Contents

1. Information Protection
2. Personal Information
3. Automatic Information Storage
4. Cookie Files
5. Information Updates and Settings
6. Use of Information
7. Person Responsible for Personal Data Protection
8. Data Transfer to Carrier/Supplier
9. Other Cases of Information Disclosure
10. Data Storage Period
11. Privacy Policy Updates

1. Information Protection

Compass Group is responsible for processing received personal data in accordance with the requirements of regulatory documents and imposes corresponding similar obligations on any counterparties with whom it interacts in the process of providing services or processing received information.

Compass Group adheres to the basic principles of protecting confidential information regarding any further data transfer, both internal and cross-border, including with respect to further transfer of obligations.

To ensure secure transmission of personal data, Compass Group uses SSL 3.0 encryption protocol. All personal data is encrypted and securely transmitted over the Internet.

2. Personal Information

You can perform most operations on the Compass Group website without providing personal information.

However, if you purchase/book a ticket on the Compass Group website and/or purchase other products or services including when you subscribe to Compass Group to receive services, Compass Group receives the following information from you:

• contact information (your name, surname and/or passenger name, surname, contact phone number and email address);
• profile data, your username and password;
• information about purchased services.

If necessary, Compass Group may verify certain information by asking you to either (a) upload a scanned copy of your ID (which will be securely stored on our servers), or (b) ask you to identify yourself in another acceptable manner.

To reduce the number of errors in our database, Compass Group may verify user authenticity and prevent misuse of the system.

At your request, Compass Group may supplement the personal information you provided with information from third-party sources.

Compass Group also collects aggregated information about your activities on our website (for example, the number/direction of trips, the response time of the Website to your request, and the like). Such information may be published in a publicly available profile on our website without personal identification.

Depending on your purposes for using the Compass Group service, some of the requested information is mandatory to provide, and some is provided at your discretion. If you refuse to provide mandatory information, you will not be able to perform operations to purchase certain services. All other Compass Group services will be at your disposal.

Your credit card number is used exclusively by services that provide payment services. Compass Group does not store credit card data.

3. Automatic Information Storage

During your use of the website, Compass Group may collect personal information about the devices you use and the networks to which they are connected. Such collection includes the following information: your IP address; login information for accessing your personal account; browser type and version; browser plugin types and versions; operating system and platform; advertising identifier; information about your visits to the website, including URL clickstream of pages you viewed or information you searched for; errors that occurred during web page loading; duration of loading certain pages; interaction with pages or phone numbers used to contact our customer service center.

Like most websites, Compass Group and independent auxiliary operators involved by it may receive certain technical and routing information about your computer during your use of the website to facilitate your use of the site and its services. For example, Compass Group may receive information about environment variables, such as browser type, operating system, processor speed. Compass Group also uses environment variable data to track site traffic. Compass Group occasionally compares this data anonymously to better understand the needs of website users. We do not sell your personal data or transfer it for the purpose of sale.

4. Cookie Files

The Compass Group website uses cookie files. Cookie files are an industry standard and are used by many websites to facilitate current user access to certain websites, provide information used to understand the content of what interests the user, and for other purposes, such as security purposes and to perform other administrative account functions, as well as functions that may help track information that may identify the user. Cookie files cannot damage the system or computer files and only the website that sent certain cookie files can read, modify and delete such files.

If you do not wish to receive information collected through cookie files, most browsers have options for deleting existing cookie files, automatically rejecting them, or offering the option to choose between rejecting or accepting individual cookie files by the computer. To learn more about such features, see your browser's user guide or help window.

Some use of cookie files on the Website may be controlled by uncontrolled organizations with which Compass Group cooperates to manage certain programs and process individual visitor/client/user requests. Compass Group requires such enterprises to use cookie files in compliance with these Rules, but Compass Group is not responsible for the use of cookie files by third parties.

5. Information Updates and Settings

Upon your request, Compass Group has the ability to provide you with information about whether Compass Group stores or processes your personal information. If you need to request this information, contact us at [email protected].

You have the right to access your personal information and settings at any time to change or delete them. This can be done through the Personal Account, where you will be able to view and make changes to your personal data. For your security, some elements of personal information can only be changed by contacting support services. Compass Group will promptly respond to your request within a reasonable timeframe.

6. Use of Information

Compass Group collects and uses your personal information to provide you with services, fulfill legal obligations (including the carriage contract), and to improve services and offerings.

Compass Group uses personal information for the purposes of: processing your financial transactions (in terms of confirmation from the payment system of the fact of payment); sending you purchased/reserved tickets and other services; servicing you as a user or passenger in the process of processing your requests and claims by the support service; managing your account data; sending you requested information about the conditions for purchasing a ticket or carriage service, etc.; informing you about special offers from Compass Group; managing promotions in which you participate and notifying you of their results; notifying you of the results of consideration of claims and/or taking measures regarding actions that violate the terms of service provision; conducting analysis of additional services and/or services to improve the operation of the Website; processing your individual requests.

7. Person Responsible for Personal Data Protection

If you have any questions or concerns related to the Privacy Policy or how Compass Group manages your personal information, or if you have any other problems regarding personal information, please contact us at [email protected].

8. Data Transfer to Carrier/Supplier

The Compass Group service in the course of its activities cooperates directly with carriers or ticket suppliers.

To provide quality carriage services, your personal data is mandatory transferred directly to the Carrier/Supplier for the flight on which you purchased a particular ticket.

The main purpose of transferring personal data to the Carrier/Supplier is to conclude a carriage contract.

9. Other Cases of Information Disclosure

Personalized user information may be provided to other organizations:

• within the scope of applicable law
• in case of alienation of the enterprise, property or bankruptcy of the company
• if Compass Group is forced to disclose certain information to comply with requirements of law enforcement or regulatory authorities, or as a result of another legal process,
• or in exceptional cases to protect the security interests of Compass Group or other website visitors.

10. Data Storage Period

Compass Group stores data as long as it is needed to accomplish the relevant data processing purposes (for example, operations to perform a carriage contract, provide service, advertising and marketing services), as well as to comply with the requirements of civil, commercial and tax law.

Personal data is subject to removal from the Compass Group personal data databases in case of:

• expiration of the data storage period determined by agreement by the personal data subject who provided it for processing or by law;
• termination of legal relations between the personal data subject and the database owner or manager, if not otherwise provided by law;
• entry into force of a court decision on the removal of personal data of an individual from the personal data database;
• receipt of a substantiated request from the personal data subject for termination of processing/destruction of his data in the cases and manner established by law.

Compass Group is obliged to make changes to the data at the request of the personal data subject if this data is unreliable or inaccurate, or perform other manipulations including transfer to a third party.

11. Privacy Policy Updates

Compass Group reserves the right to make changes to the Privacy Policy. If Compass Group makes material changes to the Privacy Policy, this will be indicated here.

Compass Group recommends regularly reviewing the Privacy Policy, as your use of the Website after changes means that you, as a User, have agreed to such changes to the privacy policy.