Users

Whenever you access our website or app, we process your Personal Data for the purposes defined below:

NAME	DESCRIPTION	CATEGORIES OF PERSONAL DATA	LEGAL GROUND
Delivering the functionalities of the website	We will process your Personal Data so that we’re able to deliver you the functionalities of our website and so that we’re able to personalize our website to make your interaction with us easier and more efficient.	Your online behavior while interacting with us Device and network metadata Your settings General location Identification information Information about your Booking(s)	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Delivery of product features).
Delivering the functionalities of the app	For some features of our app, we need to process your Personal Data on our side. We will also process your Personal Data to personalize our app for you to make your interaction with us easier and more efficient. Sometimes, we also need to access some specific data about your device (such as the precise location). We will always ask you whether you agree to share any such data with us when it first becomes relevant (e.g., you open the feature which requires access to additional data).	Contact details Your settings General location Precise location Other data requested by the app Payment data Identification information Information about your Booking(s)	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Delivery of product features). Art. 6.1(a) - consent
Product development, service improvement, and business development	We constantly strive to improve our product and services. To be able to do that, we need precise data about your interactions with us. Therefore, we collect data about the occurrence of any technical issues, data about your device and your network identifiers along with your behavior on our website and in the app and your general use of our services. We analyze all this data and use it to create or modify our features and processes. We use data also to grow our business. Whenever we need to reach a business decision, we look at data that is generated by our most important variable — our customers.	Your online behavior while interacting with us Device and network metadata Information about your Booking(s) Information about your requests and your communication with us	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Improvement of our product and services, Business development).
Kiwi.com Account	If you create a Kiwi.com Account, we will process your Personal Data as necessary to deliver you all the features it includes, in accordance with the Terms of Use. The scope of the processed Personal Data will change depending on what details you decide to save. If you use third party SSO accounts (e.g., Facebook, Google) for signing into your Kiwi.com Account, the account providers are informed about it and we obtain your Personal Data from them. Likewise, if you create your account through a website of some of our partners, we will receive the Personal Data from this partner. We will use the data from your past Bookings to offer you to prefill some of the information for your future Bookings. When making a Booking we can also prefill your Contact information from your Kiwi.com Account. We also use your Personal Data for the purpose of Authentication for Google Play services.	Contact information Account information Identification information Payment information Information about your Booking(s) Kiwi.com Credit & Promo codes Your settings	Art. 6.1(b) - necessity for the conclusion and performance of a contract (Terms of Use).
Direct marketing	To provide you with the best offers and to maximize our marketing efficiency, we process your Personal Data for the purposes of direct marketing (sending commercial communication and related processing activities). We do so if you subscribed to our offers (on the basis of your consent) or if you used our services and have not rejected (opt-out) our offers. Besides your contact details, we also keep data like your transaction and travel history, travel preferences, and other data about your interaction with us that help us with customer segmentation and personalization of these offers. For example, we might tailor a special offer just for you based on your previous Bookings. We will never share your contact details with other Data Controllers without your knowledge, and we will only contact you with offers that are linked to our main business.	Your online behavior while interacting with us Account information Device and network metadata Identification information (if entered into the fields) Contact details (if entered into the fields) Your settings	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Direct marketing). Art 6.1(a) - consent. You can always unsubscribe (exercise your right to object to direct marketing or withdraw your consent) and check your subscription status through the links below every email newsletter that you get from us.
Online advertisement	To provide you with the best offers and to maximize our marketing efficiency, we also display ads on Kiwi.com and third-party websites that are tailored for you based on your Personal Data. It might, therefore, happen that you will see advertisements that offer booking of transportation via Kiwi.com elsewhere on the internet. Advertisement networks. Besides our internal marketing database, we also use various third-party advertisement networks, such as Google Ads. These networks allow us to show you relevant ads on different places around the internet. This is done by assigning you an encrypted identifier and storing it in a cookie on your device. When you go to a website that is served ads via one of the companies working with our partner ad network, they will recognize this identifier and show you offers according to our specifications. Targeting on third-party platforms. To reach our users with our offers, we also use third-party platforms, such as Meta for Business or Google Ads. When you visit our website and book with us, we share an encrypted identifier (e.g. encrypted email address) with these platforms’ providers allowing them to match your profile on these platforms with our records. Because of this, we can show you tailored offers directly on these platforms using their advertising services. So, for example, if you search for a flight on Kiwi.com, don’t buy it, and the price goes down, we might show you an offer for this specific flight on third-party websites. These platforms are: Facebook (Meta for Business) by Meta Platforms Ireland Ltd, Google Search (Google Ads) by Google Ireland Limited, and TikTok by TikTok Technology Limited. If you don’t have a profile on these platforms, they won’t receive any information about you. Lookalike features. Some of the advertisement services which we use, namely Meta for Business and Google Ads, also provide the so-called “lookalike audiences” features. These features allow us to find users who might be interested in our services based on similarities to our existing users. We are then again able to target those users with our offers. This means that if you give us your consent, these services will analyze your profiles and find us other profiles based on common attributes. When using these features, we never gain direct access to any personal data or the profiles - this is all done by the service providers in the background and we only get the option to target our ads to a wider audience.	Your online behavior while interacting with us Account information Device and network metadata Your settings	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Direct marketing).
Marketing analytics	To improve our marketing campaigns in general, we perform analyses to help us see which campaigns work and how they contribute to our conversion rates. Additionally, we analyze your interactions with Kiwi.com to send you offers that will be relevant for you.	Your online behavior while interacting with us Device and network metadata General location	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Direct marketing).
Establishment and exercise of legal claims and defence against them	To be able to exercise our legal claims arising out of your use of our website/app in breach of our Terms of Use or use in breach of some statutory obligation and to be able to defend ourselves against legal claims raised by you, we will store your Personal Data for at least 4 years from the point of your use of the website / app.	Identification information Your online behavior while interacting with us Device and network metadata Account information Contact details (if entered into the fields) Your settings	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Protection of our legal rights).
Information security	To protect ourselves against various security threats that try to exploit vulnerabilities in our security and hurt our business, and to protect our users against unauthorized use of Kiwi.com Accounts, we need to process Personal Data of our users. To this end, we collect and process the Personal Data of our users and, in some cases, also share it with the providers of our third-party information security solutions, such as CloudFlare. We also process your Personal Data so we are able to show you and allow you to stop your active sessions - Account Takeover (ATO) Protection.	Your online behavior while interacting with us Device and network metadata	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com and our users (Security).
Collection and assessment of feedback	Sometimes we ask you to rate your experience with Kiwi.com, provide us with your feedback, or leave a review on a third-party customer review website. We will store and evaluate all this data in order to improve our product and services.	Identification information Contact details Reviews & feedback	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Improvement of product and services).

Customers

When you order any of our services, we will continue to process your Personal Data for the purposes explained above. The scope of the processed Personal Data for these purposes will, however, also include the Information about your Booking(s) and Information about your requests and your communication with us. Besides this, we will process your Personal Data for the following purposes:

NAME	DESCRIPTION	CATEGORIES OF PERSONAL DATA	LEGAL GROUND
Ordering & Provision of services	The main reason we collect and use your Personal Data is to conclude an agreement with you and to provide you the services you have ordered. Depending on the extent to which you use our services, we will process your Personal Data in a way that is necessary to enter into and fulfill our Agreement as described in our Terms & Conditions. The services that we provide include, primarily, the brokering of a contract of carriage and related services between you and the selected carrier. We may also process your Personal Data for this purpose when providing you with the service of enforcement of your claims against carriers. To achieve this purpose, we need to share your Personal Data with the carriers with whom you will enter into a contract of carriage and, in some cases, also with operators of ticket marketplaces, such as the Global Distribution Systems. Additionally, to pay for the tickets, we will use your name and surname to generate a single-use virtual payment card, which we use for the financial settlement with the transport provider. If you order additional service Special assistance or when you ask us for a refund due to health issues, we will process your Personal Data concerning health. In the case of the Special assistance service, we will share it with the carrier of your choice. During the ordering process, you will be asked to give your explicit consent with the processing of this Personal Data. You can always withdraw your consent through this form: www.kiwi.com/privacy/rights. However, please note that if you withdraw the consent with the processing of your Personal Data for the purpose of the Special Assistance additional service, we won’t be able to provide you with any subsequent support related to this service. It may also happen that you choose to order another service that we or our partners offer on our website or in our app, such as insurance or accommodation. We will process your Personal Data as required to enter into a contract with you and to provide you with the ordered service or (if the service is provided by our partner) to enable you to enter into the contract with the service provider and to do our part in the contractual relationship between you and the third-party service provider.	Identification information Contact information Information about your Booking(s) Passport or ID card information Passport or ID card copy Payment information Documents necessary to be provided with the brokered service	Art. 6.1(b) - necessity for the conclusion and performance of a contract (Terms and Conditions).
Fraud prevention	When you book a ticket or order any other service through our website or app, during the payment transaction, we use a third-party service that helps us prevent fraudulent behavior. This is a very common process that happens nearly every time you order something online. For this to be possible, we will transfer your Personal Data momentarily to a third-party provider of fraud-checking service. However, this is not something to worry about, the whole transaction is completely secure, and we use one of the best and most common fraud-prevention tools. These third-party service providers (currently we use products from Forter, Inc. and Signifyd, Inc.) use the Personal Data, which they collect to build a database of online fraudulent behavior. They then compare this database with the behavior of the end-users of their clients. Whenever they detect similar behavioral signs, they can tell the clients to reject payments done by fraudsters. Furthermore, to prevent attempts for fraudulent chargebacks, if you report fraudulent purchase through your bank, we might check your social media to see, whether you have some sort of connection to the person who ordered the ticket to make sure that it is not an attempt to get the money for the ticket back by fraud. We will only process limited information about your connection to the person, who ordered the ticket, and whether you, by any chance, have not published some information connected to the journey (e.g., photos from the airport taking a flight). To enhance our fraud prevention measures, we may also share information about your transaction with the bank associated with the card used for payment.	Identification information Contact information Information about your Booking(s) Payment information Your online behavior while interacting with us Device and network information Publicly available information related to your Booking	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com and the e-commerce industry in general (Fraud prevention).
Customer support	Customer support is a big part of our services. We will record all of our communication through all channels, such as email, chat, and phone calls, in order to provide you with the service that you require. Part of our customer support is also helping our customers with potential legal issues with the carriers (in case of missed flights and similar situations). For this, we have partnered with a third-party service provider. When you have a legal problem, we will send this provider your email address, and you will be contacted with an offer to help you exercise your claims. We also use third-party AI services to help our agents with the resolution of your cases. For example, when you contact us, we may use these tools to summarize the previous communication between you and other agents to have a quick overview of the case’s history. For certain requests, our AI assistant may provide an immediate response. In such cases, you will always be informed about the AI assistant’s involvement. If any action is taken by the AI assistant based on your request, you will be asked to confirm that action before it is finalized.	Identification information Contact information Information about your Booking(s) Passport or ID card information Passport or ID card copy Information about your requests and your communication with us	Art. 6.1(b) - necessity for the conclusion and performance of a contract (Terms and Conditions).
Sharing information with metasearch engines	If you get to our booking page through a third-party search engine (so-called metasearch), we will let the operator of this metasearch know that you have successfully finished the booking, which you have found on their site.	Contact details Information about your Booking(s)	Art. 6.1(f) - necessity for the purposes of legitimate interest of the metasearch (Business operations).
Establishment and exercise of legal claims and defense against them	We store and process your Personal Data to establish and exercise legal claims, or defend against them. Whenever you book a ticket or order any other service, we will keep all relevant data for potential future legal claims that you or we could have, especially in judicial and other proceedings and when recovering or selling claims you assigned to us, for at least 4 years from the point of the creation of the corresponding order. Similarly, if you send us a data protection request, we will also store all the data you give us and the data about our handling of the request for this purpose.	Identification information Contact information Information about your Booking(s) Passport or ID card information Payment information Your online behavior while interacting with us Device and network information Publicly available information related to your Booking Information about your requests and your communication with us	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Protection of our legal rights).
Compliance with legal obligations	We need to process some of your Personal Data to fulfill certain legal obligations that are applicable to us. Because this is a legal necessity, we do not need to obtain your consent for it. For this purpose, we will process your identification and contact information and information about your bookings. The main legal obligations we need to do this for arise from Act No. 89/2012 Coll, the Civil Code, Act No. 634/1992 Coll, on the protection of consumers, Act No. 235/2004 Coll, on Value Added Tax and Act. 563/1991 Coll, on Accounting. If you send us a data protection request to fulfill one of your rights, we will ask you for some personal data which we will then process to achieve compliance with the applicable law.	Information about your Booking(s) Information about your requests and your communication with us	Art. 6.1(c) - necessity for compliance with legal obligations to which Kiwi.com is subject.
Collection and publication of reviews	We ask you to rate your experience with Kiwi.com and provide us with your feedback. Occasionally, we may publish your feedback on our website. However, if we do so, we will not publish your full name or any other identifying details.	Identification information Contact details Information about your Booking(s) Reviews & feedback	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Marketing).
Kiwi.com Club	If you become a Kiwi.com Club member, we will process your Personal Data as necessary to deliver you all the features the membership includes, in accordance with the Terms of Kiwi.com Club.	Contact information Account information Identification information Information about your Booking(s) Kiwi.com Credit & Promo codes	Art. 6.1(b) - necessity for the conclusion and performance of a contract (Terms of Kiwi.com Club).
Execution of selected local payment methods (payer ID)	When you choose certain local payment methods in Argentina, Brazil, or South Africa, we may need your local identification number (and, where applicable, document expiration date) to process and settle the payment in line with local requirements. Where feasible, these data are collected directly by our payment partner in a secure hosted field; if we collect them, we transmit them to our payment partner.	Local payer ID for selected payment methods; Identification and Contact information	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (enabling the chosen payment method).
Payment settlement verification with payment providers (Revolut Pay)	For transactions paid via Revolut Pay, we share a minimal proof‑of‑fulfilment dataset with Revolut to verify that services were supplied and to reduce settlement reserve/holdback.	Information about your Booking(s) (PNR number)	Art. 6.1(f) GDPR (legitimate interests in payment risk management and settlement verification)

Co-travelers

If someone orders a service from Kiwi.com for you (for example, books a flight ticket with your name), we will process your Personal Data, even if you’re not a direct customer. Your Personal Data will be processed for the following purposes:

NAME	DESCRIPTION	CATEGORIES OF PERSONAL DATA	LEGAL GROUND
Ordering & Provision of services	If someone orders our services for you, we will process your Personal Data as necessary for the provision of this service.	Identification information Contact information Information about your Booking(s) Passport or ID card information Passport or ID card copy	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Provision of services).
User account — saved traveler	When someone orders service for you and has a Kiwi.com Account, we will offer them to store your Personal Data for the easier ordering of other services for you in the future. If we are provided with your email, we will send you information about this and in case you disagree, you may choose to delete your data.	Identification information Contact information Passport or ID card information	Art. 6.1(f) - necessity for the purposes of your legitimate interest (Simplification of future bookings).
Establishment and exercise of legal claims and defense against them	To be able to defend ourselves against legal claims raised by you in connection with our provision of the services, we will store your Personal Data for at least 4 years from the point of the creation of the corresponding Booking.	Identification information Contact information Information about your Booking(s) Passport or ID card information	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Protection of our legal rights).
Delivering the functionalities of the website and the app	If someone interacts with the website or the app to order services for you, we will process your Personal Data so that we’re able to personalize our website or app for this person to make their interaction with us easier and more efficient. For example, we can personalize the booking process when we know that you travel as a group.	Identification information Information about your Booking(s)	Art. 6.1(f) - necessity for the purposes of legitimate interest of Kiwi.com (Delivery of product features).

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