AwardCat Privacy Policy

Introduction

We have a strong business interest in protecting your personal information. However, taking a flight is a highly public activity and you should assume this information is not (and will not be) private. We must share your information extensively to do the job you’re hiring us to do. Accordingly, it’s your responsibility to carefully review this privacy policy, and it’s your primary responsibility to avoid sharing information you don’t want shared with service providers (such as airlines) and government agencies (such as the US Transportation Security Administration).

In short: If you don’t want a lot of people to know that you’re taking a flight, charter a private jet. That won’t be completely private either, but it’s less public than a commercial flight.

Who we are?

AwardCat does business as 2621 Holdings, LLC, who acts as a data controller and data processor in varying capacities. You can contact the data controller via postal mail at the following address:

412 N Main Street, Suite 100
Buffalo, Wyoming 82834
USA

What information do we collect?

We collect the following information:

• Your contact information
• Names, identification numbers, and dates of birth of all people traveling (as required by both airlines and government authorities).
• Dates and places related to your travel plans.
• Tickets and confirmation numbers from the airlines related to your trip.
• Billing information that you give us in order to process credit payments to our company.
• Information that you give us about your loyalty accounts and points balances.
• Information that you give us about the people who are traveling.
• Information that you give us about your travel preferences.
• Information that you give us about additional services you would like our company to help arrange.
• Any other information that you share with us in order to fulfil your requirements.

How do we use personal information?

You should view travel (particularly international travel) as a highly public activity and be aware that your personal information will be extensively shared with airlines, government agencies, and other parties as needed. If you do not want your information to be shared, we recommend that you choose not to travel.

We primarily use the information you give us to find award flight availability, contact you to review your flight options, and help you book your trip. We also set up an account for you so that you can conveniently access your tickets after we book them. Finally, we use your information to bill you for your trip.

In addition to the above, we may use your data for the following purposes:

• personalisation of content, business information or user experience
• account set up and administration
• delivering marketing and events communication
• carrying out polls and surveys
• internal research and development purposes
• to cancel your tickets if you fail to pay our fees
• providing goods and services
• legal obligations (such as prevention of fraud)
• meeting internal audit requirements
• As you otherwise authorize us to assist with your travel requirements

What legal basis do we have for processing your personal data?

All of the following legal bases apply:

• Consent: You consent to us using your personal information to help you research and arrange travel and related services.
• Contract: You enter a contract with us when you agree to pay for booking services.
• Legitimate interests: We have a legitimate interest in processing your personal data in order to meet our contractual obligations and your requests.
• Vital interests: We will process your personal information on your behalf either in order to meet our vital fiduciary interests or in good faith to protect your vital interests.
• Public tasks: As a general policy, we grant requests from government authorities that we deem to be legitimate.
• Legal obligation: We comply with all legal requirements involving your personal information.

When do we share personal data?

We will share your personal information with every party that needs it in order to fulfill your requirements.

Where do we store and process personal data?

We store and process your personal information in the United States. We claim safe harbour under all applicable EU-US data protection treaties.

How do we secure personal data?

Your information is stored on a server in a physically secure data center owned by our Internet service provider. We additionally have a security policy in place:

• to protect data against accidental loss
• to prevent unauthorised access, use, destruction or disclosure
• to ensure business continuity and disaster recovery
• to restrict access to personal information
• to conduct privacy impact assessments in accordance with the law and your business policies
• to train staff and contractors on data security
• to manage third party risks, through use of contracts and security reviews

How long do we keep your personal data for?

We maintain your personal data in your account indefinitely. The reason for this is because if we periodically deleted it, we’d also delete all of your travel history and tickets. You’d also have to update all of your travel information again. Most people don’t want us to do that, because it would be stupid and pointless (and we try not to do stupid and pointless things).

If at some point our company is going out of business or we somehow run out of space to store your data, we’ll notify you at least 30 days in advance and give you the opportunity to update your travel history.

We also allow you to delete your account. If you delete your account, neither you nor we will have access to your information anymore. Note that this can limit our ability to assist you with your itineraries.

Your rights in relation to personal data

You have the following rights:

• Access to personal information: Log into your account, and you can see all of it.
• Correction and deletion: You can delete your account and all of the information in your account. If you want information corrected, you can delete your account and create a new account with the correct information. Note that if we have been requested by governmental authorities and/or are legally required to preserve your information, we will maintain it even if you delete your account.
• Withdrawal of consent: If you don’t want us to assist with your trip any longer, just notify us and we’ll be happy to stop working on it. However, if we have already shared information related to your trip with airlines or other third parties, you’ll also need to contact them in order to withdraw consent.
• Data portability: We offer you the ability to download the tickets you have purchased at any time and store them on your own computer or any other storage service you choose.
• Restriction of processing and objection: Data processing is an essential function of the services we provide and we cannot provide the services without processing your data. To restrict processing, do not order our services or any related services, which are not and cannot legally be provided anonymously.
• You can review your rights under the EU GDPR and obtain contact information for the Privacy Commissioner at https://ec.europa.eu/info/law/law-topic/data-protection_en. They will happily accept your complaint in any European language (including German).

Use of automated decision-making and profiling

To improve your experience on our Web site, we may make automated decisions about the content you see. Here are some examples of the automated decision-making and profiling that we may choose to do:

• Only displaying award tickets you have enough points to purchase, even if airlines sell other tickets.
• Only displaying tickets to and from the cities you want to travel, even though airlines offer hundreds of thousands of flights to thousands of destinations daily.
• Only displaying fares for flights we describe as “good flights,” so you don’t have to sort through 37 hour long itineraries with 18 hour stopovers in Moldova even if they’re $3 cheaper. Unless, of course, you’re into that sort of thing.
• Showing you prices in your local currency instead of rubles. Unless we show you the price in rubles by accident, or you’re actually located in Russia (incidentally, this has been a persistent recurring bug during site development).
• Showing you content in your local language instead of Russian. Unless we show you content in Russian by accident, or you’re actually located in Russia (incidentally, this has been a persistent recurring bug during site development).
• Offering you products that could be useful in helping you achieve your travel goals.
• Offering you services that could be useful in helping you achieve your travel goals.

How to contact us?

If you want our help with a trip, you can call us. Our phone number is on our Web site.

If you want to write us about our privacy policy, you can send us a letter via US Mail:

412 N Main Street, Suite 100
Buffalo, Wyoming 82834
USA

Use of cookies and other technologies

Just think of us as Cookie Monster. We use cookies on our Web site. Our partners use cookies. Everyone in the travel industry makes extensive use of cookies.

If you don’t want to accept our cookies, you can use Incognito Mode or Private Browsing mode as supported on all modern Web browsers. We do not support old Web browsers without this feature. We don’t display annoying cookie warnings (even if you’re in Europe) because this practice is outdated and irrelevant now that modern browsers can browse without accepting cookies.

Linking to other websites / third party content

We link to other Web sites to display their information:

• Travel service providers to sell air tickets, hotels, and other travel related services.
• Points wallet and password management services to automatically obtain your account balance (with your explicit consent).
• Other sites we think provide useful travel content, such as airline Web sites and travel blogs.
• Other travel, financial, and online service providers.

Where we link to third party sites, the pages are clearly branded with the third party’s logo and information so you know you’re working with them, not us. Naturally, third party sites have their own privacy policies and they differ from ours.