We, as the Data Controller, are the company Kiwi.com, Inc., with a registered office at 1209 Orange Street, Wilmington Delaware, 19801, Tax Id. 32-0468201.
Personal Data: any information relating to a directly or indirectly identified or identifiable natural person. That means that if we possess means to identify either you or even the device you're using, any information that we can connect to you will be treated as Personal Data.
Data Processor: a third party that only helps to achieve the purposes determined by the Data Controller. For example, we as a Data Controller use many third-party services to which we outsource some parts of our activities that we don’t do ourselves for various reasons such as cost efficiency. A Data Processor is only allowed to process your Personal Data according to our documented instructions.
CCPA: California Consumer Privacy Act which applies to you if you are Californian. The CCPA sets the highest privacy and data protection standards in the United States.
For every purpose for which we need your Personal Data, we only process data that are necessary for us to fulfil it. We collect your Personal Data directly from you, either when you provide us your Personal Data or gather them by ourselves when you use our services or you are in touch with us. Depending on the given purpose, we may process:
Mainly your name, surname, nationality, IP address, ID number, and other identification information that you might give us. Additionally, we will assign you some unique identifiers for our use, such as the booking ID or, in some cases, unique promotional codes.
Your email address, phone number and other contact details that you might give us in non-standard situations.
We will remember what choices you make so that we can apply the same settings when you come back to us. If, for example, you decide to opt-out of using cookies for some reason, we will try to remember that and make sure we don't store those cookies during your next visit to our website.
We will gather data about the order itself and its payment and we will keep your past orders for the purposes of the Provision of our services, and to a limited extent, for Marketing purposes also (we will never use any data about your payment for Marketing purposes).
When you use our website or mobile application, we track what you do on it and use this for the purposes of Improving our services mainly to enhance the user experience. We may also use this data to resolve your complaints as part of our customer support services. For example, we monitor which pages you visit, what you click or tap on, or where your cursor is, and based on this, we analyse if certain features on our website or mobile application need improvement. Also, we remember some info that you fill into our booking forms for the purpose of reminding you that the order wasn't actually completed as a part of the purpose of sending personalized offers.
If you book a ticket or order other service, we will gather some data about you so that we can tailor our offers just for you and your needs. This includes information about your device (software and hardware), your IP address, general information about your location (such as timezone or general area), identification and contact information.
When you send us email, contact us through chat or when you call us, we will store your contact details, booking ID and all the information that you give us during the contact, including the messages or the call itself. We will then use it to:
The main reason we collect and use your Personal Data is to conclude an agreement with you and then to provide you the services that you’ve ordered. Depending on the extent in which you use our services, we will process your identification information, your contact details and data about what you have ordered in a way that is necessary to enter into and fulfill our Service Agreement as described in Article 2 of 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 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 Networks. 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 to get a refund due to health issues, we will process your Personal Data concerning health and in case of the Special assistance service, we will share it with the air carrier of your choice. During the ordering process, you will be asked to give your explicit consent with the processing of this Personal Data.
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 identification information, your contact details and data about what you have ordered 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.
Customer support is a huge part of our services. When providing you with our customer support, we process your identification information, your contact details, data about what you have ordered, information that we collect when you contact us, information about the solution of your customer support request, and also the recordings all of our communication through all channels, such as email, chat and phone calls. 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. You can learn more about the sharing of your personal data with third-party data controllers here.
If you used our service through one of our partners' websites to order a transport ticket, we shall inform the partner about any emergency that might impact your journey, such as a natural disaster or bankruptcy of the transport provider. This is to ensure that the information reaches you as promptly as possible. That way, if you reach out to the partner with a question or complaint, they will be able to help you without having to refer you to our customer support.
If you want to register a Kiwi.com account, we need to process your identification information, your contact details, your settings and data about your past orders. The names of the co-travelers (i.e. the travelers for whom the ticket is bought by someone else) are processed based on your legitimate interest to make future bookings of services easier by saving them to your Kiwi.com account.
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 behaviour. This is a very common process that happens nearly every time you order something online. For this to be possible, we will transfer your identification information, your contact details, your settings, data about what you have ordered and data about what did on our website / mobile application momentarily to a third-party Data Processor. 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. You can learn more about the Data Processors we use here. 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 haven’t published some information connected to the journey (e.g. photos from the airport taking a flight).
To provide you with the best offers and to maximise our marketing efficiency, we process your Personal Data for the purposes of direct marketing (email offers and related processing activities). 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 personalisation of these offers. For example, we might tailor a special offer just for you based on your previous orders.
Additionally, when you provide your information during the booking process or while ordering another service, we may send you an email to remind you of any unfinished orders that are still incomplete. We will only keep your Personal Data collected in this way for 30 days.
At any time, you can object to this and we will immediately cease to process your Personal Data for this purpose. However, this means that we will no longer be able to send you any offers.
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. You can always unsubscribe and check your subscription status through the links below every newsletter that you get from us.
To improve our marketing campaigns in general, we also use your contact details, data about what you have ordered and data about what did on our website / mobile application to perform analysis to help us see which campaigns work and how they contribute to our conversion rates. To secure the maximum effectiveness and best outcomes of such analysis, we use third-party Data Processors. In all cases, we remain the Data Controllers of your Personal Data and these third parties can only use them to fulfil our purposes.
We want to make sure that you don’t miss out any special offers that we have. Because of this, we send website and app push notifications (with your consent) and we also display ads on Kiwi.com and third-party websites that are tailored for you according to your past orders. It might therefore happen that you’ll see ads offering booking of transportation via Kiwi.com elsewhere on the internet. For this purpose we process data about what you have ordered, your settings, data about what did on our website / mobile application and info that we need to make our offers relevant to you.
If you have a friend with a Kiwi.com account, it may happen that he/she will refer you to us and provide us with your email address even if you have never visited our website or even heard about Kiwi.com before. You will then get an informational email with a link. If you use it to make a booking on our website, both you and your friend will get a financial reward in the form of credit that can be used as discount when paying for tickets or services. For this purpose we process data identification information, contact details and settings of person who refers a friend to us and the email address of the referred person.
If you give us your consent (opt-in), we’ll share data about what you have ordered and data about what did on our website / mobile application with our partners. These partners use this data to create a profile containing your preferences for the purposes of showing you relevant third-party ads. We will never share any data which would allow your direct identification with these partners. These profiles created by our partners therefore do not contain any information which could be connected to you as an individual. It can only be connected to your device based on an artificially created identifier saved in a cookie on your device. Any sort of connection to your device may therefore be prevented by deleting this cookie.
Along with using cookies to share this information with our partners, we also use the technologies of pixel tags and app events.
For this purpose, we process your Personal Data based on consent. You may instruct us to Do Not Sell Your Info and thereby exercise you right to opt-out from selling of your Personal Data under CCPA by turning off the “Third-party marketing cookies” in your cookies preferences here.
As with any other business, to improve the way we do things, we need some data about you, our customers. To this end we use third-party services that allow us to record and analyse your behaviour. Thanks to this, we can see trends and patterns which help us improve many areas of our business activities. For this purpose we process your identification information, contact details, settings, information about your past orders and information about what you did on our website / mobile application.
If you call us on our customer support line or contact us through email or chat, we will record the phone call or the messages for the purpose of improving our services. These recordings will be then sorted, and we will only keep those in which our staff made some sort of mistake when dealing with your requests. These recordings are subsequently used during training sessions so that we can make sure these mistakes don't happen again.
We also store and process your identification information, your contact details, data about what you have ordered, data about your interaction with our website and services, and information that we collect when you contact us for the purpose of establishing, exercising or defending legal claims. 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. Similarly, if you send us a data protection request, we will also be storing all the data you give us and the data about our handling of the request for this purpose.
Generally, we will keep your data for this purpose for 4 years. We will never use your Personal Data for any other purpose when it is stored solely for this purpose.
We need to process some of your Personal Data to be able to fulfil certain legal obligations that are applicable to us. Because this is a legal necessity, we don't need to obtain your consent for it. For this purpose, we will process your identification and contact information and information about your bookings.
In general, we will process your Personal Data until we won't need it for any of these purposes. The maximum data retention length will generally be 4 years.
We want you to always be in control of your Personal Data. To this end, you have certain rights that allow for it. Under certain conditions, you may:
You can exercise your rights by sending us an email with your request through this form: kiwi.com/privacy/rights.
Please note, that in order to ensure the safety of your Personal Data, we will only comply with the requests that are sent from the email address used during the booking or ordering of a service. If someone else did the booking for you, we will request that you provide additional information to us (Booking ID, etc) to ensure that you are really the owner of the Personal Data in concern.
At any time, you have the right to ask us whether we process your Personal Data and to get the following information:
Also, on your request, we will provide you with a full copy of all the Personal Data about you that we’re processing. The first copy is for free. If you are Californian we will provide you with first two copies in a 12-month period for free. However, for any further copies we may charge you a fee to cover our administrative costs.
You can also request your data in a commonly used format for the sake of data portability.
Under CCPA (if you are Californian), you may also ask for above stated information about any sales of your Personal Data to third parties.
You have also the right to have your data completely deleted (or more precisely, irreversibly anonymised) if one of the following situations applies to you:
However, you don't have the right to request the deletion of your Personal data, if the processing is necessary for:
If you are Californian, we will delete your Personal Data if requested unless we need to process your Personal Data in order to:
If you feel that any Personal Data that we're processing about you is not accurate, you can let us know and we will do our best to correct it.
Please note, that we cannot correct the data in our databases that are connected to your ticket. If we would do that, it wouldn't change it on the part of the carriers or providers of other services and we couldn't pair it together. If you want to change the details on your ticket, you can always do it in the Manage My Booking section on Kiwi.com.
Under certain conditions, we will restrict the processing of your Personal Data. This means that we will make sure that they are not being processed for any other purpose than to archive it or to move it to a secure archive. You have the right to request this restriction if:
You can object against any purpose for which we're processing your Personal Data based on the legal ground of legitimate interest. When you object against processing for any Marketing purposes, we will stop using your Personal Data for this purpose immediately.
If you protest against any other purpose based on a legitimate interest, we will stop processing your Personal Data for this purpose, unless we can prove that our legitimate grounds for processing it override your individual interests, rights and freedoms.
Lastly, you have the right to obtain your Personal Data processed in a commonly used and machine-readable format and have the right to transmit that data to another controller of your choice.
We will never discriminate against you or treat you unfavourably because you exercised any of your rights under CCPA, including, but not limited to, by denying goods or services, charging different prices or rates for or providing a different level or quality of goods or services, or by suggesting that you will receive a different price or rate for or a different level or quality of goods or services.
For all matters concerning privacy and data protection, you can always contact us through this form: kiwi.com/privacy/questions. To exercise your rights under the GDPR, you can use this form: kiwi.com/privacy/rights.
With regard to all issues related to processing of your Personal Data including the exercise of your rights, you may always contact our Data Protection Officer.
See the contact details.
Data Protection Officer of Kiwi.com