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Privacy Policy

SILVAWHEEL.COM PRIVACY POLICY

ABOUT THIS POLICY

This policy explains how we collect and handle your information across all of our websites, mobile apps and other services. We’ll review this policy from time to time to make sure it’s up-to-date. If we make changes, we’ll post the latest version here. When we make significant changes, we’ll let you know when you next access our services, or by other communications.

Learn more about this policy

You’ll come across the term ‘personal data’ a lot in this policy. By that, we mean any information relating to you as an identifiable individual. For example, this includes information that may of itself identify you such as your name, contact details, trip itinerary, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.

We can only speak for ourselves so this policy doesn’t cover the collection or use of your information by any of the airlines, online travel agents, hotels, car hire companies or other travel companies (let’s call them “Travel Suppliers”) we feature. That means when you make a booking with a Travel Supplier, your information will be processed by them in accordance with their own privacy policy and terms and conditions. But don’t worry, we’ll always give you the links so you can read them before making a booking.

WHY AND HOW DO WE USE YOUR PERSONAL DATA?

We only use your information where you’ve given us your consent, where its necessary to deliver the services you’ve requested, where it’s necessary to exercise or comply with legal rights or obligations, or for normal business purposes of the kind set out in this policy.

Learn more about why and how we use your personal data

When we need to do so to deliver our services or facilitate the performance of a contract you’ve entered – or are entering – into, such as making a booking with a Travel Supplier.

How we use personal data to perform contracts.

Ensuring our services are accessible and usable by you on your specific device, for example by altering the way we display information to you based on your device type;

Generating results in response to your search queries, for example providing you with a list of the flight, hotel or car-hire options that best meet your requirements;

Where you select a Travel Supplier that you’d like to make a booking with either:

1- Redirecting you to their platform along with whatever data is necessary to enable them to recognise you and the travel option you had selected on Silvawheel, including data about your browser or device and the details of your travel search; or

2- Contacting you with messages, notifications or alerts that are necessary in order to deliver our services requested, such as booking confirmation emails or other essential communications like flight status alerts and notifications about changes or updates to our services or to this policy, our Cookie Policy or our Terms of Service;

3- Responding to communications you have sent us, such as via our customer service help centre or on social media;

4- Where you have created an account with us, maintaining and administering this and ensuring that it is kept up-to-date and accessible;

To improve or optimise our services and to otherwise protect or further our legitimate interests. This includes pretty serious reasons like fraud prevention and security but also fun ones like product enhancement so we can keep making Silvawheel even better for our travellers.

5- Identifying and correcting faults with our services or areas for improvement through use of information like browser type, operating system, locale and language information and general site activity alongside any specific feedback you may provide to us from time to time;

Providing customer service or help services to you in relation to any questions you raise or issues you might encounter while using our services. For example, although it is the ultimate Travel Supplier who is responsible to you for any issues you might have with a flight, hotel or other travel service you’ve booked via Silvawheel, if you or the Travel Supplier contacts us regarding an issue with your booking we’ll need to use some of your personal data to be able to assist you;

6- Understanding and evaluating how, when and why people are using Silvawheel for the purposes of delivering, evaluating, improving and optimising the delivery of our services. For example:

monitoring the numbers of users who redirect to, or make bookings with, Travel Suppliers and details of the related travel options being selected for the purposes of commercial records and business analytics;

analysing at an aggregate level what different groups of users may be viewing or clicking on within our services in order to better understand which features or functionality are more popular or helpful than others;

reviewing and moderating any User Content that you upload to the Silvawheel Services;

7- Personalising your experience of our services in order to ensure your experience on Silvawheel is as helpful, efficient and relevant as possible. For example:

we will use cookies to remember your language and currency preferences and may also personalise your experience by highlighting or recommending certain information or travel options that we believe are relevant to you based on your search history on Silvawheel and use of our services;

if you have asked us to send you newsletters or other marketing communications, we may tailor the timings or content of these to reflect what we believe will be of most interest to you, such as by using the fact that you’ve recently searched for a flight in United Arab Emirates to prompt us to ask whether you’d like to search for a hotel in Dubai as well;

we may use your location information to predict which airport you are likely to want to depart from or arrive back to; and

displaying relevant advertisements to you about our services or other services that we think may be of interest to you. For example, where we know that you’ve recently searched for a flight to a given location, we may display a message to you asking whether you’d like to search for a hotel or car in the same location.

8- Personalising your experience involves us creating a profile and timeline of your activity on our services. However, we are careful to ensure that our activities do not involve undertaking any profiling or automated decision making that might have any legal or other significant effects on you.

9- We may use your data to train our machine learning algorithms to help us personalise the Services. We will not use directly identifying information such as your contact details or payment data for these purposes.

10- Informing strategic business decisions through creating aggregated datasets of anonymised data that allow us to generate helpful insights into patterns or trends within the travel industry. For example, we can use search data to monitor demand for destinations and make sure that the fares and travel options that we surface to our users are available via our services. This information is also useful for Travel Suppliers as it enables them to identify new routes or locations that are in demand and ensure they are delivering competitive rates.

11- Contacting you in order to invite you to participate in genuine market research.

Where we process your personal data based on a legitimate interest we will only do so where the processing is relevant, adequate and limited to what is necessary for the purpose it was collected for. And of course, we’ll always ensure our legitimate interests don’t unfairly impact on your own rights and freedoms.

WHEN WE HAVE YOUR CONSENT.

We will obtain your consent for purposes such as:

sending you emails for services you request such as Price Alerts;

sending you direct marketing communications via email, push notification or other means where you have consented to us doing so;

storing certain cookies on your device, where doing so requires consent; and

recording and evaluating feedback you give us where you agree to take part in one-to-one user testing.

12- Where we process your personal data based only on your consent, you can withdraw this consent at any time either by using the functionality provided within the appropriate product feature or by contacting us.

Where it’s necessary to exercise or comply with our own legal rights or obligations.

13- We may need to retain and use your information in connection with legal claims, or for compliance, regulatory and auditing purposes. For example we may retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any applicable legal rights you have to access, amend or delete your personal data, we may request identification and verification documents from you for the purpose of confirming your identity.

WHAT PERSONAL DATA DO WE COLLECT?

14- Everyone who uses our services will have bits and pieces of information about them collected, stored and processed. However, we don’t collect more information than we need.

We can’t help you plan and book your dream trip without information. So, when you use our services, we have to collect, keep and share some personal data and ask that you agree to that in line with this policy. We collect information in three ways:

1. You give it to us voluntarily

Information you choose to give us might include personal data needed for you to book travel for yourself and others. This ranges from the dates and destination you choose in a search, to the basic stuff for making a booking with a Travel Supplier such as names and contact details. It can also include content like the reviews or photographs you upload to our services to share with other travellers. Most importantly, it’s always up to you whether or not you choose to give us this kind of information.

2. We generate or collect it automatically

We generate or collect some information from your computer or device automatically as you use our services. This includes stuff like your IP address, information about the device and browser you are using to access our services, the website URL you visited us from and the third party sites you visit when you click on links to exit the Silvawheel site. It also includes details of the bookings you have made via Silvawheel. We may also know your location from your mobile or your IP address. This helps us to improve your experience and make sure you receive the content that’s most relevant to you.

3- We receive it from third parties

Sometimes we’re given information about you from third parties, depending on how you choose to interact with us. For example, when you come to our website via a promotional partner, or when you log into your Silvawheel account using our social network login feature. And, if you’ve made a booking with a Travel Supplier, we might collect information from them about whether you went ahead with your trip, what you booked and whether your booking was successful. We may also collect information about you from fraud prevention services providers we cooperate with to prevent misuse of your personal data.

We receive it from third parties

15- Our services are not intended for children under 16 years of age, and no one under the age of 16 should provide any information to, on or via our services. We don’t knowingly collect personal data from children under 16, and will delete any that we learn we have collected or received that was not provided by, or with express consent on behalf of, the child’s parent or legal guardian.

Depending on how you interact with our services, we may collect or process the following categories of personal data via the three different ways explained above.

Contact Information:

such as your name, address, email address, telephone number and other similar information.

Travel and Booking information:

such as your booking reference, booking history, passenger name record (“PNR”), identification or passport information and travel itinerary.

Demographic Information:

your age, gender, location and preferred language when you use our services.

Device and Location Information:

generic details from your device such as your IP address, type, make, model and operating system of your device;

specific location data based on GPS data from your mobile device (when you grant us access to this information via your device settings); and

non-specific location based on your IP address.

Usage and Profiling Information:

your Silvawheel search history and travel preferences;

how you’ve interacted with our services, including time you spend on our site and/or app and the pages, features or functionality you have accessed;

links you have clicked on to be redirected to or from our services, including the identity of the Travel Supplier you are redirecting to and the type of travel service you have selected; and

where you’ve redirected to a Travel Supplier’s website or app for the purposes of completing a booking, we may collect information from that Travel Supplier about whether and what you went on to book with them.

Preferences Information:

selected preferences associated with your Silvawheel account including specific consents you have given or declined, email and push notification preferences and cookies containing your advertisement preferences.

Communications Information:

includes communications we receive from you such as feedback, help requests and queries via email and other electronic communication methods such as online chat, instant messaging or social media; and

metadata associated with those communications, such as time and date.

User Generated or Provided Content:

content you upload to our services including comments, photos, videos, recommendations, preferences and reviews and metadata such as the time and date associated with that content; and

any information you submit to us during the course of any correspondence you may have with us, such as signatures, photographs, opinions and, where you are applying for a job with Silvawheel, details of your employment history, salary and other similar information.

Social Media Information

email address is automatically collected by us from the third party social media platform you log in to Silvawheel from.

How long do we store your personal data?

17- We keep your personal data only for as long as we need to. This depends on why it was collected, or if we have a continuing legal basis to do so (such as to fulfil a contract between us, perform a service you requested or for our legitimate interests). Rest assured, if we no longer have a reason or legal requirement to process your personal data, we will delete it or store it in a way so that it no longer identifies you.

We have different retention policies for different types of personal data, taking into account:

The purpose for collecting the personal data;

How long it will take to fulfil that purpose; and

Any specific reason or overriding legal obligation to retain the personal data for a specific amount of time.

Also, if you have an account with us, we will keep personal data such as your email address, name and other details so you can log in and access our services for as long as you have an account. We may keep other information indefinitely – such as site activity linked to an IP address – which we use to help us understand our travellers, improve our products and services and protect our business interests.

No matter how long the retention period, you can ask us to delete your personal data in certain circumstances.

When is your information shared with or collected by third parties?

18- We share your information only where you ask us to, where it’s a necessary part of doing business with you and providing you with the services, or where we need to for legal reasons. Companies you book with via Silvawheel (like airlines or hotels) will collect your data in line with their own policies. Sometimes companies that advertise via our services may also collect your information. Finally, companies that help us deliver our services will also collect and use your data on our behalf.

Learn more about how we share or allow others to collect your information

Sharing personal data with third parties who process it only under our instruction

We share information relating to our users with selected third parties who provide us with a variety of different services that support the delivery of our services (let’s call them “Third Party Processors”). These Third Party Processors range from providers of technical infrastructure to customer service and authentication tools. We require any Third Party Processor which handles information on our behalf to do so pursuant to contractual terms which require that the information is kept secure, is processed in accordance with applicable data protection laws, and used only as we have instructed and not for that Third Party Processor’s own purposes (unless you have explicitly consented to them doing so).

Third Party Processors may be located in, or process your information, outside of the country in which you are based. Where our use of a Third Party Processor involves the transfer of personal data from within Europe to a location outside of the European Economic Area, we will put in place appropriate measures to ensure that the personal data is adequately protected in that location, most often by applying European Commission-approved standard contractual clauses alongside robust security checks.

The types of Third Party Processors we may share elements of your personal data with include:

providers of email management and distribution tools – for example, if you sign up to receive Silvawheel newsletters or other marketing messages we will manage the delivery of these to you using a third party email distribution tool;

providers of security and fraud prevention services – for example, we use these providers to identify automated software agents that might disrupt our services or to prevent misuse of our APIs;

providers of data aggregation and analytics software services that enable us to effectively monitor and optimise the delivery of our services;

providers of tracking tools that we use to monitor instances where you click on a link to a Travel Supplier’s website and redirect from the Silvawheel platform to that Travel Supplier’s;

providers of software platforms that assist us in communicating or providing customer support services to you – for example, we manage and respond to any messages you send to us via our help centre using a third party communications management tool;

providers of online cloud storage services and other essential IT support services; and

other companies within the Silvawheel group, for the purpose of supporting the delivery of our services to you.

Sharing your information with third parties, or allowing them to collect it, for processing outside of our control

If you are purchasing travel with a Travel Supplier from within our services’ booking platform, any personal data you submit as part of the booking process will be shared with the relevant Travel Supplier and/or a third party contracted to provide services on their behalf, in order to enable the booking to processed. When we share your personal data in this way, you’ll get an opportunity to review the Travel Supplier’s privacy policy and terms and conditions first. Before completing any purchase, we recommend that you carefully review these documents in order to understand how that Travel Supplier will use your information. We may also share personal data with the Travel Supplier for their, or our, standard verification and fraud-detection purposes.

In order to prevent and detect fraud, we may share information about you with the fraud prevention services providers we cooperate with (“Fraud Prevention Providers”).

Travel Suppliers and Fraud Prevention Providers may be located in, or process your information, outside of the country in which you are based. For example, if you are booking a flight that operates within a particular country you should expect that your personal information will be transferred to, and be processed by Travel Suppliers that are located in that country. The regulations in these countries may not provide the same level of protection of personal data as the regulations in your own country of residence.

We will share personal data with third parties where you expressly authorise us to, such as where we run a promotion in conjunction with a partner and you instruct us to share your email address with that third party for the purpose of receiving promotional emails.

Publicly accessible personal data included in User Content such as your name, likeness and the content of reviews and posts may be shared and/or made available to carefully selected third parties with whom we have a contractual relationship for the purpose of displaying this content for their similar travel-related services.

We may share and/or make available your publicly accessible personal data such as your name, profile picture, reviews, traveller photos and posts to carefully selected third parties with whom we have a contractual relationship.

Certain information may also be collected from you by third parties such as advertisers, marketing networks and affiliates using cookies and similar technologies. For example your IP address and events relating to your activity like searches you have carried out or pages you have viewed on Silvawheel may be collected and transmitted to these third parties to allow them to serve relevant advertising to you across the web. The information that is collected in this way will never include your name, contact details or other information that would enable you to be identified in the offline world.

Disclosing information for legal and other reasons

We may disclose your information where necessary to a prospective or ultimate buyer if Silvawheel itself (or part of our business) is sold. We may also disclose your information if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage or where necessary in response to legally binding requests, legal action against us, or to enforce our rights and claims.

How do we keep your personal data secure?

19- Safeguarding your privacy is embedded in our culture and we use a combination of industry-standard methods to protect it.

Learn more about how we keep your personal data secure

Keeping your personal data secure is our highest priority. We limit access to only those Silvawheel group employees who have to come into contact with your information to do their jobs and deliver our services.

Unfortunately, no website or app can guarantee complete security but we have created an organisation-wide security programme designed to keep your personal data as safe as possible. It uses a range of technical, organisational and administrative security measures and best-practice techniques, depending on the type of data being processed. For example, the computer systems we use to store your data have access limitations and in-cloud based servers that use industry-standard disc encryption. We use TLS and HTTPS encryption to protect your personal data when we transfer it across the internet. And we carry out security assessments on Third Party Processors who handle your data.

To make sure we maintain a culture of ‘Privacy by Design’, we provide thorough data protection and privacy training to all Silvawheel group employees. We develop our services with the goal of using the minimum amount of personal data possible, including through use of data minimisation techniques like anonymisation and pseudonymisation. Also, whenever we develop or update our services in ways that involve the collection or use of new forms of personal data, we conduct a privacy impact assessment to understand, and reduce, the likelihood of any unintended impact on you.

Where do we store your information?

20- Your data is securely stored in data centres around the world – the exact location depends on where you are when you use Silvawheel. Your data will only be processed by suppliers who provide appropriate contractual safeguards for the information they process. Sometimes your data may be stored in countries with different levels of security to your own but we always make sure their standards meet ours.

Learn more about where we store your information

Sometimes the countries that your data is transferred to, or stored in, may have different, or less stringent, data protection and security standards than your own. However, subject to the local laws in these countries, we’ll provide the safeguards needed to protect your data regardless of location. We do this through a combination of appropriate technical, organisational and administrative security measures, and by putting in place the necessary legal contracts to backup these requirements. For example, we will only store European users’ personal data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

How is your information used for advertising?

21- You’ll see various adverts when you use our services and might also see adverts about Silvawheel when you’re on other platforms. These adverts might come from us or from third parties and may be personalised to make them more relevant to you. The information used to personalise adverts you see may include your details of what you’ve searched for on Silvawheel or general location information at a city or airport level, but will never include your name, contact details or other information that would enable you to be identified in the offline world.

Learn more about how your information is used for advertising

Adverts you might see whilst using Silvawheel:

You’ll often see adverts while using our services. These will either be delivered by us directly or by third party advertising solution providers we partner with (let’s call them “Third Party Ad Solutions”).

The majority of these adverts will be personalised to make them relevant to you and will fall into two different categories. Firstly, adverts that are personalised for you based on information collected by us or by Third Party Ad Solutions whilst you use our services, such as your general location (by city or country) and your Silvawheel searches or booking history (“Silvawheel-related Information”). So, for example, if you’ve booked a flight to Rome, you’ll see adverts about hotels in Rome, rather than hotels in Paris (Paris is lovely, but this could be a bit annoying!). Silvawheel-related Information will never include your name, contact details or other information that would enable you to be identified in the offline world. Secondly, adverts that are personalised for you based on information that we have no visibility or control over, and which is instead collected from you by Third Party Solutions when you have been using other non-Silvawheel websites or platforms (“non-Silvawheel Platforms”). Collectively, we refer to these as “interest-based” advertisements.

The information required to deliver these interest-based advertisements will be stored by Third Party Ad Solutions alongside your IP address and/or a cookie ID, so that you can be served the adverts without the Third Party Ad Solutions needing to store any information that would enable you to be identified in the offline world, like your name or address.

When you are opted-in to ads personalisation we may also use information we collect via cookies and similar technologies to show you personalised ads, marketing and promotions on Silvawheel, or to send you communications where you have opted in to receive these. For example, where you book a flight using Silvawheel or redirect from Silvawheel to make a booking on one of our partner sites, we may use the information we collect via cookies and similar technologies to personalise the ads we show you or to send you personalised marketing communications relevant to your booking based on information like your destination, the time you are travelling, the services you’ve selected or which travel supplier you are travelling with. We may also use this information to provide you with relevant information about the destination you are travelling to such as City Guides or up to date weather information or to request reviews and recommendations about the places you have visited.

Adverts you might see whilst on non-Silvawheel platforms

You might also see adverts for our services once you’ve left Silvawheel and are using non-Silvawheel websites. For example, this would happen where a non-Silvawheel Platform that you use makes advertising space available for sale and Silvawheel, or a Third Party Ad Solution that we work with, purchases that space. Similar to the adverts you see whilst using Silvawheel, these adverts may be personalised and served to you because of information that Third Party Ad Solutions have collected about you, either when you were using our services or when you were using other non-Silvawheel Platforms. For example, if you have searched for a flight from Edinburgh to London on Silvawheel or another non-Silvawheel Platform, and we have asked Third Party Ad Solution to show our advert to individuals that have expressed an interest in travelling to London, the Third Party Ad Solution may categorise you within that group and serve you our advert.

Do we use cookies or similar technologies?

22- We use cookies and similar technologies to help deliver, optimise, personalise and analyse our services and for advertising purposes.

Learn more about cookies and similar technologies

We use a combination of cookies and other technologies such as pixels/web beacons and tracking codes (explained below) to collect information for use in line with the purposes set out in this policy.

What is a cookie?

23- A cookie is a small data file that is stored on your computer or device. Cookies record things like your preferences and settings, helping to give us the information we need to provide you with the most consistent and relevant experience. We also use cookies to record information about experiments or new improvements we might test to track how you use our services and find out whether they were effective.

Cookies on our website may be set by us, third parties we’re working with, or independent third parties (such as advertisers).

What are web beacons and pixels?

24- Web beacons or pixels are small, transparent image files inside a web page or email. We use them to understand how you interact with our services, or if you’ve redirected to a Travel Supplier’s website or app. We might use the pixel to confirm if you went on to book with them, and what you booked. We also use pixels to gather information such as whether you’ve opened an email, so that we can improve our communications to you.

What are tracking codes?

25- Tracking codes are snippets of code placed in the page to measure things like visits and interactions. We use tracking codes to find out more about how you interact with our services, the adverts you see and more generally, how you use us.

What are your choices and rights?

26- If you’ve got a Silvawheel account, you can access, edit, download or delete the key personal data associated with your profile at any time by going to your Profile. From here you can also manage your subscription and marketing preferences.

You also have rights in relation to the personal data we have about you, which we explain in more detail below. You can exercise these rights by getting in touch with us.

Learn more about your choices and rights

You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you have provided to us in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Silvawheel processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.

To the extent that you’re unable to satisfactorily exercise any of these rights via your Profile, you can do so by contacting our Data Protection Officer by mail at info@Silvawheel,com

If you have unresolved concerns, you have the right to complain to a data protection authority.