We view data privacy as a fundamental component of doing business. Our Privacy Statement and practices are focused on processing personal data appropriately and lawfully, while providing confidentiality, integrity and availability.
This Privacy Statement applies to www.skypaid.eu and other SkyPaid domains, owned and operated by Sky Services and Partners S.R.L. (IDNO 1026023133791), trading as SkyPaid. For the purpose of this Privacy Statement, the terms "SkyPaid", "we", "us", or "our", refer to the whole company group or each of the companies as the case may be.
This Privacy Statement represents the full online privacy policy applicable to our activities. The Privacy Statement explains the types of information we collect, how we use, share, and secure the information you provide. It also describes your choices regarding use, access and correction of your personal data.
Your personal data is processed lawfully. Our activities are governed under applicable data privacy and data protection laws (collectively, "Data Protection Laws") in connection with the services we provide. The particular Data Protection Laws may include, depending on the circumstances, the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), and the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados or LGPD), and other applicable legislation and regulations implementing Data Protection Laws.
Sky Services and Partners S.R.L., trading as SkyPaid, is the data controller as it determines the purposes and means of the processing of personal data.
Definitions
In this Privacy Statement, unless otherwise defined herein, the capitalized terms below shall have the same meaning as in our Terms and Conditions.
Personal data
Personal data means any information relating to an identified or identifiable natural person. Personal data includes all types of information that directly or indirectly identify a person, such as names, date of birth, address, email addresses, telephone numbers etc.
Purpose and legal basis
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
- Based on Your Consent
- We process personal data when we have obtained your consent for a particular processing operation. This ensures that you have direct control over the use of your information in these instances.
- For Contractual Fulfillment
- The processing of personal data is undertaken when it is necessary for the performance of a contract to which you are a party. This includes situations where you purchase a service from us, as well as pre-contractual measures, such as responding to inquiries about our offerings.
- To Comply with Legal Obligations
- We process personal data when such processing is required to fulfill a legal obligation to which we are subject. An example of this would be compliance with tax law regulations.
- Based on Legitimate Interests
- We may process personal data where we have a legitimate interest in doing so, provided that your fundamental rights and freedoms are not overridden. An illustrative example includes the use of cookies that are essential for the technical operation of our website.
Principles
Our Privacy Statement is based on the following data protection principles:
- The processing of personal data shall take place in a lawful, fair, and transparent way.
- The collection of personal data shall only be performed for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- The collection of personal data shall be adequate, relevant, and limited to what is necessary in relation to the purpose for which they are processed.
- The personal data shall be accurate and where necessary, kept up to date.
- Every reasonable step shall be taken to ensure that personal data that is inaccurate in regard to the purposes for which it is processed, is erased or rectified without delay.
- Personal data shall be kept in a form which permits identification for no longer than it is necessary for the purpose for which the personal data is processed.
- All personal data shall be kept confidential and stored in a manner that ensures appropriate security.
- Personal data shall not be shared with third parties unless the transfer is necessary in order for SkyPaid to deliver the services in the agreement.
- You have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.
Collection and use of personal data
If you would like to benefit from our services and submit information to us, you may be asked to provide personal data in order for us to operate and improve our business and services. Personal data may be submitted via our website, email, other electronic or software solutions supported by us, postal service, or phone. All personal data is collected in accordance with the applicable Data Protection Laws. We will process personal data only to the extent required for a specified, explicit and legitimate purpose or for a purpose required by law in places where we operate.
We primarily collect personal data such as names, dates of birth, addresses, email addresses, telephone numbers, passports/IDs, and national identification numbers. We collect this personal data for the purpose of delivering our Eligibility Service, Information Service, Compensation Service, and any other Services in accordance with the agreement. This is the core activity of SkyPaid as a business.
Furthermore, we collect personal data for other purposes such as statistics, administration and communication, IT and security administration, physical security, authentication and authorization systems, support systems, collaboration of internal projects, and organizational teams and activities.
We purchase flight data from third parties, e.g. information on delayed or canceled flights within a given time etc. This information is non-personal data, which we combine with personal data. This Eligibility Service is only used to inform about the likelihood of having an eligible Claim. We will provide our Compensation Service for Eligible Claims on request.
Insofar as you share personal data of Fellow Passengers with us, you are obligated to ensure that all Fellow Passengers have explicitly given their consent for the sharing of their personal data with our organization, in compliance with data protection regulations. Moreover, you are required to provide the Fellow Passengers with access to our privacy policy to ensure that they are fully informed about the processing of their data by us.
We may ask you for additional information or documents related to Fellow Passengers. If you or Fellow Passenger fail to provide such information and/or documents, we will not be able to offer our services to the respective Fellow Passenger. Consequently, we will be compelled to remove the personal data of that Fellow Passenger from our databases and we will not be able to provide them with our Services.
When contacting us, e.g. by website, e-mail or telephone, the data provided to us (e.g. names and e-mail addresses, phone numbers) will be processed by us in order to answer your questions. The legal basis for the processing is our legitimate interest to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
To improve our services and efficiently classify documents, we utilize artificial intelligence (AI) tools, such as AWS Bedrock, to analyze submitted documentation. This processing is conducted based on our legitimate interest in service optimization and/or your consent, where applicable.
Where you start but do not complete a claim application, or where documents or a signature required to pursue your Claim are missing, we may send you service reminders by email (and, where you have provided a phone number and relevant preferences, by SMS/WhatsApp). These communications are transactional in nature and are necessary to perform pre-contractual steps and to deliver the Services you requested.
Service communications and claim processing
Based on contractual necessity and our legitimate interest in providing an effective Compensation Service (Art. 6(1)(b) and Art. 6(1)(f) GDPR), we process your personal data to operate your Claim end-to-end. This includes verifying eligibility, generating Forms (such as a power of attorney or assignment), requesting and storing supporting documents, communicating with you about incomplete steps, and updating you on claim status.
You acknowledge that SkyPaid may send all communications reasonably required to process your Claim, including reminders to provide flight details, sign authority documents, upload boarding passes or identity documents, confirm payment details, and respond to Airline or authority requests.
We may also transmit your personal data and Claim documents to Airlines, their claims handlers, Lawyers, courts, national enforcement bodies, identity-verification providers, storage providers, and payment processors, solely to the extent necessary to file, pursue, settle, or pay out your Claim. Where required by law, such transfers are subject to appropriate safeguards.
Service communications described in this section are distinct from marketing communications. You may still receive service messages that are necessary to handle your Claim even if you have opted out of marketing.
Use of personal data
We will use personal data for the purpose it is collected, and keep the data for no longer than necessary for that purpose. We may retain your information for as long as your account is active or as needed to provide services, comply with our legal obligations, or any of the purposes listed above. Access to personal data is strictly limited to personnel of SkyPaid and its controlled subsidiaries and affiliates who have the appropriate authorization under a corporate binding agreement with SkyPaid, and a clear business need for the data.
Automated Processes and Profiling
SkyPaid does not rely on automated processing in accordance with the article. 22 p. 1 of the GDPR, and your personal data will not be used for profiling purposes. Your data will not be used for these purposes unless explicitly communicated otherwise, and only with your separate consent.
We may however use our technology and technology from our partners to automate certain processes. This allows us to provide faster and better Services to you.
In order to ensure that these automated processes have no negative or unjustified impact on you, our teams regularly investigate whether they are correct. This concerns legacy and future processes.
Questions about your data and automated processes can be directed to the Data Protection Officer ("DPO") email: support@skypaid.eu.
Data processing outside the European Economic Area (EEA)
In case of transfer your data to service providers or other third parties located outside the EEA; we ensure the security of your data through several mechanisms:
- Adequacy Decisions
- For transfers to countries for which the EU Commission has issued an adequacy decision (e.g., Great Britain, Canada, and Israel), the security of the data during transfer is guaranteed (Art. 45 para. 3 GDPR).
- EU-US Data Privacy Framework
- If data is transferred to service providers in the USA, the legal basis is an adequacy decision of the EU Commission, provided the service provider has certified itself under the EU-US Data Privacy Framework.
- Standard Contractual Clauses (SCCs)
- In other cases, where no adequacy decision exists, the legal basis for data transfer typically relies on Standard Contractual Clauses. These are a set of rules adopted by the EU Commission and are incorporated into our contracts with the respective third party. According to Art. 46 para. 2 lit. b GDPR, SCCs ensure the security of the data transfer. Many of our providers also offer contractual guarantees that go beyond the standard contractual clauses to further protect your data. These may include guarantees related to data encryption or an obligation for the third party to notify data subjects if law enforcement agencies request access to their data.
Security of processing
The security of your personal data is important to us. We will process personal data securely, apply and maintain appropriate and generally accepted standards of technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. Questions about the security of personal data, can be directed to the DPO email: support@skypaid.eu
Your data protection rights
You have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right to revoke a given consent and the right of data portability, at any time.
To help us keep personal data updated, we advise you to inform us of any changes or discrepancies.
To view and/or edit personal data, or receive information on how long we intend to retain personal data or other questions related to the access of personal data, or if you would like to request that we provide you with information about whether we hold, or process on behalf of a third party, any of your personal data, please contact the DPO email: support@skypaid.eu. We will respond to your request within a reasonable timeframe.
You also have the right to complain to a data protection supervisory authority about the processing of your personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
Storage duration
Unless expressly stated in this Privacy Statement, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Applying for a job
We publish vacant positions on our website, on pages linked to the website or on third-party websites. For job applications we use a third party recruitment tool for management purposes.
When applying for a job position at SkyPaid personal data will be processed and controlled by SkyPaid. We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.
We ask you to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in the CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants.
Applications shall not be stored for longer than necessary or shared with any third parties. We process the applicants' data for further application procedures if we are provided with the consent to do so.
Upon your explicit consent, we will use AI notetakers (e.g. Metaview) during interviews to help our team focus on the conversation. This involves processing the names, emails, voice, and video of both employees and candidates. You can opt out from such a solution without affecting your application.
If you wish to access, rectify, or erase personal data, restriction of processing, or to object to processing as well as use the right of data portability, please contact the DPO email: support@skypaid.eu
Marketing communications and advertising preferences
Upon consent we are allowed to send marketing communication in the form of emails, SMS (Short Message Service), RSC (Rich Communication Services), and WhatsApp messages. This specific form of consent must be freely given, specific, informed, and unambiguous. These requirements are fulfilled when you opt-in (i.e. actively agree) to receive marketing communication.
Upon your consent, we also send a free newsletter for interested parties. The data provided during registration for the newsletter is processed exclusively for sending it. Your subscription signifies your consent to data processing (Art. 6 para. 1 s. 1 lit. a GDPR). Based on this consent, we can also measure the opening and click-through rates of our newsletters to understand audience relevance.
Under our legitimate interest, we also reserve the right to inform existing customers about our offers via email or other means if they haven't objected.
You will always have the right to object, on request and free of charge, to the processing of your personal data relating for purposes of direct marketing activities without having to provide specific justifications. You can unsubscribe from marketing communications via our unsubscribe page, by using the "Unsubscribe" link found in emails received from us, or by contacting us at support@skypaid.eu. If you object, your personal data will no longer be processed for direct marketing.
The marketing communication contains information which we believe may be of interest, such as the latest news on our products and services.
We partner with a third party to display advertising on our website or to manage our advertising on other sites, including social media platforms. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. You may opt out of interest-based advertising. Please note that you will continue to receive generic ads.
We use Google services to provide and improve our products and services, including providing you with personalized advertising. Please visit Google's Business Data Responsibility for more information on how Google will use your personal data in that context.
Customer surveys
From time to time, under our legitimate interest, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. We delete the data when the results of the surveys have been evaluated.
Fraud prevention
After uploading the bank details and/or other necessary documentation, a verification of your identity and other details with a valid identification document is carried out through our KYC (Know Your Customer) procedure.
During the process, photo and, if necessary, video recordings of your identification document will be made. Particular attention will be paid to integrity, authenticity, and security features.
Specifically, the following personal data will be processed internally:
- General personal data: first and last name, gender, personal identification code or number, date of birth, nationality and citizenship, location (street, city, country, postal code);
- Identification document data: type of document, issuing country, number, expiration date, MRZ (Machine Readable Zone), information embedded in the document's barcode (may vary depending on the document), security features;
- Facial image data: photos of the face (including selfie images) and photo or scan of the face on the identification document, videos, audio recordings;
- Biometric data: facial features;
- Contact information: address, email address, phone number, IP address;
- Technical data: information about the date, time, and activity in the services; IP address and domain name; software and hardware attributes (camera name and type); general geographic location (e.g., city, country) of the individual's device;
- Unique identifier (Applicant ID) created solely for the connection between the individual and their personal data within the information system;
- Personal data provided additionally by the individuals.
As part of the identity verification process, we also screen your information, including payment and bank account information against sanction lists, Politically Exposed Persons (PEP) lists, and watchlists.
The processing is conducted under SkyPaid's legitimate interest to use the identity verification process to prevent frauds in the context of our services and protect our customers from fraudulent actions. Any biometric data is processed under your consent which can be revoked at any time with future effect, e.g., by emailing support@skypaid.eu.
Responsibility
The Privacy Statement is under the responsibility of our Legal Team, who have the overall responsibility to ensure compliance. The DPO is ensuring compliance with the Privacy Statement on a daily basis and is involved in all issues related to the protection of personal data.
We are responsible for and will at any given time be able to demonstrate compliance with the Data Protection Laws as well as our principles set out in this Privacy Statement. We shall maintain records of processing activities under our responsibility containing the information required by the Data Protection Laws and where applicable make the records available to the supervisory authority on request.
Any inquiries concerning this Privacy Statement can be directed to the DPO email: support@skypaid.eu
Complaint
You have the right to file a complaint concerning our processing of your personal data. All queries and complaints shall be handled in a timely manner by the DPO in accordance with internal procedures. Complaints can be submitted to the DPO email: support@skypaid.eu.
In the unlikely event that you consider that our processing of your personal data infringes any Data Protection Laws, you may also lodge a complaint with a relevant supervisory authority.
Changes to this Privacy Statement
This Privacy Statement may be updated from time to time, e.g. due to modifications of relevant legislation or changes to our corporate structure. If any material changes are made, you will be notified by email or by means of notice on the website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact
Sky Services and Partners S.R.L. t/a SkyPaid
Data processing on social media platforms
We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.
Due to our legitimate interest, If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries.
We maintain profiles on the following social media platforms. For detailed information on data processing and privacy, please refer to the respective privacy policies: