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Privacy Policy

updated from 08.2024

Introduction

Travel Center “TRIME” is committed to respecting your privacy and protecting your personal information. We attach particular importance to protecting the personal information that you share with us and strive to maintain your trust in this regard.

Our Commitment

We have developed and implemented internal policies and procedures designed to provide adequate protection of personal information, and we review these regularly.

We educate our employees about protecting personal information by providing training on this topic and issuing directives outlining their roles and obligations.

We take reasonable measures to ensure that our agents, mandataries, representatives, and employees comply with the provisions of the privacy protection legislation in force.

Scope of Application

This Privacy Policy (hereinafter the “Policy”) applies to all personal information we process about you when you do business with us, purchase or use our services, visit our website, or otherwise interact with us. This Policy was developed to comply with the requirements of the privacy protection legislation in force. Our full Policy can be accessed below.

What is Personal Information?

Personal information is any information that identifies you or can be used to identify you. Your personal information may include, for example, your name, your contact details, or information relating to your travel itinerary (e.g., your booking reference number). This information may be collected from you during any interactions you have with us, for example when you visit our website, make a booking, call us or send us an email, or enter a contest. This information may also come from travel counsellors.

What Personal Information Do We Collect?

We may collect and process the following categories of personal information:

  • Identification: Name, date of birth, gender, nationality, and passport number. If your minor children are included in the booking, we will collect their identification information.
  • Contact Information: Telephone number, physical address, and email address.
  • Booking Details: Date of travel, flight reservations, hotel reservations, payment details, and any ancillary services such as upgrades and extra baggage.
  • Travel Details: Travel itinerary, check-in information, electronic boarding pass, medical needs, special dietary requirements, and any additional assistance or preferences.
  • Interactions: Communications via email, online, or social media, including any attachments such as pictures and/or videos. Telephone calls may be recorded for training purposes or to prevent fraud.
  • Previous Bookings: Information about services we have provided to you in the past, including your previous travel arrangements (flights and other bookings), interactions, and customer feedback.
  • Website Usage: IP address, browser type, operating systems, referring website, preferred language, web-browsing behavior, universally unique identifier (UUID), and app use. We may also receive your location data.
  • Social Media: Information entered during contests or comments shared on our social media platforms.
  • Sensitive Personal Information: Information that reveals racial or ethnic origin, physical or mental health, religious beliefs, or criminal convictions or offenses. Explicit consent is required for processing this information.
  • Third Party bookings A third-party booking is when a family member, friend or another person (hereinafter the “Third Party”) makes a booking on your behalf. This Third Party will necessarily provide us with the same personal information that we would collect from you directly in order to complete your booking. In such circumstances, the Third Party will have ensured that you have been made aware of the content of this Policy and that you consent to supply your personal information to us.

 

How Do We Use Your Personal Information?

We use your personal information for the following purposes:

  • To Provide Services: Process and manage your booking and travel arrangements and purchases. For example, to identify you in order to issue your ticket, ensure specified dietary requirements are met, and inform the flight crew of any special services purchased.
  • To Communicate and Keep You Informed: Contact you by email and/or telephone for administrative or operational reasons. For example, to send confirmation of bookings and payments, inform you about your travel itinerary, notify you of check-in availability or flight changes, etc. We may also use your contact information for commercial prospecting and to send you marketing communications, if you agreed to receive such communications.
  • To Personalize and Improve Your Customer Experience: Use communications exchanged with us and information about how you use our website to improve our products and services and ensure that you receive relevant commercial communications.
  • To Improve Your Experience on Our Website: Use personal information about your website use through cookies and other technologies to track and analyze usage, improve relevance, measure advertisement effectiveness, conduct research, and customize marketing communications.

 

What is Our Legal Basis for Processing Your Information?

The legal basis for processing your information will depend on the reasons your information was collected. We will only process your personal information where we have a legal basis to do so. According to privacy laws, the legal basis for processing your information may be:

  • To process and manage your booking, fulfill your travel arrangements, and otherwise perform the contract we have with you.
  • To comply with a legal obligation.
  • Because you have consented to us using your information for a particular purpose.
  • Because it is in our legitimate interest to use your personal information, in particular, to enhance and improve our products and services, personalize our offers, develop new products, and prevent fraud.

 

How Long Do We Retain Your Personal Information?

We will only keep your information for as long as we reasonably need it for the purpose it is being collected or processed for in accordance with this Policy or to comply with the law. We will actively review the information we hold and delete it securely or anonymize it when there is no longer a legal, business, or customer need for it to be retained.

Data Sharing and Disclosure

To ensure that we can provide you with the services you have requested from us, we may need to disclose your personal information to trusted third parties, including:

  • Regulatory Authorities and Law Enforcement Agencies: Such as immigration, customs, airport authorities, and border security control, for legal compliance and to ensure the safety of our customers, passengers, and employees. In accordance with applicable laws, reservation, checking, and boarding data collected from passengers (PNR/API) may be transmitted to national public services and competent authorities of a particular country.
  • Service Providers: Such as reservation agents, catering agents, travel service providers, freight providers, car rental, hotel providers, or airport ground handling services to facilitate your travel and any other requests you have made.
  • Other Passengers: Named on your booking as part of the online check-in process.
  • Technology Service Providers: Whose systems we may use to process your booking and travel, enhance your customer experience, conduct customer surveys, or provide you with personalized marketing communications on our behalf.
  • Forensic and Investigatory Service Providers: For investigating a data breach or incident.
  • Affiliates or Their Service Providers: As part of providing the travel services or offering you ancillary products.
  • Third-Party Vendors: Who provide services or functions on our behalf, including credit card processing, business analytics, customer service, distribution of newsletters or surveys, and fraud prevention. Upon direction by your employer, we may also share your personal information with third-party vendors providing services such as expense tracking and reimbursement. These companies have access to personal information needed to perform their functions but are not permitted to share or use the information for any other purpose.
  • Corporate Affiliates: For hosting, storage, analytics, and reporting purposes, so that we and our affiliates may operate, analyze, and improve our services. Corporate affiliates accessing your information will follow practices that are at least as restrictive as those described in this Privacy Statement.
  • Legal and Compliance: In response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required or permitted by applicable law. We may also share your data when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, to protect and defend our rights, property, or safety, and in connection with our Terms of Service and other agreements.
  • Law Enforcement and Government Agencies: For security, customs, and immigration purposes. Under Ukrainian law, as well as international agreements, we may be required to provide certain travel and reservation information to law enforcement agencies. For example, the U.S. Department of Homeland Security Bureau of Customs and Border Protection requires Passenger Name Record (PNR) data for travelers to or from the U.S.A. We may disclose this information to airlines or other travel providers so they can forward it to the relevant authorities.
  • Corporate Transactions: In connection with a proposed or completed corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy.

 

We may also share your information:

  • When it has been explicitly requested by you.
  • When it is necessary to comply with legal obligations, a court order, or regulatory requirements.

 

Data Security

We implement robust security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security practices include encryption, access controls, and regular security audits.

Direct-Marketing Data Protection Notice

We may use your personal contact information (name, surname, email, company name, job title, country of residence) to send you direct-marketing communications.

When you receive a direct-marketing communication from us, it is either because you or your company on your behalf have requested such communication, or because we believe the communication is of interest to you or your company based on the services we provide to you and your company.

In some cases, we will have collected your contact details from publicly available sources or through a third party with whom you or your company on your behalf have agreed onward sharing.

We rely on our legitimate interests to keep you informed about our products and services. However, if you no longer wish to receive direct-marketing communications, you can click on the ‘unsubscribe’ link at the bottom of the communication. In these cases, your contact details will no longer be used in that regard.

Where we engage third-party sub-contractors to manage our marketing campaigns, they do so on our behalf and under our instructions. We ensure they commit to complying with our policies and applicable privacy laws and do not use your data for any other purposes.

Travel Center “TRIME” shall retain your information so long as you wish to keep receiving our direct-marketing communications and/or to comply with legal obligations, a court order, or regulatory requirements, and to fulfil your request to ‘unsubscribe’ from marketing communications.

Use of Client Logos

With your consent, we may use your company’s logo in our marketing materials, including on our website, brochures, and presentations, to highlight the services we provide to our clients. This usage is intended to showcase our portfolio and the trust placed in us by reputable organizations. If at any time you wish for us to stop using your logo, please contact us, and we will promptly remove it from all our marketing materials.

Your Rights

  • Access and Rectification: You have the right to access your personal data held by us and request corrections of any inaccurate or incomplete data. Accessing the personal information contained in your file and rectifying such personal information is free of charge. At any time, you may request that the appropriate corrections be made to the personal information that we hold about you. If applicable, we will forward the amended information to the third parties that have access to your personal information.
  • Withdrawal of Consent: You have the right to withdraw your consent to the processing of your personal information. When we process your information based on consent you have previously given, you may withdraw said consent at any time.
  • EEA Residents’ Rights: If you reside in a member state of the European Economic Area (EEA), you shall have the right to erasure, restriction of processing, objection on legitimate grounds to processing, and data portability, as described in the GDPR. A small fee may be required, upon notice from us, to cover the administrative costs of processing such requests.
  • Lodging a Complaint: You may also lodge a complaint with the competent Supervisory Authority to enforce your rights, notably under the GDPR.

 

To exercise these rights, please contact us at privacy@trime.ua.

Changes to this Privacy Statement

This Policy is subject to amendment to account for the rapid evolution of the rules pertaining to the protection of personal information and privacy. Any new version will automatically come into effect as soon as it is published. Therefore, please visit our website regularly for any modifications.

Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Email: privacy@trime.ua

By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your personal data as described.

This Privacy Policy is designed to provide clarity and transparency regarding how we handle your personal data. Should you need further assistance or detailed legal advice, please consult with a legal professional.