Compensair respects privacy of all Website visitors and clients, and undertakes to ensure security of their personal data both while visiting the Website and while using the services provided by Compensair.
1. Personal data Compensair may collect and process and the purposes of its collection and processing
1.1. Compensair is a service which pursues the following purposes:
1.1.1. Provide the Services in accordance with “Terms and Conditions”;
1.1.2. Informing the Client about passenger’s rights protection and other issues related to the exercise of passenger’s rights.
1.1.3. Informing the Client about advertising campaigns and offers from Compensair and Compensair’s Partners.
1.2. During collecting, processing and storage of personal data Compensair acts under the legislation of Singapore and the General Data Protection Regulation (EU) (2016/679) including the principles enshrined in Article 5 of the GDPR:
1.2.1. The processing of personal data shall take place in a lawful, fair and transparent way;
1.2.2. The collecting of personal data shall only be performed for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
1.2.3. The collecting of personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed;
1.2.4. The personal data shall be accurate and where necessary, kept up to date;
1.2.5. Every reasonable step shall be taken to ensure that the personal data that are inaccurate having regard to the purposes for which they are processed, are erased or rectified without delay;
1.2.6. Personal data shall be kept in a form which permits identification of the data subject for no longer than it is necessary for the purpose for which the personal data are processed;
1.2.7. All personal data shall be kept confidential and stored in a manner that ensures appropriate security;
1.2.8. Personal data shall not be shared with third parties except when necessary for them to provide services upon agreement;
1.2.9. Data subjects shall have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.
1.3. For recovering of compensation with assistance of Compensair the Client makes an application. While filling an application the client provides the following personal data: name and surname, e-mail, mobile phone number, address, date of birth. These personal data are requested as airlines refuse to consider a case without them.
In case the client traveled with a minor whose legal representative is the Client while filing an application the Client also mentions the name and surname of the minor and his date of birth.
In the field “Suggested reason of Delay ” and “Description” the Client may provide a short description of the case and additional details. These fields are not intended for the Client’s personal data.
1.4. After an application is filed a personal account for each Client is created in Compensair’s system where all the data uploaded by the Client is stored. The Client may add a description or upload additional documents at any time on his own.
1.5. Additional personal data of the Client such as an identity card of the Client (ID) used to purchase a ticket, a hand-signed power of attorney of the Client may be requested by the airline or other competent authority. In this case Compensair offers the Client to upload the mentioned documents via his personal account. After the upload the Client’s documents are stored at the internal system of Compensair. For security purposes at the Client’s personal account only the information about the number of the uploaded documents is shown. Files of the documents itself are not shown and are not available for download.
1.6. If the decision to pay a compensation is made, the list of the Client’s personal data that is requested, the purposes of their usage, the order of its processing and storage are stated by the Compensair Payment Policy.
1.7. In addition to the above mentioned data, Compensair also collects and processes correspondence between Compensair and the Client.
1.8. If the Client leaves his feedback at the website or official communities of Compensair in social networks, Compensair may use it for advertising goals at aforementioned platforms as well as the websites of Compensair’s partners. The feedback is anonymous and doesn’t allow to identify the person who left it.
2. The period of storage of personal data
2.1. The Client’s personal data are stored for 10 (ten) years since the agreement between Compensair and the Client is fulfilled or since the last action of the Client on the website if the Client has not finished an application for a compensation.
2.2. The data connected with the use by the Client of opportunities or services provided by the Compensair’s website and that are not considered as the personal data may be processed anonymously during statistical and marketing researches or any other similar activities. In any case such processing of data will not allow directly or indirectly to identify the Client.
3. Disclosure of information
3.1. The Client’s data may be disclosed to the Partners of Compensair, its Affiliates and other third parties if it is required for the purposes of collecting compensation for the Client’s claim as well as for performing the contractual obligations of Compensair. In this case Compensair discloses only the personal data which is required by third persons for the service delivery. Compensair does not disclose the data to third parties for giving them an opportunity to advertise their goods or services to the Client.
3.2. Compensair may disclosure the Client’s data if it is required by law (for example, by supervisory authorities to meet the requirements of the GDPR); to comply with a subpoena or other legal processes, when Compensair believes in a good faith that the disclosure is necessary to protect the rights of Compensair, to protect safety of Clients or of others.
4. Client’s rights
4.1. The Client has the right to lodge a complaint with data protection regulators. Compensair is registered in Singapore and the Personal Data Protection Commission (PDPC) is our lead regulator. The Client can find out how to raise a concern with the PDPC by visiting their website at www.pdpc.gov.sg. If the Client is within the EU, he may also get in touch with his local Data Protection Regulator.
4.2. The Client has a number of rights under European Data Protection law if they are a citizen of the EU, Switzerland, or United Kingdom:
4.2.1. Right to withdraw a consent to the processing of personal data;
4.2.2. Right to be informed: what personal data Compensair is processing and why. The information is sent to the Client to the provided email address within 1 (one) month since the date of the Client’s request. The period of the reply may be extended up to 2 (two) months due to the number and complexity of the requests;
4.2.3. Right of access: the Client can request a copy of his data, though this right does not include access to the internal correspondence of Compensair, including correspondence with third parties considering Client’s case;
4.2.4. Right of rectification: if the data held is inaccurate, the Client has the right to have it corrected;
4.2.5. Right to erasure (“right to be forgotten”): the Client has the right to have his data deleted in certain circumstances;
4.2.6. Right to restrict processing: in limited circumstances, the Client has the right to request that processing is stopped but the data retained;
4.2.7. Right to data portability: the Client can request a copy of his data in a machine-readable form that can be transferred to another provider;
4.2.8. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) the Client may object to that processing;
If the Client wants to exercise any of his rights listed above, he may email Compensair at firstname.lastname@example.org.
Safeguards of personal data
4.5. Although Compensair does its best to protect the personal data of the Client, Compensair cannot guarantee the security of the Client’s data transmitted to the website. Any transmission is at Client’s own risk. Once Compensair has received Client`s information in the site, upon processing such it will use safe organizational and technical measures to prevent such data from accidental and unlawful destruction, alteration, disclosure as well from all other unlawful activities. Information provided to Compensair is being kept at secure servers.
4.6. The Client must take active measures to ensure privacy of his personal data including putting his best effort to ensure privacy of the password necessary to access the website. The Client must ensure that third persons shall not directly or indirectly obtain such data and shall not use the Client’s data to access the website and/or services and/or for other purposes. The Client is responsible for any actions of third persons made by using the Client’s data and all obligations and liability, arising or related to such actions of third persons shall be the Client’s to the full extent.
4.7. In case Compensair has doubts as to the correctness of data provided by the Client, Compensair may suspend the processing of such Client’s personal data and check and clarify such data.
Please forward any inquiries that you may have regarding the safeguards of personal data to the following email email@example.com
5. Links to other sites
6. Final provisions
Updated on 23 June 2023