July 15, 2022
WayAway is a multifunctional software product offering its users certain online travel related services and features as defined in its Terms of Use. For the purposes of these Privacy and Cookie Policies, WayAway shall be considered as a software product at WayAway.io as well as at any official WayAway third level domains or subdomains (hereinafter “WayAway”).
User privacy is important to us and we do whatever is required to protect it. In terms of Data Processing, we ensure your rights as Data Subjects and observe the regulations of the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act and other applicable legislation of other states along with regulations of relevant state authorities as well as other applicable laws and rules. In this Policy, we aim to openly explain how we will possess your data and what processing standards we follow.
The present Policy includes our Cookie Policy, which is an integral part of our overall policies. Please note that this Policy is closely related to the Terms of Use, where you can find more information about how WayAway functions, as well as your rights and liabilities when accessing the service.
Pay close attention to this Policy. If you have any questions after reading this Policy or if you find any errors or inaccuracies, please contact our legal team. Please describe your problem or question in detail so that we can quickly respond to it, help you, or correct the error and improve our services in the process.
We reserve the right to change this Policy if we make changes to our processing procedure or need to take newly-enacted personal data protection legislation into account. We’ll notify you in case of significant changes that may affect your interests, rights, and status. We guarantee that the protection of your personal data is always legitimate and fair, and that your data is secure.
For starters, let’s clarify some key terms that we will use in this Policy to eliminate the possibility of misinterpretation.
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 provides for a wide range of personal identifiers to constitute Personal Data, including an email address, identification number, device information, location data, or online identifiers, such as cookie files or similar technologies.
Sensitive information means special categories of personal information, as defined by subdivision (ae) of 1798.140 of California Privacy Rights Act (CPRA), that for instance include such identifiers as passport, social security, driver’s license, credit card or debit card numbers and other details of a consumer’s personal and financial documents as well as their precise geolocation and biometric data.
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.
The terms “You”, “your”, or “Data Subject”, and “Consumer” refer to visitors of the WayAway web-resource, authorized users, subscribers 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. For the purposes of this Policy, the Data Controller is Go Travel Un Limited, a Hong Kong corporation registered under the number 1658681 with a legal address at Suite 1504, 15/F, Chinachem Tower, 34-37 Connaught Rd Central, Hong Kong, doing business as WayAway.
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 the 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 the “Data Processing conditions and principles” section 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 Subjects. Profiling is done to analyze or predict aspects concerning that specific Data Subject’s preferences and interests while using a particular service of ours.
Account refers to a section of WayAway that is available to you after authorization (signing up) and gives you access to certain services and features, which improve your user experience and that can not be accessed without authorization.
We can use other terms and definitions as well, even if they are not explicitly specified in this section, as long as they are set out in the applicable legislation or in our Terms of Use.
When you use WayAway and its features or when you contact us, we may collect and process any data and information that you provide to us voluntarily or that is collected automatically, or data that we receive from other sources.
This includes any information you provide to us yourself, 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 our products (e.g., WayAway Plus subscription), send us a query or feedback, participate in discussion boards or other social media functions via WayAway and our marketing special project subdomains, complete promotions or surveys, or report a problem. We may also process data you provide to our partners, including airlines and OTAs, while making a booking after redirection.
Voluntarily provided data may include the following:
Personal information:
Sensitive information:
This mostly consists of online identifiers or technical facts about your connection point. For example, device and connectivity information, such as your 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 your 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 our websites and/or use our services/features. In some cases, this data can be created by our software or third-party programs, integrated into WayAway’ software.
The list of data categories that may be automatically collected by us includes the following information:
You can find more information on cookies and similar technologies in our Cookie Policy.
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 partners.
For example, we might insert advertising on our partner websites, social networks, or advertising networks that may categorize WayAway users with similar characteristics or interests into non-personally-identifiable data segments, which may then be offered to their own 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 personally-identifiable location information), and any user interactions with said ad or information about the page on which it appears. This information is used for statistical purposes, analysis, reporting, and troubleshooting. In most Data Processing situations, such information does not allow us to identify you as a Data Subject and will be processed with an appropriate level of protection and limitations, which the data source establishes.
We also might collect your log-in information when you enter your Account via an applicable authorization tool that is used on WayAway. Such information is provided by a third party depending on what method you use for authorization from the list below:
We do not process data on children, as WayAway is intended only for use by users over the age of 16 (or other ages of maturity determined by applicable local laws allowing for the independent use of Internet services like WayAway). If you are under the specified age, you may only use WayAway with the involvement of your guardian or holder of parental responsibility. We do not knowingly collect or process personal information from children under the specified age without the consent of the child's holder of parental responsibility. In case of doubt, we will cease the processing of questionable data and delete it.
We do not collect and process special categories of personal data and genetic data without your direct consent, such as your name, age, email, passport, and payment method details (unless you subscribe to our marketing mailing, purchase a WayAway Plus subscription or log in to your Account), phone number, home address, etc.
We do not process data that you have directly asked us to stop processing or opted out in any other way.
We also do not process any data acquired by third parties on other platforms that you click out to from our web-resources. For instance, by clicking on the ad banner, except for cases and particular data types directly mentioned in this Policy. Your Data Processing on third-party platforms is carried out according to the rules and processes set out by owners of those platforms.
Please note that, when you proceed with purchasing flight tickets or other travel services after redirection from our web-resources to the provider carrying out the particular service, we do not acquire, store, transmit, or process any additional information except depersonalized information, such as prices, dates, destinations, and a transaction identifier.
In providing personal data about other individuals (such as someone whose name you are using to enter an Account or subscribe to our marketing promotions), you represent that you have notified them 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 this 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 assure that we do not sell personal data to any third party. However, we may share your personal information to our partners for business and commercial purposes as described above and in the “Data Processing conditions and principles” section of this Policy. Read the last section of this Policy and the Cookie Policy learn more about your right for opt out of sharing of your personal information and the ways in which you can exercise this and other rights regarding the subject matter.
Email marketing and communications. We believe that WayAway users would like to get more information concerning travel that is useful to improving their possible travel experience as well as information about the best deals on flight tickets, other travel products, and more (commercial information). In addition, users would like this information to meet their own needs and interests. Upon authorization in the Account or when using particular functions of the service, we offer you the chance to subscribe to our marketing newsletter to receive such news and third-party ads. You can unsubscribe from direct marketing communications by email at any time by using the opt-out form in one of the received emails or by contacting our support team.
Profiling. It’s important for us to understand the WayAway audience, including their needs and preferences, in order to make the service better and more convenient both generally and for each particular user. To achieve these goals, we can create profiles of our users based on the data collected in their interactions with WayAway in order to provide our service in the best possible way or provide personalized ads and marketing communications if we’ve received your consent. In any case, we never use collected data to make automated decisions that significantly affect your interests or rights as a Data Subject.
We never show our users different prices on the analogous services they may find using our metasearch engine and we never prohibit or block the use of a particular feature of WayAway solely based on your online profile.
In this section of the Policy we outline the legal grounds and purposes for processing personal data in your interaction with WayAway, related domains, or individual features of our products, which may also be available on our travel network 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 a suitable 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 for instance, to provide search results or resolve an issue; (2) to email marketing information about WayAway 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, we fulfill our obligations to these partners to properly record bookings and statistics on our end. In addition, user data is processed in our legitimate interests, for example, to improve the performance of WayAway or a particular feature of the metasearch service, prevent fraud, data parsing, etc.
Data Processing purposes are largely determined by WayAway’ functionality and derive from grounds for Data Processing. Primarily, we strive towards improving our service and making your experience with WayAway efficient, secure, convenient, and personalized. We also want to keep you updated on our new features, products, promo campaigns, special WayAway projects, other interesting and bargain deals in the travel market, and more, by sending you gripping articles and sources with potentially useful information for travelers. Other interesting and beneficial deals in the travel market and more. In addition, we attract income by displaying third-party ads and can process data to track ad performance or select ads that may suit you better.
To make it more readable, we gathered all the grounds, potentially applicable purposes, and the data being processed on said grounds and for said purposes in the table below.
|
Data category |
Grounds |
Purposes |
|
Contact information (typically, an email address, but sometimes a name and social network 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 |
|
Search data
|
Fulfillment of obligations, legitimate interest |
(1) Provision and personalization of features and services, (2) necessary internal analytics and research of the service |
|
Account data |
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 |
|
Device data |
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 WayAway 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 |
We believe that the confidentiality and security of our users’ data is key to maintaining long-term trusting relationships with them. We are committed to protecting the personal data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your personal data from unauthorized access, use, or disclosure.
At WayAway, we use the 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 particular resources, Profiling, email marketing, and supporting interactions with you. Providers of such services are carefully selected based on WayAway’ specifics and ensure the safety of data at the appropriate level, according to the present Policy. In some cases, such providers help us collect cookies and similar technologies. You can learn more about them in the Cookie Policy.
We retain your personal information for as long as required on the grounds of processing purposes. Terms may also differ for particular categories of personal information.
We also reserve the right to store various types of information (without any time limit) to use for analyzing our service performance, improving its features, providing services to you, and protecting the interests of WayAway.
Meanwhile, 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 the Policy.
We share personal information about you with third parties or non-affiliated companies until you notify us of your decision to opt out of sharing your personal information, except regarding the processing that takes place in order to provide services you've requested, or under the following circumstances:
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.
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 personal information. You can request us to disclose an exact description of categories and sources of personal data we collect and what are the purposes of collection and sharing your information, who are the third parties we share your data with and the list of specific pieces of personal information we have collected about you.
The right to correct or rectify your personal dataif it is inaccurate, incomplete, or outdated. You are entitled to make corrections on the personal data you have provided us with during the registration procedure using special interface features in your Account at any time.
The right to 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 it any further.
Rights related to automated decision-making, including Profiling. We do not make any decisions that might produce legal consequences for 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 the Data preferences menu.
The 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 said Data preferences menu (Do Not Share My Personal Information).
The right to limit the use of your Sensitive Information.Please be informed that we use your sensitive information solely to provide you with the services under the contract that 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 to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with your local supervisory authority if you have a concern about our processing practices.
The right of no retaliation following opt out or exercise of other rights. You have the right to exercise all of the abovementioned rights free of charge and without any following retaliation or discrimination against you. We respect your privacy rights and will not charge you or deny you any services should you prefer to keep your personal information private and decide to exercise any of the said rights. However, some of WayAway's functionality/products are technically based on processing your data and we may not be able to perform the respective services without certain data about you.
You can exercise all of your above rights (if implied) by contacting us or using the available opt-out or «manage your privacy» functions within the service.