose of creating an Account for the User, as well as for user-based personalization of the Service;
    • provide access to Aviasales and its features (contractual performance) in the interest and by request of the User, including through the user interface;
    • protect the Aviasales software product and Users' data against any interference of third parties, fraudulent use, and to detect improper use of Aviasales and/or violation of the Terms of Use;
    • conduct marketing, statistical, analytical, and other studies on the use of Aviasales to optimize the Service, its individual features, the development of products and Services of Aviasales and its providers, as well as increasing their convenience for consumers;
    • display and customize advertisements on the Internet and on Aviasales itself and/or send advertising information to the User via telecommunication networks (including mobile Services, push notifications, e-mail) relating to Aviasales and the travel Services market, as well as other offers from partners and third parties;
    • promote Aviasales and its features on the market, in particular, through direct contact with its Users according to the contact information provided by the User, as well as disclose statistical data relating to the Service and individual cases of its usage, if such disclosure does not pose a threat to the interests of the User;
    • process complaints by Users submitted to the support Service in connection with the use of Aviasales and provide advice and assistance in resolving issues related to the provision of Services by providers;

    If there are sufficient grounds, the Owner may process Personal Data to serve both one or more purposes simultaneously.

  • 3. Grounds for processing Personal Data and other information

    Personal Data is processed based on:

    • the Terms of Use of Aviasales and other contracts concluded with the User;
    • consent to this Agreement or individual consents of the User that may be given by the User when using Aviasales;
    • compliance with the contractual and statutory obligations of the Owner;

    The User, using Aviasales or its features, independently, freely, of his will, and in his/her interest, gives the Owner informed consent to the processing of his/her Personal Data and other information until the purpose of processing is achieved or consent is withdrawn.

    By using Aviasales, individual features of the Service, and/or by logging into Aviasales, participating in marketing or advertising projects, as well as by contacting the support Service, the User confirms that they he/she has read this Agreement, the contents of which are made available in advance on Aviasales, including, during authorization in the form of a notification with the following text and hyperlink: "By signing in, you agree to our Terms of Use and Privacy Policy".

  • 4. Quantities and categories of Personal Data

    The Owner may process the following data obtained from the User directly or through the use of Aviasales.

    The following is provided by the User independently within the framework of the contract(s) on the use of Aviasales, individual features, including the simplified booking function:

    • name, surname, sex, passport details, date of birth, citizenship;
    • e-maill address;
    • telephone number;
    • other data provided by the User through using Aviasales, including data received from third parties on behalf of the User;
    • information related to the payment method when the necessity to perform mutual settlements arises in connection with the use of Aviasales;

    Processed automatically when you visit and use Aviasales:

    • IP address, social network ID (identification number), cookie files, and similar technologies in accordance with Section 5 of the Agreement, parameters and settings of Internet browsers and User's devices;
    • various statistics on how the User uses of the Service's functions, as well as other technical information, such as searched destinations;
    • Information on the location where the User connects to the Service;

    The Owner is not responsible for the completeness and relevance of information about Users. The User has the right to edit at any moment the Personal Data he or she has provided in his or her Account during authorization and other use of Aviasales.

    By providing third-party data, the User warrants that he or she has the authority to provide such data to the Owner.

    The Owner is not responsible for any processing of Personal Data that may take place following the User's access to third-party resources available on Aviasales and that does not fall under the terms of this Agreement.

  • 5. Cookie files and similar technologies

    Cookies and similar technologies (e.g., pixels, tags, cache, local storage, etc.) are small data fragments most often implemented in the form of text identifier files that are installed on the User's device or platform when visiting Internet resources and individual pages and interacting with them to create information. Aviasales uses cookie files of a various nature, which can be created by the Service itself or by third parties-partners providing, for example, functional and technical solutions within the Service.

    Cookies and similar technologies make it possible to personalize the settings of the Service and display advertising information, optimize Aviasales for Users by storing information on actions performed, such as information about Account authorization, viewed/claimed advertisements, impersonal information about interests, effectiveness of the user interface on certain pages, choosing the language of the Service, or activation or deactivation of certain features.

    The types of cookies used by Aviasales (including cookies and similar third-party technologies) to achieve processing aims can be categorized as follows:

    • Technical cookies are cookies that are required in order for Aviasales or its individual features to be accessed by the User in accordance with the Terms and other obligations of the Owner;
    • Functional cookies are cookies that help to personalize the User experience during interactions with Aviasales and make it more convenient, as well as analyze data on behavior and events on the Service;
    • Advertising/Marketing cookies are cookies that allow the Owner to monitor the effectiveness and performance of advertising information on Aviasales, and Users to see more personalized advertising on the Internet and influence how it is displayed in the future, including ads that are shown and customized through the advertising platforms of suppliers Google, Facebook, Twitter, Yandex or others;

    The User can independently configure parameters for setting, blocking, or rejecting cookies in a browser, such as Chrome or Safari, or the device used to access Aviasales. Information on setting, blocking, and deleting cookies can be found in the help sections of the User's browser or device. The User can also configure third-party cookies on the pages of relevant advertising platforms or analytical Services, such as Yandex Metrics, Google Analytics, Facebook, whose cookies are (can be) used on the Service. Custom cookies-file management can also be used on the Aviasales user interface.

    Removing or disabling certain cookies may result in unavailability of certain features or parts of the Aviasales Service.

  • 6. Processing of Personal Data and User Rights

    Processing is carried out by the Owner and third parties (operators) on its behalf, including collection, recording, systematization, accumulation, storage, clarification (updates and changes), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data. Processing may be performed by both automated and non-automated means.

    When processing Personal Data, the Owner shall ensure its protection against unauthorized access and dissemination in accordance with its internal rules and regulations and applicable data protection laws.

    Personal Data of the User shall be kept confidential, unless the technology of the Service or the settings of the browser or device used by the User provide for an open exchange of information with other Users or with any Internet users. The Owner may disclose Personal Data and other information about the User to bodies of inquiry and investigation or other authorized bodies on the grounds provided by applicable law.

    The Owner may transfer Personal Data to third parties, including across borders to foreign entities in order to achieve the purposes set forth in this Agreement. In this case the Owner guarantees observance of measures of protection of Personal Data by such persons in accordance with the standards of this Agreement and applicable law.

    If all the processing objectives are achieved or if the User withdraws their consent to the processing, the User is guaranteed the deletion of their Personal Data from all third parties involved in the processing under the Agreement, regardless of the location of the data.

    The User has the right at any time to withdraw his or her consent to the processing of his or her Personal Data and to exercise other rights as the subject of said Personal Data in accordance with applicable law by sending a request to the Owner at help@aviasales.com or by using the data management features available on Aviasales. The Owner shall stop processing Personal Data and destroy them within no more than 3 business days of receiving such a request. The Owner has the right not to delete the User's data required to be stored in accordance with applicable law. In this case, the Owner shall retain such data in an anonymized form in its database systems.

  • 7. Final provisions

    This Agreement applies to all Users. All matters not settled in the Agreement shall be resolved in accordance with applicable law.

    The Agreement may be amended by the Owner without prior notice to Users. The new version of the Agreement comes into force from the moment of its posting at https://www.aviasales.ge/privacy. When changes are made in the current edition, the date of the most recent update is indicated.

    If you have any questions about the processing of Personal Data on Aviasales and this Agreement, contact the Aviasales support Service by at help@aviasales.com or legal@aviasales.com, you can also send a letter to the Owner's registered postal address.