Privacy Policy

Policy owner: Abraham Jaime

Effective Date: 27-11-2023

Table of contents

  • Introduction
  • How we collect and use (process) your personal information
  • Information we process on behalf of customers when they use our product
  • Use of the Deal Engine website
  • Cookies and tracking technologies
  • Lawful basis under which we process your data
  • Sharing information with third parties
  • Transferring personal data to the U.S.
  • Data subject rights
  • Data storage and retention
  • Security
  • Children's data
  • Questions, concerns, or complaints
  • Data Protection Officer
  • Our EU and UK Representatives

Introduction

The Deal Engine is a travel software company. Our mission is to bring digital transformation to the travel industry. Utilizing proprietary AI and APIs, Deal Engine brings automation to travel, eliminating manual processes, and making sure people spend their time, where they generate more value.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes the Deal Engine’s policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

How we collect and use (process) your personal information

Deal Engine collects personal information about its website visitors and customers. With a few exceptions, this information is generally limited to:

  • name
  • job title
  • employer name
  • work address
  • work email
  • work phone number

We use this information to provide prospects and customers with services. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services. From time to time, Deal Engine receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third party website (e.g. LinkedIn)

Information we process on behalf of customers when they use our product

Our Product assists airlines in processing refunds efficiently. When our customers use our services, they may collect necessary personal data, such as passenger names. It's important to note that we act as a data processor, handling personal data strictly under the explicit guidance of our customers, who function as the data controllers. Our clients are responsible for complying with all relevant regulations and laws, including providing notice, disclosure, and obtaining consent before sharing personal data to use our services.

Use of the Deal Engine Website

As is true of most other websites, Deal Engine’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of Deal Engine’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs.

We may also use your IP address to help diagnose problems with our server and administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Deal Engine has a legitimate interest in understanding how members, customers, and potential customers use its website. These assist Deal Engine with providing more relevant products and services, communicating value to our sponsors and corporate members, and providing appropriate staffing to meet member and customer needs.

Cookies and tracking technologies

Deal Engine makes available a comprehensive Cookie Policy that describes the cookies and tracking technologies used on Deal Engine website and provides information on how users can accept or reject them.

Lawful basis under which we process your data

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new customer.
  • Identity
  • Contact
  • Performance of a contract with you
  • Consent
To process and deliver the products and services you request.
  • Identity
  • Contact
  • Performance of a contract with you
  • Consent (Cookies Policy)
To manage our ongoing relationship with you which will include notifying you about changes to our terms, services, or privacy policy, to maintain our records.
  • Identity
  • Contact
  • Profile
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests to keep our records updated and to study how customers use our services
  • Consent
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
  • Identity
  • Contact
  • Technical
  • Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of business Reorganization or group restructuring exercise
  • Necessary to comply with a legal obligation
  • Consent

Sharing information with third parties

The personal information Deal Engine collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, Deal Engine engages third parties to send information to you, including information about our products, services, and events.

A list of our third party sub processors can be found here: Help Scout and Google Analytics.

We do not otherwise reveal your personal data to non-Deal Engine persons or businesses for their independent use unless: (1) you request or authorize it; (2) it’s in connection with Deal Engine-hosted and Deal Engine co-sponsored conferences as described above; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God; or (6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

The Deal Engine website connects with third-party services such as Facebook, LinkedIn, Twitter, and others. If you choose to share information from the Deal Engine website through these services, you should review the privacy policy of that service. If you are a member of a third-party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.

Transferring personal data to the U.S.

Deal Engine has its headquarters in the United States. Information we collect about you will be processed in the United States. By using Deal Engine’s services, you acknowledge that your personal information will be processed in the United States. Deal Engine is providing appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.

Depending on the circumstance, Deal Engine also collects and transfers to the U.S. personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Deal Engine in a manner that does not outweigh your rights and freedoms. Deal Engine endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Deal Engine and the practices described in this Privacy Statement. Deal Engine also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Deal Engine has received zero government requests for information. For more information or if you have any questions, please contact us at: privacy@deal-engine.com

Data Subject rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

  • Right to be informed
  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restrict processing
  • Right of data portability
  • Right to object
  • Rights related to automated decision making including profiling

This Privacy Notice is intended to inform you about what personal data Deal Engine collects about you and how it is used. If you wish to confirm that Deal Engine is processing your personal data or to have access to the personal data Deal Engine may have about you, please contact us.

You may also request information about the purpose of the processing; the categories of personal data concerned; who else outside Deal Engine might have received the data from Deal Engine; what the source of the information was (if you didn’t provide it directly Deal Engine); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Deal Engine if it is inaccurate.

Likewise, you may request that Deal Engine erase that data or cease processing it, subject to certain exceptions. You may also request that Deal Engine cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Deal Engine processes your personal data. When technically feasible, Deal Engine will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Deal Engine will provide you with a date when the information will be provided. If, for some reason, access is denied, Deal Engine will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at: privacy@deal-engine.com.

Data storage and retention

Your personal data is stored by the Deal Engine on its servers, and on the servers of the cloud-based database management services the Deal Engine engages, located in the United States. The Deal Engine retains service data for the duration of the customer’s business relationship with the Deal Engine and for a period of time thereafter, to analyze the data for Deal Engine’s operations and for historical and archiving purposes associated with Deal Engine’s services. Deal Engine retains prospect data until such time as it no longer has business value and is purged from Deal Engine systems.

As a company, we are dedicated to safeguarding the personal data of our customers and employees. Under this commitment, we comply with the principles of the General Data Protection Regulation (GDPR) when collecting, utilizing, and handling personal data. This includes adherence to the principles of legality, fairness, and transparency; limiting data collection to specific purposes; minimizing the amount of data collected; ensuring accuracy; limiting data storage; maintaining integrity and confidentiality; and being accountable for data protection.

All personal data that Deal Engine controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: privacy@deal-engine.com

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Where required under GDPR will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Children’s data

We do not knowingly attempt to solicit or receive information from children. If it comes to our attention that we have inadvertently collected information from a child, we will promptly take steps to delete that data from our records.

Questions, concerns or complaints

Deal Engine is a travel software company headquartered in Miami, in the United States. If you have questions, concerns, or complaints, or would like to exercise your rights, please contact us at: privacy@deal-engine.com

If you remain dissatisfied, then you have the right to apply directly to your local data protection authority. You can find the list at: Data protection authorities.

Data Protection Officer

Under Article 37 of the GDPR we have appointed a Data Protection Officer for you to contact if you have any questions or concerns about Deal Engine’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Deal Engine’s data protection officer. Deal Engine’s data protection officer’s name and contact information are as follows:

Adam Brogden

GDPR Local Ltd

contact@gdpr.com

Tel: +441 772 217 800

1st Floor Front Suite 27-29 North Street, Brighton, England BN1 1EB


Our EU Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:

Instant EU GDPR Representative Ltd.

Adam Brogden

contact@gdprlocal.com

Tel: +35315549700

Office 2,

12A Lower Main Street, Lucan Co. Dublin

K78 X5P8,

Ireland


Our UK Representative:

Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is GDPR Local Ltd.

Instant UK GDPR Representative Ltd.

Adam Brogden

contact@gdprlocal.com

Tel: +44 1772 217800

1st Floor Front Suite,

27-29 North Street, Brighton

England