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Privacy Policy

Updated December 23, 2023

 

Oafare, Inc., Oafare.com is a price matrix product that offer users online travel related services and features as defined in our Terms of Use. For the purposes of this Privacy and Cookie Policy,  Oafare shall be considered a third-party seller of travel services and hosts third level domains or subdomains (hereinafter “travel.oafare.com”).

 

Your user privacy is important to us, and we take necessary steps to protect it. In terms of Data Processing, we protect your rights as data users and observe California Consumer Privacy Act (“CCPA”) regulations, Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act and other applicable legislation of other states along with regulations of relevant state authorities including other applicable laws and policies. In this Policy, Oafare explain how we get your data and the processing standards we follow.

 

This Privacy Policy is closely related to our Terms of Use where you can find more information about Oafare's functionality as well as your rights and liabilities when accessing the service. Please note that our Cookie Policy is part of this policy as well. 

 

If you have any questions about this Policy or find any errors or inaccuracies, please contact us. When describing your issue or question, please do so in detail so we may quickly respond to your inquiry and correct the error. This helps us improve our services and offerings to you.

 

We reserve the right to change this Policy at any time and make changes to our processing procedure taking newly enacted Personal Data protection legislation into account. We’ll notify you the user in cases of significant changes that may affect your interests, rights, and status. Oafare guarantees that the protection of your Personal Data is always legitimate and fair, and that your data is secure.

Key Terms

Personal Data or Personal Information refers to any information relating to an identifiable person or household who can be directly or indirectly identified or reasonably linked by reference to an identifier. This definition applies to a wide range of personal identifiers that constitute Personal Data, including an email address, identification number, device information, location data, or online identifiers, such as cookie files or similar technologies.

 

Data Processing refers to any operation or set of operations performed on Personal Data or on sets of Personal Data, whether by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure, or destruction

 

“You”, “your”, or “Data Subject” “Consumer” refers to a visitor of Oafare's web-resource, authorized user, a subscriber to any service we offer through our web-resources, or prospective/existing clients communicating with us via email or other means.

Data Controller refers to a person who (either alone or jointly with other persons) determines the purposes for which, and the manner in which, any Personal Data is, or is to be, processed.

Data Processor, in relation to Personal Data, refers to any person (other than an employee of the Data Controller) that is considered as a service provider to Data Controller who processes data on behalf of the Data Controller for business purposes. We describe how we engage with Data Processors and other third parties that may process Personal Data on our behalf in Section 3 of this Policy.

 

Profiling refers to any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to Data users. Profiling is done to analyze or predict aspects concerning that specific Data user preferences and interests while using a particular set of our services.

 

Account refers to a section of Oafare that is available to you after authorization (signing up) and gives you access to certain services and features, which improves your user experience, that may not be accessed without authorization.

 

Assisted Booking refers to the feature of Oafare that allows you to start purchasing flight tickets through a special interface by concluding an agreement with the travel service provider when leaving Oafare's interface. The interface simplifies filling in necessary data for the booking (surname, name, passport data, contact data), which a user uploaded to Oafare earlier or when this feature is used for the first time.

 

We reserve the right to use other terms and definitions, even if they are not explicitly specified in this section, as long as they are set out our applicable Terms of Use.

Data that we can collect and process 

When you use Oafare and its features or contact us, we may collect and process any data and information that you provide to us voluntarily, that is collected automatically, or that we receive from other sources.

 

Voluntarily provided data

This includes any information you provide to us, such as information provided when you fill out a search form, subscribe to our marketing and commercial communications, enter your account information, enter into contractual relationships with us related to the usage of some of our product offerings (e.g., Oafare Fly-High subscription), send us a query or feedback, participate in discussion boards or other social media functions via Oafare.com marketing special projects or subdomains (travel.oafare.com), complete promotions or surveys, or report a problem. We may also process data you provide to our partners, including airlines and OTAs, while using assisted booking or making a booking after redirection.

Voluntarily provided data may include the following:

Personal Information:

  • Search data of available products on Oafare, including travel dates and destinations.

  • Respective authentication data, including, for example, social network parameters and email addresses.

  • Contact data entered by you in the input fields on the airline, hotel, or OTA website after redirection.

  • Other Personal Information contained in your queries and communications with us.

 

Sensitive Information:

  • Your personal details and respective data of people who will accompany you on a trip (this may include PNR, your passport or debit/credit card number, etc.) if you proceed to make a purchase with using Assisted Booking or that you directly provide us with in order to receive support with relevant issues from our support team.

  • Particulars of your payment method needed for conducting payments upon a direct agreement concluded between you and the Data Controller (e.g., Oafare, our partners, Fly-High subscription agreement).

Automatically processed information

This mostly consists of online identifiers or technical facts about your connection point. For example, device and connectivity information, such as IP address (Internet Protocol), unique device identifiers (such as the IMEI for phones, MAC address of the device's wireless network interface), mobile network information, your mobile operating system, the type of browser you use, as well as time zone and language settings. Other types of configuration data include browser type, version, language settings, browser plug-in types, and browser versions.

 

This data is automatically collected when you visit Oafare.com and its websites and/or use our services/features. In some cases, this data can be created by our software or third-party programs, integrated into Oafare's software(s).

 

The list of data categories that may be automatically collected by us includes the following information:

  • IP-address and log information (such as error reports).

  • Geolocation (meaning country or region in terms of redirection to the appropriate market domain).

  • Mobile device information, including device type/model, locale, and OS information.

  • Impersonalized booking data after redirection or use of Assisted Booking (meaning destination, dates, and prices).

  • Cookies and similar tracking technologies, including local storage data, statistics and analytics on the use of the service and its different features, as well as interaction information (scrolling, clicks, timings, etc.)

You can find more information on cookies and similar technologies in our Cookie Policy.

 

Data received from third parties

This category includes different types of data, mostly online identifiers, which we receive from airlines, OTAs, GDS, as well as our technical, analytical, marketing, and other online partners.

 

For example, we might insert advertising on our subdomain websites, social networks, or advertising networks that may categorize Oafare users with similar interests into non-personally identifiable data segments, which may be offered to our clients, visitors, and subscribers.

 

We might obtain and record information that an ad was requested or shown, how many times said ad was shown, the target geo of said ad (which will not include an IP address or specific identifiable location information), and any user interactions with said ad or information about the page on which it appeared. This information is used for statistical purposes, analysis, reporting, and troubleshooting. In most Data Processing situations, such information does not permit us to identify you as a Data user and will be processed with appropriate levels of protection and limitations, which the data source may establish.

 

Data we don’t process

We do not process data on children, as Oafare.com is intended only for users over the age of 16 (or another age of maturity determined by applicable laws allowing for the independent use of Internet services like Oafare). If you are under the specified age, you may only use Oafare with assistance of a parent or guardian. We do not knowingly collect or process personal information from minors below the specified age without their parent/guardian's consent and assistance. In questionable activity, we will cease such processing of data and delete it.

 

We do not collect or process special categories of Personal Data nor genetic without your direct consent, such as name, age, email, passport, and payment method details (unless you subscribed to one of our marketing mailings, joined a subscription program or entered personal identifiable information, phone number, home address, etc.

 

We also do not process data a user or subscribers ask us directly to stop processing or opted out of.

 

Oafare does not process data acquired by third parties on other platforms that you may be directed to from our web-resources. For instance, by clicking on an ad banner, except for cases and particular data directly mentioned in this Policy. Your Data Processing on third-party platforms is carried out according to the rules and processes by owners of those platforms.

 

Additional information on Data Processing

Please note that, when you proceed with purchasing flight tickets or other travel services after redirection from our web-resources to the provider, we do not acquire, store, transmit, or process any information except depersonalized information, such as prices, dates, destinations, and transaction identifier. Whereas, in situations where you make a payment on an OTA’s or airline’s website using our redirected Assisted Booking, we may process all the information you fill in, including your name, passport data, amount of people accompanying you, and their respective details in order to perform our obligations and meet outlined purposes.

 

In providing Personal Data about other individuals (such as someone whose name you are using to create an account or subscribe to any promotions), you represent that you have notified that person of:

(1) the grounds and purposes for which said information will be used (see below),

(2) the recipients of their Personal Data,

(3) and how they can access and correct such information.

The consent that you give for a third person is considered by us to be the consent of said third person.

 

Selling and Sharing of Personal Data

We do not sell your Personal Data to third parties. However, we may share your personal information to our partners for business and commercial purposes as it is described in section 3 of this Policy. Please, check the last section of this Policy and the Cookie Policy where you can get information about your right for opting out of sharing of your personal information and ways on how you can exercise those rights.

 

Email marketing and communications

Oafare would like our subscribers and users to get the best information concerning travel that will help improve their travel experience as well as information about the best deals on flight tickets, hotels, and other travel products. In addition, we share with our user's information that may help with travel plans, such as notifications on savings. Upon creating an account, or when using particular functions of Oafare's service, we offer you the chance to subscribe to our Fly-High newsletter which offers airline ticket price drops, percentage savings on flights and hotels, and third-party ads. You can unsubscribe from these direct marketing communications at any time by using the opt-out form in one of the received emails or by contacting our support team.

 

Profiling

You're important, that is why we try to understand our audience, including their needs and preferences in order to make our service more user friendly and easily accessible. To achieve these goals, we may create profiles of our users based on data collected through their interactions. This gives us a better understanding of how we can personalize ads and marketing communications based on consent received from you. Importantly, we never use collected data to make automated decisions that significantly affect your rights as a data user. Oafare will never prohibit or block the use of a particular feature solely based on your online profile.

Grounds and purposes for Data Processing

Grounds for Data Processing

In this section of the Policy, we describe legal grounds and purposes for processing Personal Data in your interaction with Oafare, related domains and subdomains, or individual features of our products, which may also be available on our network of travel partners’ websites.

 

We process your data only if there are legal grounds to do so. When applicable, we receive your consent for Data Processing, which you provide through an explicit action, such as clicking an event action, consent-giving button or ticking a relevant box.

 

In other cases, data is processed:

(1) in your interest or to provide you with the relevant service or functionality of the service according to the Terms, or instance, to provide search results or fix a problem.

(2) to email marketing information about Oafare or our advertisers, or

(3) to fulfill other contractual obligations.

 

For example: By transferring the relevant information about your chosen flight tickets to our partners, available in the search results, we fulfill our obligations to these partners to properly record bookings and statistics on our side. In addition, user data is processed in our legitimate interests, for example, to improve the performance of Oafare offerings or a particular feature of the metasearch service, prevent fraud, data parsing, etc.

 

Purposes of Data Processing

Data Processing purposes are largely determined by Oafare's functionality and derive from grounds for Data Processing. Primarily, we strive towards improving our service and making your experience with us stress free, easy, efficient, secure, convenient, and personalized. We also strive on updating users about thrilling articles about savings, destinations, and sources with potentially useful information for travelers as well as about new features, products, promo campaigns and special Oafare projects, other interesting beneficial deals in the travel market and more. In addition, we receive income by displaying third-party ads and can process data to track ad performance or select the ads that may suit your particular travel interest.

Selling and Sharing of Personal Data

Data Category                                                                      Grounds                                                                                       Purposes

Contact information (most often, an email address, sometimes name and social networks data)

Consent, fulfillment of obligations, legitimate interest

((1) Provision and personalization of features and services as well as entering additional agreements, (2) necessary internal analytics and research of the service, (3) providing advertising information, (4) monitoring, accessing, and using user-generated content

Data on searches

Fulfillment of obligations, legitimate interest

((1) Provision and personalization of features and services, (2) necessary internal analytics and research of the service

Data on the Account

Consent, fulfillment of obligations, legitimate interest

(1) Provision and personalization of features and services as well as entering additional agreements, (2) providing advertising information, (3) monitoring, accessing, and using user-generated content

Data on your payment method details

Consent, performance of a contract to which you are party

(1) Conducting payments upon the direct agreement between you and the Data Controller, (2) provision of the Assisted Booking feature (not stored by the Data Controller)

Data on the device

Fulfillment of obligations, legitimate interest

(1) Provision and personalization of features and services, (2) necessary internal analytics and research of the service

Cookies and other online identifiers, including local storage data.

(find out more in our Cookie Policy)

Fulfillment of obligations, legitimate interest

(1) Provision and personalization of features and services, provision of advertising information, (2) necessary internal analytics and research of the service

Data on the use of Aviasales features

Fulfillment of obligations, legitimate interest

(1) Provision and personalization of features and services, provision of advertising information, (2) necessary internal analytics and research of the service

Passport and other Personal Data needed to use the Assisted Booking feature

Consent, fulfillment of obligations, legitimate interest

(1) Provision and personalization of features and services, (2) necessary internal analytics and research of the service, (3) provision of advertising information

Your Security

Data Processing Conditions and Principles

Confidentiality and security

We believe that the confidentiality and security of our users’ data is important and part of our ethical standards which is key to maintaining trust and a long-term relationship. We are committed to protecting Personal Data you share with us. We use a combination of industry-standard security technologies, procedures, and measures to help protect your Personal Data and information from unauthorized access, use, or disclosure.

 

Oafare uses these services of Data Processors, whose products and solutions are required for hosting our web-resources and products, storage and collection of data, implementing our features, analyzing and testing, profiling, email marketing, and supportive interactions with you. Providers of such services are researched and carefully selected to ensure the safety of your data at every level. In some cases, such providers help us collect cookies and similar technologies. You can learn more about this in our Cookie Policy

 

Data retention

We retain your Personal Information for as long as necessary for processing purposes. Terms may also differ for such categories of Personal Information.

We also reserve the right to store various types of information (without any time limit) to use for analyzing service performance, improving features, providing services to you, and protecting Oafare's interests.

 

However, we give you the opportunity to control and influence the time we store and process your data, as specified in the “Your Rights” section of this Policy.

Transferring Personal Data to Third Parties

We share Personal Information about you with third parties or non-affiliated companies until you decide to opt out of sharing that Information, except of the processing that takes place in order to provide services you've requested, or under the following circumstances:

  • Information to trusted third parties, who provide us with services and work on our behalf under confidentiality agreements. These companies may store, maintain, or process your data. These companies do not have any independent right to process this information.

  • We may disclose your information to third parties when we reasonably believe we are obligated to do so by law and/or in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.

  • In the event we are acquired by or merge with a third party or undergo another change of control, we reserve the right to transfer information, including any personally identifiable information, to a successor entity.

We may disclose or otherwise allow others to access your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant, or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention, and national security.

Your rights

You have the following rights concerning the collection and processing of Personal Data:

 

The right to be informed:

In this Policy, we provide you with detailed information related to the processing of your Personal Data. The right to know what personal information is being collected and right to access said personal information. You can request we disclose an exact description of categories and sources of personal data collected the purposes of collection and sharing of your information, who the third parties are we share your data with and list of specific pieces of personal information we collected about you.

  • The right to rectify your Personal Data f it is inaccurate, incomplete, or outdated.

  • The right of erasure (deletion or removal) of your Personal Data.

  • The right to restrict (block) processing.

 

When processing is restricted, we will continue to store your Personal Data, but not process that information any further.

 

Rights related to automated decision-making, including Profiling:

We do not make any decisions that might produce a legal effect on you based on automated processing without legal grounds. However, you may opt out of automatic processing of your data unless this data is not processed by us for business purposes (i.e. marketing and functional cookie processing). This right may be exercised via managing your cookie preferences through special Data preferences menu.

Right to opt out of selling or sharing your data:

You can opt out of sharing your personal information to third parties for non-business purposes by managing your data preferences through the data preferences menu (Do Not Share My Personal Information).

The right to limit the use of your Sensitive Information

We may use your sensitive information only to provide you with services under a contract you have entered into. We do not sell or share your sensitive information for commercial purposes.

 

  • The right to withdraw your consent (object) to direct marketing.

  • The right of no retaliation following opt out or exercise of other rights. You have the right to exercise all of the abovementioned rights for free and without any following retaliation or discrimination against you.

 

We respect your privacy rights and do not levy charges or deny you services once you've preferred to keep your personal information private by exercising said rights. However, some of Oafare's functionality/products are technically based on the processing of your data and we may not be able to perform the respective services without certain data about you.

 

You can exercise the above rights (if implied) by Contacting Us or using our opt-out or «manage your privacy» functionality.

Updates to Statement

We may update this Statement in response to changing laws or technical and business developments. If we propose to make any material changes, we will notify you by means of a notice on this page. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this policy.

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