1. General provisions
1.1 We, the company TRAVEL POINT ("TRAVEL POINT"), are ready to provide our services to any Internet user. You can use our services by using the website https://travel-point.me/ and this Privacy Policy ("Policy") is an integral part of the agreement on their use.
1.2 To begin with, we want you to understand how TRAVEL POINT works.
The functionality of TRAVEL POINT is built on interaction with a "token", such as BMP-Link or Go-Link. This is the key to the Global Distribution Systems (GDS) store with data about the tickets you have sold. The token is created so that you can transfer your data and their processing to third-party applications. We at TRAVEL POINT use a "token" to keep records of sold tickets in one place, provide invoices to customers, and for mutual settlements with partners.
TRAVEL POINT was created to make life easier for airline managers and to simplify interaction with consolidators.
Is it necessary to use a token in TRAVEL POINT? No, not necessarily. Most functionality will be unavailable. Invoices for payment will need to be requested on your own, you will need to return to the ticket registration plates and keep a calendar, noting who to register when.
Is it possible to disable the download of tickets in TRAVEL POINT? Yes, you can do it yourself or write to support@travel-point.me
Is it possible to delete all user data from TRAVEL POINT? So. If you need to do this, write to support@travel-point.me
1.3 We have developed this Policy to confirm the compliance of TRAVEL POINT with the provisions of the General Data Protection Regulation, i.e. Regulation No. 2016/679 of the European Parliament and the Council of the European Union "On the protection of natural persons during the processing of personal data and the free circulation of such data, as well as on the repeal of Directive 95/46/EU" ("GDPR"), the Law of Ukraine "On the Protection of Personal Data "data" and other legislative acts regulating the procedure for interaction with personal data of Internet users.
1.4 We treat personal data with respect. By using TRAVEL POINT services, you entrust us with your personal information and we do our best to ensure the security of this data while giving you the ability to manage it.
1.5 Please note that the Policy applies to all personal data that you provide to us and that we collect independently in the process of providing TRAVEL POINT services (including using cookies).
1.6 This Policy does not apply to websites that you have accessed via hyperlinks on our website https://travel-point.me/ .
1.7 With this Policy, we want to tell you about:
- who are we;
- how we work with personal data;
- what personal data we collect;
- what is the purpose of personal data processing;
- where and why we transfer personal data;
- how long we store personal data;
- what rights do you have as a subject of personal data;
- how we keep personal data confidential;
- how to contact us.
1.8 For us, the legal basis for processing personal data is, in accordance with Article 6 GDPR, separately or simultaneously:
- consent to the processing of your personal data and personal data of third parties on whose behalf or for whose benefit you act, for the purpose of providing TRAVEL POINT with its services;
- the need to perform a contract to which you are a party or a third party on whose behalf or for whose benefit you are acting;
- the need, at the passenger's request, to take actions necessary for concluding a contract with the carrier.
1.9 The processing of a special category of personal data (for example, health data) will be carried out only if there is an appropriate consent to the processing of your personal data and the personal data of third parties on whose behalf or in whose interests you act, and/or the need for the carriers to provide special services related to the health of the passenger.
1.10 We draw your attention to the fact that you, as a user, are solely responsible for the interaction of TRAVEL POINT with other programs, extensions or applications from other developers, its consistency with the rules and policies, in particular, GDS terminals.
1.11 We reserve the right to make changes to the Privacy Policy at any time and for any reason. The date the Policy was last updated will be indicated in the "Last Updated" line at the bottom of this page.
2. Personal data of third parties
2.1 If you use TRAVEL POINT services on behalf of or for the benefit of third parties (for example, your customers), the information you provide about such third parties is collected and processed by TRAVEL POINT under the same conditions on which your personal data is processed.
3. Consent to the processing of personal data
If, during registration on our website, you checked the box "I agree to the privacy policy" or joined our Sub-Agency Agreement for the provision of intermediary services, the provisions of which are published on the Internet at the link https://travel-point.me/offer , we believe that you:
- you definitely, completely and without any changes accept the terms of this Policy;
- informed that this website may collect your personal data and personal data of third parties on whose behalf or for whose benefit you act, as well as their processing using the technical capabilities of TRAVEL POINT;
- you consent to the collection and processing of all personal data provided by you for the purpose specified in this Policy;
- you consent to the processing of a special category of personal data (for example, health data) regarding you or third parties on whose behalf or in whose interests you act, in case of the need to provide special services directly related to this category of personal data;
- you consent to the processing and international distribution of your personal data and the personal data of third parties on whose behalf or for whose benefit you act, if the conditions of service provision require it;
- you consent to the transfer of personal data to third parties for the purpose of fulfilling the terms of the contract and providing relevant TRAVEL POINT services;
- you give your consent to the collection and storage of your personal data and the personal data of third parties on whose behalf or in whose interests you act, without limitation of validity period, until you or a third party on whose behalf or in whose interests you act do not personally contact a request or wish to stop processing your personal data and/or their destruction, and/or until the moment of termination of the relationship at the initiative of TRAVEL POINT and/or on other grounds in accordance with the provisions of this Policy and the requirements of the law
3.2 By agreeing to the terms of the Policy, you confirm that you are a legally competent person who has reached the age of 16.
3.3 By agreeing to the terms of the Policy, you consent to the processing of your personal data and the personal data of third parties on whose behalf or in whose interests you act, under the conditions specified in this Privacy Policy.
3.4 By providing information about third parties, you confirm that such third party is familiar with the provisions of this Privacy Policy and provides its unconditional and full consent to the collection and processing of personal data in accordance with the terms of this Policy
4. Personal data we collect and process
4.1 We receive and store any information you provide via the https://travel-point.me/ website , report to our support service, provide TRAVEL POINT in any other way to the extent necessary to provide services, improving the quality of such services and fulfilling contractual obligations to you or third parties on whose behalf or in whose interests you act.
4.2 The above information includes:
- information that can be used to identify a natural person who directly uses TRAVEL POINT services, in particular, surname, first name, mobile phone number, e-mail address, name of the company-employer, position;
- information that can be used to identify a passenger, that is, a natural person who is transported by aircraft with the consent of the carrier in accordance with the contract of carriage, and in whose name a ticket (transport document) is issued, in particular, surname, first name, date of birth, gender, citizenship, mobile phone number, postal address, email address, soap card, loyalty card information, visa information;
- data of identity documents, for example, passport number and series, date of issue, validity period;
- technical information, including the Internet Protocol (IP) address used to connect to the Internet, your registration information, browser type and version, time zone, browser plug-in types and versions, operating system and platform;
- profile information (settings, search history, booking and sales history);
- information about your visit, history of visits and movements on our website, history of transition from our site (including date and time), services you viewed or searched for, page response time, loading errors, length of stay on certain pages, information about activity on the page (for example, scrolling, clicking and hovering), ways to leave the page;
- information we need to improve the quality of the TRAVEL POINT service, which is an integral part of providing the service in general, including the information you use when working with cloud distribution systems online after logging into the system;
- information obtained in the process of communicating with you by phone, e-mail, through our website, social networks, support service or in another way;
- information necessary for us to enter into or perform a contract with you or third parties on whose behalf or for whose benefit you act;
- information about transactions with our and your participation, or the participation of third parties on whose behalf or in whose interests you act;
- cookies that are essential and without which the operation of our website is not possible, and cookies that are collected and sent to Amplitude so that we can use their tools to improve the operation of the website;
- Other information that you voluntarily leave on this site.
4.3 If you do not want us to process your personal data or the personal data of third parties on whose behalf or for whose benefit you act, please do not provide us with such information
4.4 We do not collect personal data from persons under the age of 16, they are prohibited from providing information on their own to receive our services. If we learn that personal data is not submitted by one of the child's parents (i.e. a person under 16) or a legal guardian or a user directly authorized by them, we undertake to immediately delete such data.
5. Cookies
5.1 Like most, we use cookies, which are text files containing a small amount of information that are sent to your browser and stored on the computer, mobile phone or other device from which you access the site.
5.2 Information provided by cookies is anonymous. We use it to make our website easier to use by learning about the user during their visit or during a repeat session.
5.3 We inform you that you can block or delete cookies, as well as limit their activity, in your browser settings. The steps required for this may vary in different browsers. Please note that certain pages of our website are only available with the use of cookies. Disabling cookies may limit access to our materials and the website may not function properly.
6. Purpose of personal data processing
6.1 We use your personal data and the personal data of third parties on whose behalf or for whose benefit you act, for the purpose of providing TRAVEL POINT with the highest quality of its services, in particular, but not exclusively, for extracting, preparing, issuing or processing any air ticket, making changes to the ticket, for calculating and returning the ticket, providing EMD services, etc.
6.2 We may also use personal data to provide you with quality responses or other information from TRAVEL POINT based on your inquiries or those of third parties on whose behalf or in whose interests you act.
6.3 Also, the purpose of personal data processing is to use them for marketing and advertising purposes, including direct marketing, market research, and statistics.
6.4 We also use personal data to continuously improve the provision of TRAVEL POINT services, improve your experience using our website https://travel-point.me/ .
7. Transfer of personal data
7.1 Your data may be transferred to third parties only for the purpose of properly providing TRAVEL POINT with its services, which could not be provided without such transfer of your personal data or the personal data of third parties on whose behalf or for whose benefit you act. For example, personal data may be transferred to carriers for issuing tickets (transport documents).
7.2 We may also provide your personal data and the personal data of third parties, on behalf of or in whose interests you act, to persons related to TRAVEL POINT, officials, its representatives, agents, employees or partners of TRAVEL POINT for the purpose of providing you with their services
7.3 TRAVEL POINT uses Amplitude on its website, which is a web analytics tool that helps to understand how visitors interact with this site. Amplitude collects data: about the browser, device type, device model, location, country, city, service provider, screen resolution (mobile), time spent on the site, language, operating system, visited pages on the site. Amplitude uses the information to study site usage, prepare reports on site activity, and offer other additional services. Please note that Amplitude receives your cookies. Without such cookies, Amplitude cannot work. You can read Amplitude's privacy policy on their official website at this link .
7.4 In addition, we may disclose information:
- in response to an executive document, a court summons or a court decision;
- to protect against illegal claims;
- to fulfill other legal requirements;
- in the event that we consider it necessary to respond to illegal actions against us, or to analyze an illegal act, to protect or preserve our rights, property or the safety of TRAVEL POINT.
7.5 In case of transfer of personal data on grounds other than those specified in this Policy, you will be notified of such transfer and you will be able to allow or prohibit us from providing your personal data to a third party.
7.6 When transferring personal data, we always use the safest and most proven ways.
8. Cross-border data transfer
8.1 You agree that in order to provide its services, TRAVEL POINT may store and process personal data, including verifying transactions on servers and resources located outside of Ukraine and the European Economic Area. You give your unconditional consent to the transfer of any or all of your personal data and the data of third parties on whose behalf or for whose benefit you act, outside Ukraine and the European Economic Area only for the purpose of obtaining an appropriate level of services. The storage and processing of your personal data may be carried out on servers and resources owned by TRAVEL POINT or independent contractors, which may be located in any country in the world (for example, USA, Canada).
8.2 If you use this website, you agree to the transfer of your personal data outside Ukraine, the European Union and the European Economic Area. You are informed and agree that your personal data may also be transferred to the USA. Any cross-border transfer of data takes place only to fulfill the conditions of the relevant requests, contracts of this Policy and for the purpose of providing services. All cross-border transfers are limited to those categories of data and recipients that are necessary for the performance of the relevant contracts, provisions of the Policy and provision of services.
9. Term of storage of personal data
9.1 We store your personal data for as long as it is necessary for the above activities. Depending on the purpose for which the data is collected, or whether we have an ongoing legal basis for retaining the data (for example, to fulfill the terms of a contract between us, to provide the services you have requested). Rest assured that if we no longer have a reason or legitimate need to process your personal data, we will delete it or store it in such a way that it can no longer identify you.
9.2 TRAVEL POINT storage of various types of personal data depends on the following factors:
- the purpose of collecting personal data;
- the time it will take to achieve the goal;
- any specific reason or strict legal obligation to keep personal data for a certain period of time.
9.3 If you have an account on our website, we will store personal data such as your email address, first name, last name, company name you work for and mobile phone so that you can log in and access our services for as long as your account exists.
9.4 When determining the terms of storage of personal data, we also take into account the storage time necessary to fulfill our obligations to you or third parties on whose behalf or in whose interests you act, controlling authorities, as well as for the submission of accounting and tax reports.
10. Rights of the user (subject of personal data)
10.1 We respect your rights regarding personal data and promote their implementation. You can contact TRAVEL POINT at the contacts that will be displayed below with a request to exercise your rights. We ensure that the request is fulfilled within a reasonable time, but no later than 1 (one) month from the moment of receiving the request. This term can be extended up to three (three) months, taking into account the complexity or large number of requests from TRAVEL POINT customers. We will notify you in advance about such an extension of the term by e-mail, which address you specified during registration.
10.2 You can exercise the rights to:
- access to information related to the processing of your personal data:
- access to information that is part of the contract between us;
- receiving an electronic copy of personal data that was being processed;
- clarification and/or correction of your personal data, in particular we will notify all persons to whom we have previously transferred your personal data, provided that such notification can be made and does not require a disproportionate effort on our part;
- direct transfer of your personal data from TRAVEL POINT to third parties;
- restrictions, full or partial withdrawal of your consent to the processing of personal data in certain ways;
- destruction of your personal data at your request, or if consent to processing has been withdrawn, or if the need to process your personal data has disappeared.
10.3 If you believe that your rights and/or legitimate interests have been violated, you have the right to file a claim or complaint with a competent public authority.
11. Preservation of confidentiality of personal data
11.1 We adopt a set of technical, organizational and legal measures to protect your personal data from unauthorized or accidental access, collection, storage, use, transmission, blocking or destruction, as well as other unauthorized actions or accidental leakage.
11.2 For example, we provide:
- restrictions and regulation of TRAVEL POINT employees who have access to personal data;
- familiarization of TRAVEL POINT employees with the requirements of the current legislation and normative documents on the processing and protection of personal data;
- accounting and storage of material carriers of information, which makes theft, replacement, unauthorized copying and destruction impossible;
- identification of security threats to the confidentiality of personal data;
- training employees in the use of information protection tools, rules for working with personal data information systems.
- accounting of means of information protection, operational and technical documentation for them;
- monitoring of user actions, consideration of facts of violation of personal data security requirements;
- other measures that contribute to the protection of privacy.
12. Contacts
12.1 You can contact us by sending a message to support@travel-point.me or through TRAVEL POINT's technical support via a live chat on our website.
12.2 You can also send us a letter to the address 03150, Kyiv, st. Velyka Vasylkivska, building 72, office 31, the recipient is TRAVEL POINT GLOBAL Limited Liability Company, legal entity registration code 42896302.
Document version 1.02 dated: 03/01/2023