Privacy Policy for AirTrack

We are pleased that you are using our Telegram Bot. Data protection and data security when using our services are very important to us. We would therefore like to inform you which of your Personal Data we collect when you use our services and for what purposes it is used.

Who is responsible?

The person responsible in the sense of Estonia’s Personal Data Protection Act (“PDPA”) and the EU’s General Data Protection Regulation (“GDPR”) is ManySignals OÜ of Sepapaja tn 6, 15551 Tallinn, Estonia (“AirTrackBot”, “we”, “us”, or “our”). Please direct any questions you may have to office@airtrackbot.com.

Principles of data processing

a. Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior.

b. Processing

The processing of Personal Data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis.

c. Legal basis

In accordance with the PDPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

d. Retention

Processed Personal Data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.

Data we collect

a. Provision and use of Telegram

The use of our Telegram Bot requires the Services of Telegram Messenger Inc. Downloading Telegram may require prior registration with Telegram and/or installation of the software. The responsible party in this respect is solely Telegram as the operator of the Telegram Messenger Service. https://telegram.org/privacy/eu

b. Contacting Us

We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.

c. When using our Telegram Bot

The protection of your Personal Data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, telegram nickname, telephone number, IP address) as is absolutely necessary.

Nevertheless, we rely on the processing of certain travel information you provide (for example: your travel details and preferences, your travel itineraries and flight information) (“Service Data”) to; i) search for flights and tickets at the best prices; ii) track prices and find you the best offers; iii) redirect you to the relevant booking provider; iv) send notifications in case of price changes: and v) offer you our premium services.

We recognize that you own your Service Data and provide you with complete control of your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data.

When we process your Service Data, we become your Data Processor or in other words, we will process the Service Data involved in your use of our Telegram Bot in accordance with your instructions and shall use it only for the purposes agreed between you and us.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

d. Premium Services

To use our premium services, you may need to spend and/or purchase Telegram Stars. The purchase of Stars is subject to the relevant app store provider (Google or Apple) and our payment processor Paddle. We do not collect or store payment information or bank details ourselves but receive payment confirmation statements. The legal basis for the data processing is the fulfillment of our contractual obligations and the fulfillment of our legal obligations.

Data Security

We undertake to protect your privacy and to treat your Personal Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organizational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).

However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

How we may share your Personal Data

We may share your Personal Data with our Business Partners for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customizing our business to better meet your needs. We share your Personal Data only with Business Partners who agree to protect and use your Personal Data solely for the purposes specified by us.

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.

What we do not do

  • We do not request Personal Data from minors and children;
  • We do not use Automated decision-making including profiling; and
  • We do not sell your Personal Data.

Privacy rights

Under the PDPA and the GDPR, you can exercise the following rights:

  • Right to information
  • Right to rectification
  • Right to deletion
  • Right to data portability
  • Right of objection
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information and withdrawing your consent

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Estonia is: Data Protection Inspectorate, Tatari 39, Tallinn 10134, Estonia, www.aki.ee.

Validity and questions

This Privacy Policy was last updated on Friday, 12th of July, 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary.