Seatfrog Privacy Policy

Last update: 24 May 2018

Seatfrog Ops Ltd (10784220) of 11 Staple Inn, London WC1V 7QH (Seatfrog, We or us) are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy (together with our Terms and Conditions as set out at http://www.seatfrog.com/terms.html and any additional terms of use incorporated by reference into the Terms and Conditions, together our Terms of Use) applies to your use of:

• The Seatfrog mobile application software (App), whether available on our site or hosted on third party sites (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Seatfrog Services) that are available on the App Site or other sites of ours (Services Sites).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

Seatfrog’s Services are not intended for minors under 18 years of age. No one under the age of 18 may provide personal data to or through the Seatfrog App or the Website. We do not knowingly collect personal data from minors under 18. If you are under 18, please do not create a Seatfrog account or send us any information about you.

For the purpose of the General Data Protection Regulation (GDPR), the data controller is Seatfrog Ops Ltd of 11 Staple Inn, London, United Kingdom, WC1V 7QH.

1. DATA WE COLLECT FROM YOU

The type of information we collect from you will depend upon the type of interaction you have with us. Broadly speaking, the types of personal data that we collect may include:

• if you are a customer of Seatfrog (or one of our partners whose app incorporates aspects of the Seatfrog Services): your first and last name, email address, phone number, details of your itinerary and transactions which you conduct using the Seatfrog Services;
• if you are a partner, supplier or service provider: your full name, employer name, work contact details (including address, phone number, fax number and email address); and
• if you are a job applicant, employee or contractor: your full name, contact details (including address, phone number and email address), driver’s licence details, job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency), national insurance number or similar tax information if required by law.

We may collect personal data from you in a variety of ways, including the following:

• when you create a Seatfrog customer account;
• when you participate in an auction using the Seatfrog App (or a Seatfrog partner’s app, where the auction is facilitated by Seatfrog), for example, when you enter your booking reference details;
• automatically when you navigate through the Seatfrog Services. Information collected automatically may include usage details, geo-location data, IP addresses and information collected through cookies, and other tracking technologies (which may not be information which identifies you);
• when you provide content and other information when you use the Seatfrog Services or post on our social media accounts;
• when you:
  • arrange payment for use of Seatfrog’s Services. For example, we may collect details of the type of credit card you are using, the credit card’s last four digits and its expiry date (but not any other details of your credit card);
  • visit our Website and any other webpage that we own and manage;
  • manage/change your customer, partner or supplier account information;
  • contact us by phone, email, post or via the Website;
  • attend onsite pilot programmes;
  • subscribe to receive our newsletter or promotional materials or sign up to a mailing list; and/or
  • participate in surveys, or competitions or other promotional activities.

Seatfrog may also collect your personal data from third parties. This may include (but is not limited to) the collection of your personal data from:

• other users of the Seatfrog Services;
• our partners, for example, travel service providers (such as airlines and rail operators);
• other partners, such as car rental operators and accommodation service providers where aspects of the Seatfrog Services have been incorporated into their own apps enabling them to offer auctions, which are facilitated by Seatfrog;
• Global Distribution Systems (GDS), such as Amadeus, Sabre and Navitaire, or ticketing agencies, which are used by our partners;
• our customer support service provider, when you make a customer service inquiry;
• someone duly authorised to act on your behalf (such as your next of kin);
• recruiters we have retained and from referees you have provided in support of a job application.

From time to time, you may be able to visit our Website and deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we require, we may not be able to provide you with the particular Seatfrog Services that you seek. For example, if we do not have your first and last names and reservation number, you will not be able to participate in an auction using the App.

2. COOKIES

We use cookies and other similar technologies such as pixel tags, embeddable scripts and local storage.

Cookies are small text files that may be placed on your computer or other device by websites when you visit them.  Cookies enable Seatfrog to recognise your device on a subsequent visit by that device to our Website and allow us to deliver a more personalised experience by providing information to us. Cookies are essential for some website functions and these functions will not work in the absence of those cookies.

You can use the browser privacy functions to clear the cookies already on your computer or to block cookies in the future by altering the browser privacy settings. However, please note this may cause some of the functionality of the Website not to work correctly.

If you continue to use our Website, you are agreeing to the use of cookies.

Please note that our partners may also use cookies and other tracking technologies on their own apps, which may incorporate aspects of the Seatfrog Services.

3. USE MADE OF PERSONAL DATA

Our use of your personal data will always have a lawful basis, either because it is necessary to fulfil our contractual obligations in providing the Seatfrog Services, because you have consented to our use of your personal data (e.g. by subscribing our newsletter), or because it is in our legitimate interests.

The personal data we collect may be used in a number of ways as outlined below.

To fulfil our contractual obligations:

• to provide the Seatfrog Services, for example, enabling you to participate in auctions, including sending you notifications when bidding has opened/closed in an auction, re-issuing your boarding pass and allowing you to participate in interactive features of the Seatfrog Services, when you choose to do so;
• liaising with airlines, rail operators, travel agents, ticketing agencies and our other partners in connection with your use of the Seatfrog Services;
• exchanging information with one or more Global Distribution Systems (GDS) (such as Amadeus, Sabre and Navitaire, or ticketing agencies) in connection with your use of the Seatfrog Services;
• to provide you with information or services that you request from us;
• generating bills, managing accounts and carrying out debt-recovery functions;
• providing customer, partner and supplier technical support and other customer/partner/supplier relationship management functions;
• dealing with enquiries or complaints;
• to notify you of changes to the Seatfrog Services;

Upon your consent:

• for various communications and marketing purposes;

In our legitimate interests:

• collecting and analysing product performance, service and reliability data in connection with the Seatfrog Services;
• carrying out market research and product analysis and development;
• complying with our obligations under the law;
• training our staff;
• in any other way we may describe when you provide the information;
• in the event of a change of business ownership, merger, sale or other business transaction, transferring your information to a successor entity;
• conducting our internal business and management processes, for example accounting or auditing purposes; and
• for any other purposes that would be reasonably expected.

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

We will also anonymise personal data regarding you and consolidate such data. We may provide our partners, such as travel service providers (including airlines and rail operators) with aggregated anonymised data about the users of Seatfrog Services, for example auction performance parameters, bidding characteristics and behavioural data.

4. DISCLOSURE OF PERSONAL DATA REGARDING YOU

Seatfrog may disclose personal data to third parties in certain circumstances including (but not limited to) the following:

• to fulfil the purposes for which you provided your information, for example:
  • if you are a job applicant, to obtain a reference from your referees; or
  • if you are a successful bidder in an auction, your personal information may be disclosed to your travel service provider, their ticketing agency and/or a GDS;
• other third parties We engage to help us run Seatfrog’s business - such as our customer support service provider; payment processors; contractors; couriers; pay roll service providers; debt collection agencies and other parties that assist with debt-recovery functions;
• our professional advisors, including lawyers, accountants, tax advisors and auditors;
• law enforcement bodies, Courts of law or as otherwise required or authorised by law;
• regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies;
• if Seatfrog or substantially all of its assets are acquired by a third party, in which case personal data held by Seatfrog about its customers will be one of the transferred assets, to be used in the same ways set out in this Privacy Policy;
• if Seatfrog restructures, or integrate our business with another group of companies, to the new owner, to be used in the same ways set out in this Privacy Policy;
• for any other purposes that you would reasonably expect; and
• to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

Before Seatfrog discloses any personal data to a third party, we take steps to ensure that the third party will protect your personal data in accordance with applicable privacy laws and in a manner consistent with this Privacy Policy. Third parties are required to restrict their use of this information to the purpose for which the information was provided.

We may transfer your personal data to overseas recipients for business purposes and operational, support and continuity purposes, for example, when we use IT service providers or data storage services which are located overseas. Countries where these recipients are located may have data protection laws which differ to the data protection laws in your country of residence.

Seatfrog also engages third party software service providers who, for example, provide data analysis services (but do not access personal data regarding you in providing these services). These software service providers may be located anywhere in the world.

Please note that third parties we engage with, such as travel service providers (including airlines and rail operators); online travel, car hire and accommodation reservation systems and ticketing agencies, may be located anywhere in the world.

Where this is the case, we will take appropriate measures to protect personal data regarding you in accordance with this Privacy Policy.

We may distribute aspects of the Seatfrog Services (such as our auction engine) for display and/or use on Seatfrog’s partners’ and affiliates’ websites or apps using API-based technology.

We may also provide our partners, such as travel service providers (including airlines and rail operators) with aggregated data about the users of the Seatfrog Services via an online platform which Seatfrog operates, for example, auction performance metrics, bidding characteristics and behavioural data.

We will disclose personal data regarding you to third parties in order to:

• enforce or the Terms and Conditions (http://www.seatfrog.com/terms.html), and other agreements or to investigate potential breaches; or
• protect the rights, property or safety of Seatfrog our customers, or others. This includes exchanging data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5. WHERE WE STORE YOUR PERSONAL DATA

Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received personal data regarding you, We use strict procedures and security features to try to prevent unauthorised access.

All information you provide to Seatfrog is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology. The safety and security of your information also depends on you. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the Seatfrog Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:

• storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
• using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology;
• restrictions are placed on the electronic transfer of files; and
• our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Seatfrog Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Seatfrog takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by Seatfrog and Seatfrog is no longer required by law to retain the information.

The data that We collect from you will be transferred to, and stored at, a destination outside the European Economic Area (EEA). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Seatfrog will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

6. DISCLOSURE OF PERSONAL DATA REGARDING YOU

You have the right to ask us not to process your personal data for email, sms or text marketing purposes. We inform you (before collecting your data) if We intend to use your data for or if We intend to disclose personal data regarding you to any third party for such purposes. You can exercise your right to prevent such processing by choosing not to check certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at to privacy@seatfrog.com or Seatfrog Ops Ltd at 11 Staple Inn, London, United Kingdom, WC1V 7QH.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Seatfrog Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

7. ACCESS TO INFORMATION

The General Data Protection Regulation (GDPR) gives you the right to access personal data held about you. Your right of access can be exercised in accordance with that Regulation. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request.

Where a request is manifestly unfounded or excessive we may charge a reasonable fee for the administrative costs of complying with the request. We may also charge a reasonable fee if an individual requests further copies of their data following a request, based on the administrative costs of providing further copies.

To request access personal data that We hold regarding you, please send an email to privacy@seatfrog.com or send a letter to Seatfrog Ops Ltd at 11 Staple Inn, London, United Kingdom, WC1V 7QH.

8. CHANGES TO PRIVACY POLICY

Seatfrog reviews and amends its privacy policy from time to time. Any changes We may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Seatfrog Services.

9. CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@seatfrog.com or Seatfrog Ops Ltd at 11 Staple Inn, London, United Kingdom, WC1V 7QH.