Privacy Policy

Effective Date: 16/05/2023

This privacy policy (the “Privacy Policy“) is an integral part of the terms of use and both documents should be read together.

Secret Flights Ltd. (“Captain Flights“, “Us“, “We“, or “Our“) operates its service “Captain Flights” and other communication channels such as Telegram, emails and chatbots (the “Service” or the “Website“).

Captain Flights respects the privacy of its users. In order to improve the protection of the Users, Captain Flights publishes this Privacy Policy regarding how Captain Flights collects Your information from Your use of the Service.

The processing and collection of personal data is governed by the General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act (“CCPA“), and whenever you’ll provide Captain Flights such information, Captain Flights will only use your information in line with all applicable data protection laws, including the GDPR and the CCPA. At all times You are in control of Your information, and You can withdraw Your consent to provide Your information to Captain Flights.

The data controller of the Service is Secret Flights LTD, Reg No. 515833291 which is the entity which decides how Your personal information is processed and for what purposes as detailed in the Privacy Policy.

  1. General

    During Your use of the Service, Captain Flights will collect some information with accordance to Your consent which may be withdrew at any time:
    • statistical data related to Your searches and other use of the Website;
    • any other data which will be detailed by Captain Flights, if applicable.

  2. Your Rights Regarding Your Personal Information

    1. Under the GDPR and subject to different exemptions, You have the following rights:
      • To access Your personal data and receive a copy of Your personal data upon Your request, if available;
      • To rectify, erase or restrict Your information upon Your request (right to be forgotten);
      • To object to the processing of Your information;
      • To request that Captain Flights will provide the You with Your personal information and, if possible, to transmit Your data directly to another data controller (right to data portability).
      • To withdraw Your consent to processing and the processing at any time;
    2. No fees are required for exercising any of the above rights. However and subject to the GDPR, Captain Flights may charge You a reasonable fee including administration fees if Your request is repetitive or excessive or demands Captain Flights to bear excessive and/or expensive efforts.
    3. To exercise your rights, please contact Captain Flights’ Data Protection Officer at the following contact details: Secret Flights Ltd. Email: flywith @ captainflights.com.

  3. Database and Use of Information

    1. All collected information as stated above is stored in Captain Flights’ database. With accordance to Your consent, Captain Flights warrants to use such information for the following purposes:
      • Enabling convenient and efficient use;
      • Improve and enrich existing services and content;
      • Modify and/or remove existing services and content;
      • Perform research and provide statistic information to third parties, including advertisers (in such case, the provided information will not identify You);
      • Enforce Captain Flights’ terms and conditions;
      • Any other purpose detailed in the terms of use and this Privacy Policy.
    2. Information You decide to provide Captain Flights is collected and used because Captain Flights has a legitimate business interest for Your personal data to be used for the above purposes. This enables Captain Flights to send You relevant and personalized content designed to improve Your use of the Service. You have the right to object to this by contacting Captain Flights via email: [email protected] Please note that if you object, this may affect Captain Flights’ ability to send personalized content to You.
    3. Please note that some of the information You will be requested to provide is necessary for providing You the Services. Therefore Your refusal to provide some information may result in You not receiving the Services since Captain Flights will not be practically able to provide you the Services.
    4. Captain Flights may receive Your information from third parties which Captain Flights cooperates with (e.g. business partners, professional advisors, service providers, etc.) and Captain Flights may receive Your information from them.

  4. Transferring Information to Third Parties

    1. Subject to Your consent, Captain Flights will transfer and/or share Your information in the following events and circumstances and, when applicable, will give you reasonable notice upon doing so:
      • When You have permitted Captain Flights to transfer and/or share Your information;
      • When You violate the terms of use of the Website or act illegally;
      • To enforce the Terms or other agreements or policies;
      • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency;
      • To establish or exercise Captain Flights’ legal rights;
      • To defend against legal claims; or as otherwise required by law. In such cases, Captain Flights may raise or waive any legal objection or right available to Captain Flights, in Captain Flights’ sole discretion;
      • When Captain Flights believes disclosure is appropriate in connection with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing;
      • To protect and defend the rights, property or safety of Captain Flights, its Users, employees or others;
      • In connection with a substantial corporate transaction, such as the sale of Captain Flights’ business, a divestiture, merger, consolidation, or asset sale, or in the event of insolvency.
    2. With accordance to the CCPA, Captain Flights does not share, sell, disclose or commercialize your information unless explicitly mentioned otherwise.

  5. Third-Parties

    1. There are several places in the Service where You may click on a link to access other websites that do not operate under this Privacy Policy and are not related to Captain Flights including, but not only, links leading to third party websites. These links may independently solicit and collect information, including personal information, from You and, in some instances, provide Captain Flights with information about Your activities on those links.
    2. Every third party such as detailed above may have its own privacy policy describing its use of personal information, and such policy will regulate the use, handling and disclosure of such personal information of the User. Should You require additional information regarding any privacy policy of third parties, Captain Flights recommends that You visit these third-party Services and read their privacy policies.
    3. Your information will be handled and used by Captain Flights’ trusted third parties including the following recipients to deliver services provided by Captain Flights:
      • Providers, partners and sub-contractors on behalf of Captain Flights;
      • Analytics and search engine providers that may assist Captain Flights in improving the optimization and performance of the Service.

  6. Retaining Your Information

    Captain Flights will only retain Your personal information for as long as necessary to fulfil the purposes it was collected for including, but not only, for the purposes of complying with legal, accounting, or reporting requirements. The retention period is determined based on the amount, nature, and sensitivity of Your personal information, the potential risk of harm from unauthorized use or disclosure of Your information, the purposes for which Captain Flights processes Your information and whether such purposes can be achieved through other means with accordance to any applicable law.

  7. Use of Various Collection Technologies

    1. Upon Your consent, We use various technologies to collect information from Your device and about Your activities while using the Service in order to improve and personalize Your online experience of the Service including by means of storing cookies to Your device. Please note that some of the technologies We use are necessary for using the Service and some are used to provide features of third parties.
    2. Please note that We cannot guarantee the proper performance and use of the Service, and therefore without permitting Us to gather information via such technologies, We will not be able to provide You Our Services and You will be requested to refrain from any use of the Service.
    3. During your use of the Service, third-party Services may store cookies to Your device, e.g. when some content of the Service is embedded from the Third Party Services. Please note that We have no control over these cookies and You should check such third party’s cookie policy.

  8. Data Security

    1. Captain Flights takes appropriate security measures for data security purposes to help prevent unauthorized persons from gaining access to Your personal information. However, no system can be completely secure. Therefore Captain Flights does not warrant that its services will be totally immune to any breaches of security and/or unauthorized access, including access to the data stored in the Service, although Captain Flights will contact You upon a breach of Your data security with accordance to any applicable law.
    2. Captain Flights may inspect, from time to time, the data security of the Service and performs modifications and upgrades accordingly in order to keep the Service’s security. Nonetheless, Captain Flights will not be liable for any direct or indirect damage caused to You due to exposure of Your information by an unauthorized access to Captain Flights’ database and/or due to any negligence or act not controlled by Captain Flights.

  9. Minors

    We do not knowingly collect or solicit information from anyone under the age of eighteen (18) or knowingly allow minors to use the Service or any of Our Services. If We become aware that we have collected information from a minor without the consent of his/her parent or guardian, We will immediately remove such collected information and block his/her access to the Service and/or any of Our Services.

  10. Email Updates

    1. Captain Flights may offer to all its users to receive email messages and/or newsletters about updates, improvements and other user notifications regarding Captain Flights’ activity, including via emails and SMS (the “Mailings”).
    2. It is clarified that at any stage You will have the ability to opt out of receiving the Mailings by contacting Captain Flights and/or by clicking on a link available on the Mailings sent to You by Captain Flights.

  11. Changes to This Privacy Policy

    Captain Flights may occasionally update this Privacy Policy. Captain Flights will notify You by sending an email to the email address You most recently provided Captain Flights and/or by prominently posting notice of the changes and will state at the heading of the Privacy Policy the date of change.
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