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Refundor Privacy Policy
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Version 1.0
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Effective as of 17 July 2018
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\nThis privacy policy (the “Privacy Policy”) explains how the Refundor online\nplatform located at www.refundor.com (the “Platform”) maintained by\nRefundor SIA, a company established pursuant to the laws of the Republic\nof Latvia with registration number 50203148131, having its registered address\nat Codes 1a, Rīga LV-1058 (“Refundor”, “we” or “us”), collects and uses\ninformation when you (the “User”or “you”) interact with us. This Privacy\nPolicy applies to all the Users of the Platform. By using or interacting\nwith any of the services provided by Refundor under the Platform you agree\nto the provisions of this Privacy Policy and consent you have read and\nunderstood all of the provisions stated herein. Further, you provide\nfreely given, specific, informed and unambiguous consent that Refundor\nmay process your personal data as provided under this Privacy Policy where\nyou consent is the basis for the processing of your personal data. Please\nread the provisions of this Privacy Policy carefully and do not hesitate\nto contact us if necessary.\n
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\n1. Data Collected\n
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\n1.1. Personal\ndata means any information relating to an identified or identifiable\nnatural person (‘data subject’). An identifiable natural person is one who\ncan be identified, directly or indirectly, in particular by reference to an\nidentifier such as a name, an identification number, location data, an online\nidentifier or to one or more factors specific to the physical, physiological,\ngenetic, mental, economic, cultural or social identity of that natural person.\n
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1.2. In\norder to perform Our duties under the Customer contract, We will collect\nthe following Personal Data about you:\n
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\n1.2.1. Your\nName, Surname and other personal identification data;\n
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\n1.2.2. Your\nflight information;\n
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\n1.2.3. Your\naccount and banking information necessary to enforce wire transfers;\n
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\n1.2.4. Your\nlocation, if available;\n
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\n1.2.5. Any\nadditional information that you provide about you in the Platform when\nsubmitting information for use of Our services.\n
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\n1.3. The\ndata collected about you is necessary for Refundor to ensure basic functions\nof the Platform as well as to develop its functionality and analyse the use of\nthe Platform to improve your experience when using the Platform.\n
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\n1.4. The\ndata collected about you in the Platform is also summarised into statistics\nthat may be given to third parties. Statistics contain only the criteria and\nnumeral data, therefore, a natural person cannot be identified by the\naforementioned third parties. We do not transfer your Personal Data to third\nparties unless this is required for performance of the Customer contract.\n
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\n1.5. Please\nnote that other users of the Platform cannot see any information provided by\nyou in the Platform.\n
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\n2. How the Data is Collected\n
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\n2.1. We\nmay collect Personal Data from you when you register, input your data in the\nPlatform, otherwise interact with the Platform or provide your data in the\nfollow-up communication.\n
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\n3. Purposes and Basis for Personal Data\nProcessing\n
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\n3.1. By\nusing the Platform you give a freely and informed consent to the processing\nof your Personal Data. You have the right to withdraw your consent at any\ntime in accordance with Clause 5.4 of this Privacy Policy.\n
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\n3.2.\nRefundor processes your Personal Data based on your consent to:\n
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\n3.2.1. fulfil the Customer contract;\n
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\n3.2.2. ensure the possibility to use\nthe functionality of the Platform described in the Customer contract or\nanother relevant document. In cases where you accept the terms of any\nother document, to which you and Refundor are parties, the Personal Data\nis also processed for the performance of the obligations of Refundor and\npursuant to the purposes referred to in such document;\n
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\n3.2.3.\tcommunicate\nand provide additional information that may be of interest to you about\nour services;\n
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\n3.2.4.\tsend\nyou reminders, technical notices, updates, newsletters, security alerts\nand support and administrative messages, service bulletins, or marketing\nmaterials;\n
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\n3.3. Please\nnote that if we do not have your consent for the processing of your data for\nthe aforementioned purposes, we will not be able to fulfil our obligations\nunder the Customer contract.\n
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\n3.4. Refundor\nprocesses your Personal Data based on our legitimate interests (such as business\ndevelopment and development of the Platform functionality) to:\n
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\n3.4.1. operate\nand improve the Platform;\n
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\n3.4.2. evaluate\neligibility of the Users to receive our services;\n
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\n3.4.3. evaluate\nthe type of services that may be of interests to the Users;\n
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\n3.4.4. identify\nthe most active use of our services by location in order to ensure the\nclient-oriented provision of the Services and our business development;\n
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\n3.4.5. perform various analytics;\n
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\n3.4.6. provide\ncustomer support to the Users;\n
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\n3.4.7. fulfil\nrequests related to our services;\n
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\n3.4.8. provide\nthe statistical information to third parties;\n
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\n3.4.9. manage\nour everyday business needs such as the Platform administration,\nanalytics, fraud prevention, or to comply with provisions of the\napplicable law.\n
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\n3.5. Decisions\npursuant Clause 3.4.2. of this Privacy Policy may be automated.\n
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\n3.6. Subject\nto specific statutory requirements, we may provide your Personal Data to\ncorresponding authorities. Please note that if Refundor has an obligation\nto provide your Personal Data to third parties according to the statutory\nrequirements, you will not have the right to request us to stop such\nprocessing of your Personal Data.\n
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\n4. Data Storage and Transfer\n
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\n4.1.\nWe may transfer your Personal Data to such recipients as services providers,\nbusiness partners or adversary third parties, Supervisory authorities,\nincluding but not limited to such recipients:\n
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\n4.1.1.\nState authorities and other authorized parties that may request us to\nprovide your Personal Data subject to specific statutory requirements;\n
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\n4.1.2.\nTechnical services providers such as developers who may access your\nPersonal Data while performing testing or support activities. However, we\nminimize the amount of the Personal Data available to such recipients;\n
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\n4.1.3.\nBusiness partners or adversary third parties of Refundor, where such\ntransfer is necessary for fulfilment of the Customer contracts.\n
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\n4.2. We\nwill only store your Personal Data for as long as it is needed to fulfil the\npurposes for which it was collected, subject to applicable data retention periods\nimposed upon by the applicable legislation as well as until such time as is\nrequired to meet the aforementioned Personal Data processing purposes. If you are\npart in or benefit from Refundor’s affiliation program, we will store your Personal\ndata until your refusal for data processing is received in accordance with\nClause 5.4.\n
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\n4.3.\nThe Data collected from you may be transferred to, and stored at, a\ndestination within the European Union (\"EU\"). It will be processed by data\nprocessors operating within territory of EU.\n
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\n4.4.\nBy submitting your data, you agree to the processing of your data including\nstoring and transfer within the EU for the purposes set out in this Privacy\nPolicy. We will take all steps reasonably necessary to ensure that your\nPersonal Data is treated securely and in accordance with the applicable\ndata protection laws and regulations. We will not store your data longer\nthan necessary to fulfil the purposes set out in this Privacy Policy.\n
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\n4.5.\nAlthough we will do our best to protect your Personal Data, we cannot\nguarantee the security of your data transmitted to the Platform, therefore\nany transmission is at your own risk and you are free to choose whether to\nuse our Platform or not. Once we have received your information, we will use\nstrict procedures and security features to try to prevent unauthorized access.\n
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\n5.\tAccess to Data and Other Rights\n
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\n5.1.\nIf you are a natural person and have provided your personal data to us you\nhave the right to access to your data and to receive the information on: the\npurposes of the processing, the categories of personal data concerned; the\ncategories of recipient to whom the personal data have been or will be\ndisclosed, retention term if applicable, your rights, information on the\nsource from which your personal data was received by us, information on the\nautomated decision-making and profiling.\n
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\n5.2.\nYou also have the right to request a copy of your personal data that we\nprocess. For any further copies requested, we may charge a reasonable fee\nbased on administrative costs.\n
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\n5.3.\nYou have the right to request rectification or erasure of your personal data\nor restriction of processing or to object to processing, to lodge a complaint\nwith a supervisory authority, as well as the right to data portability.\n
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5.4.\nYou are free to refuse from any further processing of your personal data at\nany time by informing us by e-mail:
legal@refundor.com,\nif the processing of your\nPersonal Data is based on your consent as indicated above. Such withdrawal\nwill not affect the lawfulness of processing done before the withdrawal,\nhowever. Withdrawal may impact fulfilment of the Customer contract and you\nmay be held liable for damages suffered by us.\n
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\n6. Third-party Data\n
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\n6.1.\nYou may not upload or otherwise submit to the Platform the personal data of other\nnatural persons.\n
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\n6.2.\nBy accepting this Privacy Policy, you confirm that you understand that you are\ncompletely responsible and liable for the processing of the personal data of such\nthird parties via Platform. Refundor shall be neither responsible nor liable for\nthe personal data of the third parties that you process via Platform.\n
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\n6.3.\nHereby you confirm that you understand that you have the right to use Platform\nfor the processing of the third party’s personal data only if you have a legal\nbasis to carry out such activities with the personal data and if you comply with\nthe requirements of the applicable laws.\n
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\n7. General terms and conditions\n
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\n7.1.\nYou are liable for the appropriate use of our Platform. Any action which causes or could\ncause any disturbance to the operations of Platform is strictly prohibited. You may not\ninterfere into the operations and technical solutions of Platform.\n
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\n7.2\nAll copyrights in or to the Platform or part of them are owned by us, our licensors or\nour partners, who reserved their rights. Any kind of monitoring of the Platform and/or\ncopying, reproducing, usage or republishing of the acquired information, as well as its\ncontents unless it is stated otherwise is strictly prohibited without our prior written\nconsent.\n
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\n7.3.\nWe are entitled to prohibit you the usage of the Platform if there are sufficient\ngrounds to consider that this Policy is not complied with.\n
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\n8. Modification of the Privacy Policy\n
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\nRefundor may revise the terms and conditions of this Privacy Policy at any time\nwithout notice. By using the Platform, you are agreeing to be bound by the current\nversion of this Privacy Policy.\n
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\n9. Governing Law\n
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\nAny disputes arising from this Privacy Policy shall be governed by the laws of\nLatvia and subject to the exclusive jurisdiction of the courts of the Republic\nof Latvia.\n
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\n10. Contact Information\n
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\nIf you have any questions about this Privacy Policy, please contact us\nat:
legal@refundor.com\n
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