Data Protection and Privacy Statement of compare-flight.com
 

Data protection and privacy is very important to us, VIP Response (hereinafter "Compare Flight" or "we"), Parijsboulevard 143C, 3541 CS, Utrecht, The Netherlands. In our position as data controller we would like to inform you of the nature, scope, and purposes of any collection, storage, transfer, and/or use of personal data. Please read this privacy policy carefully. 

Be aware that this privacy policy only applies to this domain: https://compare-flight.com (henceforth “Site” or “Domain”) and its sub-domains. Through interaction with our site, from the moment of access, you agree with the terms stated in this policy. 

You may contact us at any time, either via our postal address (above) or via email: info@vipresponse.nl. For in-depth questions concerning data protection, please reach our Data Protection Officer at dpo@vipresponse.nl. 

Contents

This statement provides you with information on all aspects of our offering that are relevant in terms of data protection and privacy, particularly:

• the collection and storage of your personal data,
• the transfer and use of your personal data, 
• your rights, and
• the California Consumer Privacy Act (CCPA)

We collect your personal data and will share it, under our legitimate interest, with independent third-party data controllers, including resellers and distributors, to help them provide the marketed services. 

1. Which personal data we collect and store
 

When you visit and use our site, or submit any of our contact or request forms, you authorize the collection of your personally-identifiable personal data (PII), including, 

• Personal data that you provide us by utilising our offering and/or using our website may be collected. If one or several provisions of this Agreement should be or become lawfully ineffective, this shall not impair the validity of the other provisions. The invalid provision will be replaced as quickly as possible with another provision most closely approximating the economic intent and content of the invalid provision. “Personal data” include, in particular, your name, address, e-mail address, phone number, and any interests, etc., that may be identified in surveys.
• To the extent that you answer any questions regarding your preferences, interests, user behavior, and/or your interests become apparent because you sign up for a quote or consultation or similar items, we will also store this information in order to establish a personal user profile. This user profile enables interest-driven, optimised direct marketing which seems reasonable for both sides to ensure that you will only receive offers that are relevant to you and fit within the context of your lifestyle and available purchasing power. For example, if you have provided your gas provider and have consented for third parties to contact you, we will work with third party brand partners to send you a utility quote tailored to your needs – thus saving you time researching the entire market.
• We also collect and process personal data that you provide to us by contacting us.

During your visit to our site, you may answer prompts to enter personal information and/or initiate a phone call to one of our partners. By doing so, you expressly consent to share your PII with Compare Flight and our marketing partners, who are hereby permitted to contact you. Contact may be sought via phone calls, text messages, and emails, regardless of whether you are on any federal or state “Do Not Call” or “Do Not Email” list or registry. Compare Flight does not charge you for the use of any of our services; however, phone carrier fees may apply depending on your telecommunications provider.

Additionally, our hosting service tracks your general interaction with our page. Through this tracking, we collect non-personally-identifiable information (NPII), including, but not limited to:  

• Personal data that may be collected through your visit to our page, particularly data traffic, location and time information, IP addresses, browser and device ID and other communication information provided through the use of your computer.
   

Further data – such as, in particular, local times, time zones, and usage data – may also be stored in addition to the data specified above.

2. Personal Data Processing and Purposes

Based on the participation agreement that is entered into and in the event of an online quote request, Compare Flight will collect and process your personal data. This agreement requires that you provide your personal data if, and insofar as, you wish to receive a quote or financial consultation. The data processing takes place for both our own direct marketing as well as for our third-party marketing partners to also enable them to engage in individual, demand-driven direct marketing that is tailored to you via the channels of e-mail, phone, and SMS.

Processing your personal data would be in accordance with declaration of consent for advertising and marketing purposes, via phone, text messages, email, push notifications, mail and/or the disclosure of data for direct marketing purposes for the mentioned third-party sponsors that may have been issued separately; this also takes place within the scope of our legitimate interests as established by your relevant consent.

Compare Flight assumes that the consent to receive advertising by phone, text message, and e-mail from us and our third-party marketing partners also constitutes consent for purposes of data protection and privacy law to the processing of your personal data with the result that – in addition – the relevant, aforementioned data processing is also permitted.

Using the data obtained, particularly those from our surveys preceding the quote registration page, we will create a “user profile” of you in order to be able to offer you an interest-driven service that is geared towards your individual needs and requirements. By creating this profile, we may categorise personal aspects, such as your interests and preferences, through automated processing of your data in order to make it possible for both us and our sponsors to send you exclusive advertising and offers that match you profile.

Assertion, if any, of your rights as provided in Sec. 4 of this data protection and privacy statement also leads to collection and processing of your personal data.

Disclosure of your personal data may take place in cases in which we are under a legal obligation of disclosure or to the extent that disclosure should be necessary to enforce other rights/demands or for purposes of legal defense, if and insofar as these are based on the legitimate interests of the organiser or other third parties. The same applies in the event of (also partially) purchase or sale of business assets and/or other assets, in the event that our business is otherwise acquired by a third party, in the event of initiation of insolvency proceedings, or if a request for initiation of insolvency proceedings is denied for lack of sufficient assets.

3. Personal Data Storage and Transfers

 a) As a Netherlands-registered company, Compare Flight/VIP Response store your personal data within the European Economic Area (EEA), where the General Data Protection Regulation (GDPR) is observed.
 
 However, depending on the location and registration of our third-party marketing partners, we may transfer that data to “third countries.” Third countries constitutes nations and regions located outside the European Union (EU), including the United States of America. With regard to such data transfers, we ensure a secure transfer within the scope of the EU specifications on data protection and privacy to all third countries.  

b) We store your data permanently, for the purposes mentioned above, unless you expressly exercise your rights of withdrawal and erasure as explained in Sec. 4: “Your Rights.”

When you revoke your consent to process or use your personal information, we will add you to our “Do Not Contact” directory, which will be shared with our third-party marketing partners. This means that we will no longer use your personal data for marketing purposes, nor will we disclose them to new third-party marketing partners. Your data will be stored for legal purposes only (e.g. documentation obligations, defending against and asserting claims, etc.), and it will be erased after four years unless compelling reasons argue against our doing so or you provide new consent. 

If your personal data has not been in use by us for 24 months, we will likewise store it purely for legal purposes and erase it after four years unless compelling reasons argue against our doing so. 

4. Your Rights

 At any time, you have a right to obtain information regarding your collected and stored personal information, including the origin of consent, third-party recipients, and the purpose of our data processing. 

At any time, you have a right to demand that we correct inaccurate personal information concerning you. You may restrict the processing of data in the event of a dispute concerning the accuracy of your personal data. 

Moreover, at any time, you have a right to revoke any declaration(s) of consent to the processing and transfer of your personal data that may have been issued. Compliance with your demand will enter into effect at the moment of revocation of consent. However, revocation of consent does not affect the legality of the processing that has already taken place until that moment. 

In addition, at any time, you are entitled to demand that we provide you with the personal data transferred to us in a format that permits the transfer thereof to another body.

You can object to the processing of data for reasons that arise from your particular personal situation.

Furthermore, you have the right to demand the erasure of your data and assert your right to be forgotten. If the statutory prerequisites are met, we will proceed in this regard even without such a request having been issued on your part and will erase your personal data.

To opt-out of communication, please contact  info@vipresponse.nl or join our “Do Not Contact” registry at https://unsuball.vip/unsubscribe/1 

If you have a complaint, you can contact the supervisory authority with jurisdiction over Compare Flight/VIP Response B.V., the Data Protection Official for Utrecht (Chamber of Commerce) (St Jacobsstraat 300, 3511 BT Utrecht, The Netherlands). You may also file a complaint with the Office for Civil Rights of the U.S. Department of Health and Human Services Rights by sending a letter to Centralized Case Management Operations, U.S. Department of Health and Human Services, 200 Independence Avenue, S.W., Room 509F HHH Bldg., Washington, D.C. 20201, or via fax, email or the OCR Complaint Portal, available at https://www.hhs.gov/hipaa/filing-a-complaint/complaint-process/index.html. Filing a complaint will not result in any negative repercussions for you. 

5. The California Consumer Privacy Act (CCPA)

 The privacy policy explained above complies with the California Consumer Privacy Act, according to which residents of California have the right to request: 

• A full report of the data we have collected from you, to be provided via email within 45 days after the submitted request. If this process requires more than 45 days, we will notify you. 
• A complete deletion of your personal data and information from our databases unless that data falls outside the control areas covered by the CCPA. Deletion will take place within 45 days. You will not be notified unless an extension is required. 
• Do Not Sell My Personal Information. We will add you to our Do Not Sell list, which will be available to our third-party marketing partners for the purpose of protecting your rights. 

Furthermore, we extend these rights to residents of the United States, not just California.  

These rights can be exercised via email: info@vipresponse.nl or through our opt-out list.  

By opting out of data sales, you permit Compare Flight to share this list with third parties, for the sole purpose of avoiding a breach of your rights.

In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov.

6. Usage data and cookies

 You can view our Internet pages without providing personal information. However, certain technical data, known as "usage data", are generated whenever our pages are visited. In addition, we may use one or more cookies and integrate social media plugins in some cases. The text below is intended to provide you with information regarding this as well.

Usage data
 
 When you visit our Web pages, the only items of information we store by default are the website from which you reached our page, the name of your Internet service provider, which Web pages you visited within our Internet presence, and the date and duration of your visit. The data obtained is fully anonymous.

Your IP address and a time stamp are also stored for security reasons and used for internal purposes. The IP address is a machine-related code that provides information of the computer or Internet gateway used to access the Internet at the time of online retrieval. A time stamp is a value in a defined format that assigns a certain point in time to an event (for example, sending or receiving a message, modification of data, etc.). The purpose of a time stamp is to make it clear to people or computers when events occurred.

Social media plugins

 We integrate "social media plugins" (often also known as "social media buttons") into some areas of our Web pages. These kinds of plugins are marked on our pages by buttons (hence the term "buttons"), each of which shows the provider of the plugin through corresponding colours and symbols. Clicking these buttons allows you to do things like notify your friends in the social networks you use that you like one of our pages or share a link to a website with other Internet users, depending on the button.

If you are surfing on our website and access one of our Web pages that contains a social media plugin, your browser makes a direct connection with the servers of the provider of the plugin, and the plugin is loaded from there. In the process, the provider of the plugin may be notified that the relevant Web page has been accessed from our website.

If you have a user account with one or more of the social networks operated by the providers of the plugins and are logged into the network(s) in question while you are on one of our Web pages that contains one or more social media plugins of the provider(s) in question, it may also be possible to associate the access to that page with your existing user profile(s) with the provider(s) in question. If you click on integrated plugins and log into one or more of the networks afterward (or are already logged in), the shared or "recommended" information is generally posted in short form in your profile. This may allow the provider of the network to collect and store further usage data. In this way, the providers of the networks can create user profiles that go beyond what you yourself directly and actively disclose in the network. For further information on the collection and processing of data, please see the privacy policies of the providers of the plugins.

Cookies

 We use so-called cookies on our Internet pages. These are small files that are stored on your hard drive and in which certain information is stored that a server can read out again. These cookies can be so-called session cookies, which are automatically deleted as soon as you close your browser, on the one hand, and cookies with a longer, predefined runtime, on the other. 

The information stored in cookies may include the date and time of your visit, your other behaviour on our pages, the cookie number and the URL of the website from which you accessed our offer pages.

The use of certain cookies enables us, on the one hand, to guarantee the functionality of our websites and to continuously improve their performance. In addition, cookies help us and our partner to recognise you and in this way to adapt our offers – also on the other pages on which our partner is active – optimally to your individual needs and thus to display the most relevant information for you. This technology enables us to pass on the personal data you have previously entered in one of our competitions and which you have released for commercial use directly and conveniently to those of our sponsors whose services you are interested in. Finally, cookies make it possible to record the statistical frequency of visits to the various pages of our website and the general navigation.

If, however, you wish to prevent the use of cookies, which has no influence on the perception of our competition or other related offers on our part, we ask you to make the appropriate setting in your browser before using our pages. There you can prevent the acceptance and storage of new cookies. You can find out more about this on the help pages of your browser or by contacting its service provider.

7. Deletion of cookies

 As a user, you have the right at any time to decide which cookies – including those for push notifications – you wish to accept or delete. You can adjust the individual settings thereto in the settings menu of your Internet browser. For further information, please contact the provider of your Internet browser.

8. Minors

 We do not knowingly solicit or collect information from anyone under the age of 18. Insofar as a minor submits their personal information, and their age is unquestionably identifiable, we will withhold this data from our third-party marketing partners, and we will not issue advertising material to identified minors. 

9. External Links

 This website may feature external links that direct you off compare-flight.com and/or other VIP Response-owned domains. Please be advised that we are not responsible for the content or services offered by third parties, nor are we responsible for any contracts you make with our third-party marketing partners. 

If a privacy policy is not readily disclosed by a third-party marketing partner, we recommend that you contact the responsible party (domain owner) for clarification about their personal data processing before further engagement. 

Additionally, you may find telephone buttons on our websites that will connect you to third-party call centers. On connecting with these call centers by phone, you may, at any time, demand a specification of how they use your personal information and request erasure. 

10. Changes to this Policy

 We reserve the right to modify this privacy policy at any time, without explicit written notice to our users, so please review it frequently to remain up to date on your rights. An updated privacy policy will be linked at the bottom of our website(s) at all times.  
 
 Current as of: January 2023