1. Roles and scope
We act as a processor (data processor) when you, as a customer or partner, arrange travel logistics through our services and provide us with personal data necessary to perform and support those arrangements. Where we determine the purposes and means of processing, we may act as a controller (data controller) for that processing.
2. What personal data we process
Depending on your arrangements, the personal data may include: contact details (e.g., name, email, phone), booking/travel details (e.g., dates and itinerary information), and data needed to confirm, coordinate, or deliver travel-related services.
3. Processing purposes and instructions
We process personal data only to provide travel-logistics services and to support the performance of your requests, based on your documented instructions and applicable law. We do not use personal data for unrelated purposes unless you authorize it or the law permits it.
4. Subprocessors
We may use subprocessors to perform parts of the services (for example: hosting and operational support, customer communications, IT/security services, and service providers involved in travel-logistics execution). We require subprocessors to apply appropriate safeguards for personal data and to process data only for the purposes described in this addendum.
Where applicable, we provide a way to request information about subprocessors and their categories (e.g., by contacting us using the details in the footer).
5. Security measures
We implement organizational and technical measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Measures may include access controls, least-privilege practices, encryption in transit where feasible, secure account administration, monitoring, and incident-response procedures.
6. International data transfers
If we transfer personal data outside Ukraine, we will implement appropriate safeguards to protect it and ensure the transfer is handled in accordance with applicable legal requirements. If such transfers are expected, we may provide additional details upon request.
7. Consumer- and contract-related transparency (Ukraine)
If we conclude services arrangements with consumers remotely, we provide required distance-contract information before/at contracting, including the trader’s identity/location and the complaint/claims procedure, as required by Закон України "Про захист прав споживачів" від 10.06.2023 № 3153-IX, Стаття 17, Стаття 19, Стаття 16.
If electronic contracts are used for services, we provide mandatory information required in connection with the electronic contract and ensure the required e-commerce identification/contract mechanics are supported on our site, as required by Про електронну комерцію | від 03.09.2015 № 675-VIII.
8. Personal data, privacy, and legal basis (Ukraine)
Where applicable, our processing is performed in line with Ukraine’s personal-data requirements and transparency obligations under Про захист персональних даних | від 01.06.2010 № 2297-VI.
9. Cookies/trackers (if used)
If cookies/trackers are used as part of electronic communications services or related online measurement, we ensure tracking implementation aligns with obligations under Про електронні комунікації : Закон України від 16.12.2020 № 1089-IX.
10. Contact and requests
If you need information about this addendum, subprocessors, security measures, or wish to submit a request related to personal data processing, contact us below.