Privacy policy

Introduction

Duffel Technology Limited, a company incorporated and registered in England and Wales with company number 11188295, whose registered office is situated at 3rd Floor, 100 Clifton Street, London, EC2A 4TP, United Kingdom ("the company", "we", "us" or "our" in this Privacy Policy) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over email, the telephone) and tell you about your privacy rights and how the law protects you.

Please also refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this Privacy Policy that you are unfamiliar with.

• 1. overview
• 2. the data we collect
• 3. how your personal data is collected
• 4. how we use your personal data
• 5. disclosure of your personal data
• 6. international data transfer
• 7. data security
• 8. data retention
• 9. your legal rights
• 10. glossary

1. Overview

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Duffel collects and processes your personal data, including any data you may provide through this website when you browse, sign up for an account, or when using the services.

It is important that you read this Privacy Policy together with our Data Processing Addendum and any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Data Controller

Duffel Technology is the controller and responsible for your personal data.

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review and may make changes from time to time to reflect new services, changes in laws and/or our practices. Please refer to the “Last Updated” banner at the beginning of this Policy for details of when we have made changes to our Privacy Policy. Any changes are effective from when we post the revised version of our Privacy Policy. If we are required by Law to notify you prior to making any changes to our Privacy Policy we will provide such notice. This version and historic versions can be obtained by emailing us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

This website and our services are not intended for minors and the only circumstances in which we collect data relating to them is where they are part of an order for travel services.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(A) Identity Data

This includes data relating specifically to your identity, such as your given name, family name, username or similar identifier, title, date of birth and gender.

(B) Contact Data

This includes data relating specifically to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

(C) Financial & Governmental Data

This includes data relating to your means and methods of payment, such as your bank account and payment card details (card number, CVC, expiration date). As part of our Know Your Customer processes we ask you to provide certain financial information related to your business and also government identifiers associated with you and your organization (such as your social security number, tax number, or Employer Identification Number).

(D) Transaction Data

This includes data relating to the transactions you have carried out with us, such as details about deposits, orders, cancellations/refunds and payments to and from you and other details of the services we provide to you.

(E) Technical Data

This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, device information, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

(F) Profile Data

This includes the data that we receive when you sign-up via our website, add your team (additional account users) and create your Duffel Account, such as your username and password, orders made by you, your interests, preferences, feedback and survey responses.

(G) Usage Data

This includes information about how you use our website, products and services.

(H) Marketing and Communications Data

This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of our Services Agreement with you and you fail to provide that data when requested, we may not be able to perform our obligations or provide our services to you.

In other words, where we require details from you in order to provide you the services, if you do not provide us with the necessary details then we will not be able to provide such services for example completing a flight order.

In this case, depending upon when you fail to provide the necessary data, we may not be able to provide you with the services.

3. How Your Personal Data is Collected

We use different methods to collect data from and about you including through:

(A) Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on our Platform;
• add your employees, contractors, affiliates to your Duffel Account;
• make a booking of travel services;
• subscribe to our newsletter or other publications;
• request marketing to be sent to you.

(B) Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies.

(C) Third parties

We may collect or receive personal data about you from various third parties.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to we need to perform our obligations and deliver our services to you as described in our Services Agreement.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal, financial or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity	Purpose/Activity	Purpose/Activity
To register you as a new customer & complete our onboarding & KYC processes.	(a) Identity; (b) Contact; (c)Financial & Governmental Data.	Performance of our services; Necessary for our legitimate interests (to keep our records updated).
To process and deliver your booking including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us; (c) To return funds to you in the instance of cancellations, refunds or price adjustments etc.	(a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing Communications.	Performance of our services; Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy; (b) Asking you to leave a review or take a survey. (c) To participate in product demonstrations & to provide feedback on new features	(a) Identity; (b) Contact; (c) Profile; (d) Marketing Communications.	Performance of our services; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity; (b) Contact; (c) Technical.	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity; (b) Contact; (c) Profile; (d) Usage; (e)Marketing Communications; (f) Technical.	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	(a) Technical; (b) Usage.	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about services that may be of interest to you.	(a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing Communications.	Necessary for our legitimate interests (to develop our products/services and grow our business).
To monitor our communications with you in order to check any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to defend legal claims.	(a) Identity; (b) Contact; (c) Technical.	Necessary for our legitimate interests (to assist us in training our employees and defend our business in the event of a claim); Necessary to comply with a legal obligation. |

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please inform us directly if there are any ways in which you feel we are not making these choices available to you.

We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of the Duffel Technology Group for marketing purposes.

Opting In or out

On Sign-Up to Duffel you have the option to receive updates from us (to opt-in), you are not automatically added to our mailing list. Additionally if you are already on our list you can request for us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.

Monitoring communications

We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of Your Personal Data

We may have to share your personal data with the parties below for the purposes set out in the table in paragraph 4 above.

• (A) Internal Third Parties as set out in the Glossary.

• (B) External Third Parties as set out in the Glossary.

• (C) Third parties to whom we may in the future enter into a transaction that results in a business restructure (merger, sale, acquisition, joint-venture etc.). Such restructure may result in us sharing personal data with the relevant third parties.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Data Transfer

Duffel operates internationally therefore we may share your personal data within the Duffel Group of Companies. This will involve transferring your data outside the United Kingdom (UK) to countries where some of the data protection rules differ. Additionally, some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

For all transfers of data, whenever your personal data is transferred outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period to enable us to comply with external reporting requirements and/or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We maintain details of retention periods for different aspects of your personal data within our retention policy and regularly review this to ensure it is in compliance with any limitation periods and record retention obligations that are imposed by applicable law.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, these rights are explained in more detail in our Glossary.

• (A) Request access to your personal data.

• (B) Request correction of your personal data.

• (C) Request erasure of your personal data.

• (D) Object to processing of your personal data.

• (E) Request restriction of processing your personal data.

• (F) Request transfer of your personal data.

• (G) Right to withdraw consent.

If you wish to exercise any of the rights set out above, please email privacy@duffel.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful Basis

• Legitimate Interest
  means our interest in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Performance of Contract
  means processing your data where it is necessary for the performance of our Agreement with you as set out in our Services Agreement.
• Comply with a Legal or Regulatory Obligation
  means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

• Internal Third Parties
  Other companies in the Duffel Group to which we share personal data with in order to provide our services and for other administrative purposes.
• External Third Parties
  i. Suppliers who provide the travel services (e.g airlines for flights and ancillaries) for orders made through our platform.
  ii. Service providers who provide IT and system administration and infrastructure.
  iii. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  iv. HM Revenue & Customs, regulators and other governmental authorities who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

• Request access
  to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction
  of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure
  of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing
  of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing
  of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  (a) if you want us to establish the data's accuracy;
  (b) where our use of the data is unlawful but you do not want us to erase it;
  (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer
  of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time
  where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.