Privacy Policy
Last updated May 2018
We recognise the importance of protecting your privacy and your rights with regards to data protection. The Internet is a very powerful medium when it comes to transmitting personal information; for that reason, we and all other companies belonging to the lastminute.com group undertake the serious task of respecting the current laws regarding the protection of personal data and the security of the same, with the aim of guaranteeing secure, controlled and confidential navigation for its users and customers when visiting and/or using the Website and/or use our Comparison Service (you as a "User") or then purchase our services (you as a "Customer").
This Privacy Policy describes how we collect, use, process, and disclose your personal data in conjunction with your access to and use of our Website and services and, specifically:
1. Who is the controller of your data?
2. What categories of your data do we collect and use?
3. Why and how do we collect your data?
4. Who sees, receives and uses your data and where?
5. How long do we retain your data?
6. What are your data protection rights and how can you exercise them?
7. Contact details of the data controller
8. Contact details of our data protection officer
9. Information about cookies
10. Update and old versions of this privacy policy
It also informs you how you can exercise Your Rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the section below.
If you see an undefined term in this Privacy Policy (such as “Service” or “Website”), it has the same definition as in our Company contractual service conditions.
1. Who is the controller of your personal data?
When this policy mentions “Company”, “we,” “us,” “our” or “Data Controller”, it refers to:
BravoNext, S.A., a Swiss company belonging to the lastminute.com group, listed in the Ticino business register under no. CHE - 115.704.228 and with registered office at Vicolo de’ Calvi 2 - 6830 Chiasso, Switzerland, which is responsible for the processing of Users’ and/or Customers’ personal data under this Privacy Policy (hereinafter, referred to as the “Company”, “we”, “us”, “our”, “Data Controller”).
We, being an entity located in Switzerland, are subject to Swiss law regarding the protection of personal data. For that reason, we undertake to comply with the obligations imposed by the Swiss Federal Act on Data Protection of 19 June 1992 (FADP). In the same vein, we inform our Users and/or Customers that the Decision of the Commission of 26 July 2000 in accordance with Directive 95/46/CE of the European Parliament and the Council relating to the adequate level of protection for personal data in Switzerland declared that, in Switzerland, the laws guarantee an adequate level of protection in accordance with Directive 95/46/CE.
In accordance with Swiss Federal Act on Data Protection of 19 June 1992 and with Article 45 of the Swiss Federal Act on the Supervision of Insurance Companies of 17 December 2004 (FASIC) we inform our Users and/or Customers that their personal data is processed and kept by the Company in the manner and for the means as follows, in accordance with the LPD and LSA.
2. What categories of your data do we collect and use?
When you visit the Website and use our Comparison Service (you as a "User") or then purchase our services (you as a "Customer") we collect the categories of personal data as follows:
2.1. Personal data provided by you
The personal data that you share with us when you register for an account, subscribe to newsletters and which you provide to us when using our services, including the information entered into our booking platform and included in your comments, reviews or messages sent via telephone to our Customer Care Team or through the Live Chat.
Special categories of personal data (for example, information concerning your health or revealing religious or sexual orientation that you might voluntary provide us in the course of making a booking by selecting the box "special transportation need" and filling in the empty field or by other means, such as via telephone to our Customer Care Team or through the Live Chat or at any moment when making a booking. We will use the special categories of personal data only as strictly necessary to fulfil your request.
The provision of the above personal data, where requested, is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
It is important that all the personal data you give us when you register as a User or otherwise when you use the Website is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.
If you plan to submit someone else's personal data to us, for instance when booking on their behalf, you should only provide us with that third party's details with their consent and after they have been given access to this Privacy Policy.
Please note that we may collect and use information of children only as provided by their parent or guardian or with their consent. If we become aware that we have processed information of a child without the valid consent of a parent or guardian, we reserve the right to delete it.
2.2. Personal data collected automatically from our Website and from third parties
Information about your visits to and use of the Website, such as information about the device and browser you are using, your IP address or domain names of the computers connected to the Websites, uniform resource identifiers for requests made, the time of request, the method used to submit the request to the server, the size of the archive obtained as a response, the numerical code indicating the status of the response given by the server (correct, error, etc.) and other parameters relative to the operating system and the computer environment used, the date and time that you visited, the duration of your visit, the referral source and website navigation paths of your visit and your interactions on the Website including the Services and offers you are interested in. Please note that we may associate this information with your account.
Please see the cookies section of this Privacy Policy (9. Information about cookies) for further information on the purposes for which we collect and use this information.
If you link, connect or login to your account with a third party service (e.g., Facebook, Google), the third party service may send us information such as your registration and profile information (i.e. user name, user ID associated with your social media account, picture, email), and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Website.
To the extent permitted by the applicable law wherein we receive additional information about you, such as fraud detection information and warnings from third party service providers and/or partners for our fraud prevention activities.
3. Why do we collect your data?
In general terms, we use your personal data to provide you with the services you request, process payment, provide customer services, send you marketing and promotional communications, notify you about important changes to our Website and to deliver our content and ads which we think may be of interest to you. More specifically:
Why?
A. To create and maintain the contractual relation established for the provision of the Service requested you in all its phases and by way of any possible integration and modification (e.g. facilitating your bookings and taking payments; responding to your questions and concerns; administering your account).
Please note that if your call to us is not connected, or if it is disconnected mid-call, you authorise us to use your phone number to call you back, in order to respond to your request.
B. For sending you information via email, phone or SMS relative to the established contractual relationship, including any communication relating to modifications thereof.
On which legal basis?
To fulfil a contract, or take steps linked to a contract
Why?
C. To meet the legal, regulatory and compliance requirements and to respond to requests by government or law enforcement authorities conducting an investigation.
On which legal basis?
To comply with the law
Why?
D. To carry out anonymous, aggregative statistical analyses so that we can see how our Website, products and services are being used and how our business is performing.
On which legal basis?
To pursue our legitimate interest (i.e. improving our Website, its features and our products and services)
Why?
E. To send you (in cases permitted by law excepting where you did not object) advertising material via email or, where permitted by the law, other equivalent electronic communication regarding products and services similar to those already purchased by you and offered on our Website. On some occasions, we may send you a personalised and tailored version of the aforementioned advertisement materials.
On which legal basis?
Soft Opt-in/To pursue our legitimate interest (i.e. marketing)
Why?
F. Without prejudice to the provisions of the preceding paragraph E, and only with your consent, to send you via email, phone, mail, SMS or MMS the best deals and offers on products and services we think you might find interesting which are marketed by us or our partners or business partners operating in the following sectors: tourism, leisure, entertainment, high technology, fashion, decoration, consumer goods, food and beverage, communication, mass media, real estate, education and training, energy, publications and publishing, information and communications technology. We may analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use automated decision making to segment and target product offers based on your demands and needs. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant. You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. For further details, you may contact our Data Protection Officers whose details are provided in this privacy policy.
On which legal basis?
Where you give your consent (by ticking the appropriate check box)
Why?
G. Passing your data to BravoNext, S.A. to collect and obtain the information about your bookings from the Data Controller with which you have contracted, in turn authorising this company to share this information to BravoNext, S.A.; this will facilitate the search and location of bookings you have made with any company of lastminute.com group on any of the Websites of the lastminute.com group through the APP or the personal area.
On which legal basis?
Where you give your consent (when you register or log into the APP or personal area)
Why?
H. To keep our Website and systems secure and to prevent and detect fraud, security incidents and other crime.
On which legal basis?
To pursue our legitimate interest (i.e. ensuring the security of our Website)
Why?
I. To verify compliance with our terms and conditions and for the establishment, exercise or defence of legal claims.
On which legal basis?
To pursue our legitimate interest (i.e. compliance with our terms and conditions, protection of our rights in the event of any dispute or claim)
Why?
J. To tailor and personalise online marketing notifications and advertising for you based on the information on your use of our Website, products and services and other sites collected through cookies (please see the Cookies section of this Privacy Policy for further information)
On which legal basis?
Where you give your consent (i.e. through the cookie banner or by your browser's settings)
4. Who sees, receives and uses your data and where?
4.1. Categories of recipients of your data
We share your personal data, for the purposes described in this privacy policy, to the following categories of recipients:
Our authorised employees and/or collaborators that assist and advise us on administration, products, legal affairs, Customer Care Team, and information systems, as well as those in charge of maintaining our network and hardware/software equipment;
Airlines, hotels, car hire companies, insurance companies, tour operators as well as those other parties to which it is necessary to disclose your personal data in order to provide you with the requested services that will be operating as autonomous data controllers. Please note that airline companies are required, in accordance with new regulations introduced in the US and other countries, to allow customs and border authorities to have access to flight passenger data. For that reason, in certain situations, we may communicate data collected on passengers included in the reservation to the competent authorities of the countries included in the Customer’s travel itinerary if required by the local law.
Our third-party service providers (including other entities of the lastminute.com group), which process your personal data on our behalf and under our instructions for the purposes described hereinabove acting as data processors, such as those providing us with IT and hosting services call centre and customer support, analytics and administration services etc.
Payment providers and financial institutions (e.g. for chargeback, fraud detection and prevention purposes) acting as autonomous data controllers.
Our business partners who are social media platforms when it is explicitly requested by you (e.g. when using social media authentication methods).
Competent authorities when we are required to do so by the current law.
Competent authorities and Law and enforcement third parties when this is necessary so that we can enforce our terms of use and protect and defend our rights or property or the rights or property of any third party.
Third parties that receive the data (e.g. business consultants, professionals for delivering due diligence services or assess value and capabilities of the business) when it is necessary in connection with any sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners.
The complete list of parties to which your personal data may be disclosed is available at our registered office and may be requested by writing to privacy.en@lastminutegroup.com.
4.2. International transfer of your data
Users’ and/or Customers’ personal data is processed in at the Data Controller’s registered office (see point 1) , on lastminute.com group servers, and at the offices of other entities to which data may be provided in order to provide the services requested of the Data Controller.
Given the fact that we are an international travel company, we also transfer your personal data to:
- non-European Economic Area (EEA) countries offering an adequate level of data protection such as Switzerland in accordance with the “Adequacy decisions” of the EU Commission that recognises some countries as providing adequate protection;
- non-European Economic Area countries where data protection laws may be less protective than the legislation in the EEA. This happens when:
- we disclose your data to autonomous data controllers such as airlines, hotels, car hire companies, tour operators etc. that might process your data outside the EEA in order to provide you with the requested services.
- we disclose your data to our service providers who act as data processors on our behalf that might be located in a country outside the EEA, including Morocco, India and Tunisia. When such a transfer happens, we ensure that it takes place in accordance with this Privacy Policy and is regulated by standard contractual clauses approved by the European Commission as ensuring adequate protection for data subjects. Our providers, acting as data processor, may be engaged in, among other things, the fulfilment of your service request, the processing of your payment details, the provision of advertising and marketing services on our behalf and the provision of support services through electronic communications or call centre.
Should you want to obtain further details about the safeguards put in place, you can contact us by writing to privacy.en@lastminutegroup.com.
5. How long do we retain your data?
We retain your personal data for as long as is required to achieve the purposes and fulfil the activities as set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law. Further information about the retention period is available here:
CUSTOMER RECORDS
Document
Booking records (name, address, contact information, PNR, ID Booking, birth date, number or identity document, date of issue, date of expiring, issuer country, typology ) including:
- Product details
- records of customer contacts related to the Agent section (i.e. Notes/Events in the BO),
- purchase data
- Checkout "Special request" section
Retention period
10 years
Starting date
From the date of the purchase
Document
Account information (see My Area):
- User, password
- Social login
- Purchase data
Retention period
10 years
Starting date
From the date of the last interaction
Document
Customer care emails (confirmation, schedule change/cancellation, quotation, penalties quotation, payment reminder, refund choice, voucher/payment, massive communications), including customer requests/claims via email
Retention period
10 years
Starting date
From date on which email is sent
Document
Customer care phone records
Retention period
3 years
Starting date
From date recording
Document
Chat (Customer/User)
Retention period
3 years
Starting date
From the date or the request
Document
Reports or claims
Retention period
10 years
Document
Contractual documentation (log of the acceptance)
Retention period
10 years
Starting date
From the date of the purchase
Document
Credit card data
Retention period
Not retained
Document
Finance/transactional information
Retention period
10 years
Starting date
From completion of financial transaction
Document
Transactional fraud check data
Retention period
5 years
Starting date
From rejection of transaction for fraud
DATA USED FOR MARKETING PURPOSES (CRM)
Document
Data used for marketing activities to customers/users subject to the consent
Retention period
5 years
Starting date
From the consent or the renewal of the consent via interaction with marketing communications
DATA COLLECTED VIA TAG
Document
Technical cookies
Retention period
Max 3 years
Starting date
From the date of browsing on our websites
Document
Non-technical Cookies
Retention period
Max 1 year
Starting date
From the date of browsing on our websites
Name of the right
Right of access
Content
To receive confirmation of the existence of your personal data, access its content and obtain a copy.
Name of the right
Right of rectification
Content
To update, rectify and/or correct your personal data.
Name of the right
Right to erasure/right to be forgotten and right to restriction
Content
To request the erasure of your data or restriction of your data which has been processed in violation of the law, including whose storage is not necessary in relation to the purposes for which the data was collected or otherwise processed; where we have made your personal data public, you have also the right to request the erasure of your personal data and to take reasonable steps, including technical measures, to inform other data controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
Name of the right
Right to data portability
Content
To receive a copy of your personal data you provided to us for a contract or with your consent in a structured, commonly used and machine-readable format (e.g. data relating to your purchases) and to ask us to transfer that personal data to another data controller.
Name of the right
Right to withdraw your consent
Content
Wherever we rely on your consent (see p. 3 - F, G and J), you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes.
Name of the right
Right to object, at any time
Content
You have the right to object at any time to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement (see p. 3-D, H, I), or where we are using your data for direct marketing (p. 3-E).
You can exercise the above rights at any time by:
Contacting us via email at privacy.en@lastminutegroup.com.
As for direct marketing, please note that you can also object at any time by clicking the unsubscribe link which we provide in each communication sent to you
As for online targeted ads and the withdrawal of your consent please refer to our Cookie section of this Privacy Policy.
Your rights in relation to your personal data might be limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process your personal data which you have asked us to delete.
You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Data Protection Supervisory Authority.
7. Contact details of the data controller
The contact details of the Data Controller of the data processing described hereinabove are:
BravoNext, S.A., a Swiss company belonging to the lastminute.com group, listed in the Ticino business register under no. CHE - 115.704.228 and with registered office at Vicolo de’ Calvi 2 - 6830 Chiasso, Switzerland.
9. Information about cookies
Cookies are small files which are stored on your computer, they hold a modest amount of data specific to you and allows a server to deliver a page tailored to you on your computer, hard drive, smartphone or tablet (hereinafter referred to as, “Device”). Later on, if you return to our Website, it can read and recognise the cookies. Primarily, they are used to operate or improve the way our Website works as well as to provide business and marketing information to the Website owner.
In accordance with the notice of cookie usage appearing on our Website’s homepage and our Cookie Policy you agree that, when browsing our Website, you consent to the use of cookies described herein, except to the extent that you have modified your browser settings to disable their use. This includes but is not limited to browsing our Website to complete any of the following actions: closing the cookie notice on the Homepage, scrolling through the Website, clicking on any element of the Website, etc.
What follows is a description of the type of cookies used in the website:
9.1 Types of cookies according to the managing entity
Depending on what entity manages the computer or domain from which the cookies are sent and processed, there exist the following types of cookies:
- First party cookies: these are sent to your Device from a computer or domain managed by us and from which the service you requested is provided.
- Third party cookies: these are sent to your Device from a computer or domain that is not managed by us, but by a separate entity that processes data obtained through cookies.
9.2. Types of cookies according to the length of time you stay connected:
Depending on the amount of time you remain active on your Device, these are the following types of cookies:
- Session cookies: these are designed to receive and store data while you access the Website. These cookies do not remain stored on your Device when you exit the session or browser.
- Persistent cookies: these types of cookies remain stored on your Device and can be accessed and processed after you exit the Website as well as when you navigate on it for a pre-determined period of time. The cookie remains on the hard drive until it reaches its expiration date. The maximum time we use persistent cookies on our Website is 2 years. At this point the browser would purge the cookie from the hard drive.
9.3. Types of cookies according to their purpose
Cookies can be grouped as follows:
- a) Technical cookies: these cookies are strictly necessary for the operation of our Website and are essential for browsing and allow the use of various features. Without them, you cannot use the search function, compare tool or book other available services on our Website.
- b) Personalisation cookies: these are used to make navigating our Website easier, as well as to remember your selections and offer more personalised services. In some cases, we may allow advertisers or other third parties to place cookies on our Website to provide personalised content and services. In any case, your use of our Website serves as your acceptance of the use of this type of cookie. If cookies are blocked, we cannot guarantee the functioning of such services.
- c) Analytical cookies for statistical purposes and measuring traffic: these cookies gather information about your use of our Website, the pages you visit and any errors that may occur during navigation. We also use these cookies to recognise the place of origin for visits to our Website. These cookies do not gather information that may personally identify you. All information is collected in an anonymous manner and is used to improve the functioning of our Website through statistical information. Therefore, these cookies do not contain personal data. In some cases, some of these cookies are managed on our behalf by third parties, but may not be used by them for purposes other than those mentioned above.
- d) Advertising and re-marketing cookies: these cookies are used to gather information so that ads are more interesting to you, as well as to display other advertising campaigns along with advertisements on the Website or on those of third parties. Most of these cookies are “third party cookies” which are not managed by us and, because of the way they work, cannot be accessed by us, nor are we responsible for their management or purpose. Our Privacy Policy contains more information about the way third party cookies work, their purpose and how they are used. You may find this information in the list of cookies available in Clause 5 of our Cookie Policy.
To that end, we can also use the services of a third party in order to collect data and/or publish ads when you visit our Website. These companies often use anonymous and aggregated information (not including, for example, your name, address, email address or telephone number) regarding visits to this Website and others in order to publish ads about goods and services of interest to you.
- e) Social cookies: these cookies allow you to share our Website and click “Like” on social networks like Facebook, Twitter, Google+, and YouTube, etc. They also allow you interact with each distinct platform’s contents. The way these cookies are used and the information gathered is governed by the privacy policy of each social platform, which you can find on the list below in Paragraph 5 of our Cookie Policy.
To see the list of cookies used on this Website, click here http://www.bravofly.com.au/en/info/list-cookies.html.
The information contained in the above list of cookies has been provided by the other companies which generate them.
These companies have their own privacy policies in which they set forth both their own declarations as well as applicable disabling systems.
The lastminute.com group is not responsible for the contents and accuracy of third party cookie policies contained in our Cookie Policy.
You must keep in mind that if your Device does not have cookies enabled, your experience on the Website may be limited, thereby impeding the navigation and use of our services.
There are a number of ways to manage cookies. By modifying your browser settings, you can opt to disable cookies or receive a notification before accepting them. You can also erase all cookies installed in your browser’s cookie folder. Keep in mind that each browser has a different procedure for managing and configuring cookies. Here’s how you manage cookies in the various major browsers:
- MICROSOFT WINDOWS EXPLORER
- GOOGLE CHROME
- MOZILLA FIREFOX
- APPLE SAFARI
If you use another browser, please read its help menu for more information.
If you would like information about managing cookies on your tablet or smartphone, please read the related documentation or help archives online.
We do not install third party cookies. They are installed by our partners or other third parties when you visit our Website. Therefore, we suggest that you consult our partners’ Websites for more information on managing any third party cookies that are installed. However, we invite you to visit the following website http://www.youronlinechoices.com/where you can find useful information about the use of cookies as well as the measures you can take to protect your privacy on the internet.
10. Update and old versions of this privacy policy
We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our Website and update the “Last Updated” date at the top of this Privacy Policy.
Old versions of this Privacy Policy are available here.
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