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PRIVACY POLICY — GDPR

flyrecover.com — FlyRecover OÜ

Last update: [date]


1. Data controller

FLYRECOVER OÜ — Estonian private limited company, registry no. [●], registered office [●], Tallinn, Estonia. Privacy email: privacy@flyrecover.com. EU representative under Art. 27 GDPR: not required (main establishment in EU).

2. Commitment

The Company processes personal data in accordance with Regulation (EU) 2016/679 ("GDPR"), the Estonian Personal Data Protection Act (Isikuandmete kaitse seadus) and equivalent rules in jurisdictions where Clients reside.

3. Categories of data processed

Category Examples Main purpose
Identity name, DoB, ID document Identification, anti-fraud, KYC
Contact email, phone, WhatsApp, postal address Communication, claim follow-up, payment
Flight data flight number, date, route, PNR, boarding pass Building the claim, eligibility check
Financial data IBAN, BIC, payment evidence Remittance of recovered sums
Connection data IP address, browser type, date/time Security, audit, anti-fraud
Support exchanges emails, chats, WhatsApp, call notes Customer service, quality, evidence
Purpose Legal basis (GDPR)
Conclusion and performance of the Agreement Performance of contract (Art. 6.1.b)
Claim management Performance of contract (Art. 6.1.b)
Representation before airlines and authorities Performance + legitimate interest (Art. 6.1.b/f)
Anti-fraud / KYC / AML Legal obligation (Art. 6.1.c) + legitimate interest
Bookkeeping and tax obligations Legal obligation (Art. 6.1.c)
Marketing communications (newsletter) Consent (Art. 6.1.a), revocable any time
Site analytics Legitimate interest (Art. 6.1.f)
Non-essential cookies Consent (Art. 6.1.a)

5. Recipients

Strictly on a need-to-know basis: - internal staff and contractors; - airlines concerned; - National Enforcement Bodies (DGAC, CAA, LBA, etc.); - partner lawyers and bailiffs; - technical providers (hosting, CRM, e-signature, payments, WhatsApp BSP, support); - public authorities upon legal request.

Data is never sold for third-party marketing.

6. Main sub-processors

Sub-processor Role Location Safeguards
[Hosting provider] hosting EU Art. 28 GDPR DPA
[CRM] client relationship EU/USA DPA + SCCs
[E-signature] contract signature EU DPA + eIDAS
[Payments — Stripe / Wise] collection and remittance EU DPA + PSD2
[WhatsApp BSP] WhatsApp messaging EU/USA DPA + SCCs + opt-in
[Flight data API] flight data EU commercial contract

7. Transfers outside EU

Where transferred to a country without an adequacy decision, the Company implements: - EU Commission Standard Contractual Clauses (SCCs); and/or - supplementary measures (encryption, pseudonymization, access restrictions).

8. Retention

Category Duration
Active claim duration + 3 years
Accounting documents 7 years (Estonian law)
KYC / AML data 5 years after closure
Cookies per Cookies Policy (max 13 months)
Connection logs 12 months
Newsletter until unsubscribe

9. Data subject rights

To exercise: privacy@flyrecover.com. Reply within 30 days, extendable by 60 days for complex requests.

10. Security

11. Cookies

See the Cookies Policy: https://flyrecover.com/cookies.

12. Minors

The Services are not intended for persons under 16 acting on their own behalf. Where a minor is concerned, the parent or legal representative must sign.

13. Amendments

The Company may amend this Policy. The version published on the Site applies. Material changes are notified by email to active Clients.

14. Contact