Refundor Privacy Policy

Version 1.0

Effective as of 17 July 2018

This privacy policy (the “Privacy Policy”) explains how the Refundor online platform located at (the “Platform”) maintained by Refundor SIA, a company established pursuant to the laws of the Republic of Latvia with registration number 50203148131, having its registered address at Codes 1a, Rīga LV-1058 (“Refundor”, “we” or “us”), collects and uses information when you (the “User”or “you”) interact with us. This Privacy Policy applies to all the Users of the Platform. By using or interacting with any of the services provided by Refundor under the Platform you agree to the provisions of this Privacy Policy and consent you have read and understood all of the provisions stated herein. Further, you provide freely given, specific, informed and unambiguous consent that Refundor may process your personal data as provided under this Privacy Policy where you consent is the basis for the processing of your personal data. Please read the provisions of this Privacy Policy carefully and do not hesitate to contact us if necessary.

1. Data Collected
1.1. Personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2. In order to perform Our duties under the Customer contract, We will collect the following Personal Data about you:
1.2.1. Your Name, Surname and other personal identification data;
1.2.2. Your flight information;
1.2.3. Your account and banking information necessary to enforce wire transfers;
1.2.4. Your location, if available;
1.2.5. Any additional information that you provide about you in the Platform when submitting information for use of Our services.
1.3. The data collected about you is necessary for Refundor to ensure basic functions of the Platform as well as to develop its functionality and analyse the use of the Platform to improve your experience when using the Platform.
1.4. The data collected about you in the Platform is also summarised into statistics that may be given to third parties. Statistics contain only the criteria and numeral data, therefore, a natural person cannot be identified by the aforementioned third parties. We do not transfer your Personal Data to third parties unless this is required for performance of the Customer contract.
1.5. Please note that other users of the Platform cannot see any information provided by you in the Platform.
2. How the Data is Collected
2.1. We may collect Personal Data from you when you register, input your data in the Platform, otherwise interact with the Platform or provide your data in the follow-up communication.
3. Purposes and Basis for Personal Data Processing
3.1. By using the Platform you give a freely and informed consent to the processing of your Personal Data. You have the right to withdraw your consent at any time in accordance with Clause 5.4 of this Privacy Policy.
3.2. Refundor processes your Personal Data based on your consent to:
3.2.1. fulfil the Customer contract;
3.2.2. ensure the possibility to use the functionality of the Platform described in the Customer contract or another relevant document. In cases where you accept the terms of any other document, to which you and Refundor are parties, the Personal Data is also processed for the performance of the obligations of Refundor and pursuant to the purposes referred to in such document;
3.2.3. communicate and provide additional information that may be of interest to you about our services;
3.2.4. send you reminders, technical notices, updates, newsletters, security alerts and support and administrative messages, service bulletins, or marketing materials;
3.3. Please note that if we do not have your consent for the processing of your data for the aforementioned purposes, we will not be able to fulfil our obligations under the Customer contract.
3.4. Refundor processes your Personal Data based on our legitimate interests (such as business development and development of the Platform functionality) to:
3.4.1. operate and improve the Platform;
3.4.2. evaluate eligibility of the Users to receive our services;
3.4.3. evaluate the type of services that may be of interests to the Users;
3.4.4. identify the most active use of our services by location in order to ensure the client-oriented provision of the Services and our business development;
3.4.5. perform various analytics;
3.4.6. provide customer support to the Users;
3.4.7. fulfil requests related to our services;
3.4.8. provide the statistical information to third parties;
3.4.9. manage our everyday business needs such as the Platform administration, analytics, fraud prevention, or to comply with provisions of the applicable law.
3.5. Decisions pursuant Clause 3.4.2. of this Privacy Policy may be automated.
3.6. Subject to specific statutory requirements, we may provide your Personal Data to corresponding authorities. Please note that if Refundor has an obligation to provide your Personal Data to third parties according to the statutory requirements, you will not have the right to request us to stop such processing of your Personal Data.
4. Data Storage and Transfer
4.1. We may transfer your Personal Data to such recipients as services providers, business partners or adversary third parties, Supervisory authorities, including but not limited to such recipients:
4.1.1. State authorities and other authorized parties that may request us to provide your Personal Data subject to specific statutory requirements;
4.1.2. Technical services providers such as developers who may access your Personal Data while performing testing or support activities. However, we minimize the amount of the Personal Data available to such recipients;
4.1.3. Business partners or adversary third parties of Refundor, where such transfer is necessary for fulfilment of the Customer contracts.
4.2. We will only store your Personal Data for as long as it is needed to fulfil the purposes for which it was collected, subject to applicable data retention periods imposed upon by the applicable legislation as well as until such time as is required to meet the aforementioned Personal Data processing purposes. If you are part in or benefit from Refundor’s affiliation program, we will store your Personal data until your refusal for data processing is received in accordance with Clause 5.4.
4.3. The Data collected from you may be transferred to, and stored at, a destination within the European Union ("EU"). It will be processed by data processors operating within territory of EU.
4.4. By submitting your data, you agree to the processing of your data including storing and transfer within the EU for the purposes set out in this Privacy Policy. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with the applicable data protection laws and regulations. We will not store your data longer than necessary to fulfil the purposes set out in this Privacy Policy.
4.5. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Platform, therefore any transmission is at your own risk and you are free to choose whether to use our Platform or not. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
5. Access to Data and Other Rights
5.1. If you are a natural person and have provided your personal data to us you have the right to access to your data and to receive the information on: the purposes of the processing, the categories of personal data concerned; the categories of recipient to whom the personal data have been or will be disclosed, retention term if applicable, your rights, information on the source from which your personal data was received by us, information on the automated decision-making and profiling.
5.2. You also have the right to request a copy of your personal data that we process. For any further copies requested, we may charge a reasonable fee based on administrative costs.
5.3. You have the right to request rectification or erasure of your personal data or restriction of processing or to object to processing, to lodge a complaint with a supervisory authority, as well as the right to data portability.
5.4. You are free to refuse from any further processing of your personal data at any time by informing us by e-mail:, if the processing of your Personal Data is based on your consent as indicated above. Such withdrawal will not affect the lawfulness of processing done before the withdrawal, however. Withdrawal may impact fulfilment of the Customer contract and you may be held liable for damages suffered by us.
6. Third-party Data
6.1. You may not upload or otherwise submit to the Platform the personal data of other natural persons.
6.2. By accepting this Privacy Policy, you confirm that you understand that you are completely responsible and liable for the processing of the personal data of such third parties via Platform. Refundor shall be neither responsible nor liable for the personal data of the third parties that you process via Platform.
6.3. Hereby you confirm that you understand that you have the right to use Platform for the processing of the third party’s personal data only if you have a legal basis to carry out such activities with the personal data and if you comply with the requirements of the applicable laws.
7. General terms and conditions
7.1. You are liable for the appropriate use of our Platform. Any action which causes or could cause any disturbance to the operations of Platform is strictly prohibited. You may not interfere into the operations and technical solutions of Platform.
7.2 All copyrights in or to the Platform or part of them are owned by us, our licensors or our partners, who reserved their rights. Any kind of monitoring of the Platform and/or copying, reproducing, usage or republishing of the acquired information, as well as its contents unless it is stated otherwise is strictly prohibited without our prior written consent.
7.3. We are entitled to prohibit you the usage of the Platform if there are sufficient grounds to consider that this Policy is not complied with.
8. Modification of the Privacy Policy
Refundor may revise the terms and conditions of this Privacy Policy at any time without notice. By using the Platform, you are agreeing to be bound by the current version of this Privacy Policy.
9. Governing Law
Any disputes arising from this Privacy Policy shall be governed by the laws of Latvia and subject to the exclusive jurisdiction of the courts of the Republic of Latvia.
10. Contact Information
If you have any questions about this Privacy Policy, please contact us at: