Privacy Policy

1.Welcome to our privacy policy

We create unforgettable moments for our customers across the world. Looking after the personal data you share with us is also an important part of this. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better experience.

We respect your privacy and we are committed to protect your personal data. This privacy policy will inform you:

  • about how we use your personal data through your use of this website, including any data you may provide us when you purchase a product or service from us, sign up to our communications or take part in our competitions;
  • about your privacy rights; and
  • how the law protects you.

This privacy policy is provided in a layered format so you can choose the specific areas in which you are particularly interested.

Alternatively, you can find a summary here

2.About us

We are U Can Fly Ltd, operating under the trading name of "LycaFly". We primarily provide travel agency services, which includes the provision of booking services for flights, transportation, temporary accommodation as well as visa arrangement services.

We are a company incorporated under the laws of England and Wales with company registration number 6194960 and our office address is  Walbrook Building, 195 Marsh Wall, London, E14 9SG, United Kingdom We are regulated by the Civil Aviation Authority and our Air Travel Organiser's Licence (ATOL) number is 9624.

U Can Fly Ltd is a data controller and responsible for your personal data (collectively referred to as "LycaFly", "we", "us" or "our" in this privacy notice).

3.what data do we collect?

Personal Data is any information about you from which you can be identified. It does not include data where your identity has been removed (it's called anonymous data).

We may collect, use, store and transfer different kinds of personal data about you and other individuals on your booking. We have grouped the data sets together as follows:

  • Identity Data includes details such as passenger title, full name including any middle names and maiden names, gender and biometric data held on travel document(s).
  • Emergency Contact Data for Booking which can include passenger next of kin details such as, full names, address details and contact telephone numbers.
  • Contact Data includes passenger billing address, email address, contact number, full postal address.
  • Financial Data includes passenger bank account and payment card details.
  • Transaction Data includes details about payments made to passenger (refunds) and from passenger and other details of products and services that have been purchased from us.
  • Special Data which relates to passenger disability requests for wheelchair arrangements, meal preferences, dietary and religious requirements.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform you use to access our website.
  • Profile Data includes your username and password, purchases and orders made by you, your interests, preferences and loyalty memberships.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Customer Care Data includes your correspondences, feedback to us, survey responses for market research purposes and voice mail recordings when you contact us.

We also process your personal data to derive information so that we can make personalised offers that we feel are relevant to you. The derived information does not directly or indirectly reveal your identity. However, if we combine or connect the derived information with your personal data, it can directly or indirectly identify you. So, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we need to collect personal data by law and you fail to provide that data when requested, we may not be able to provide you with our travel agency services. We may also have to cancel the service you have with us but we will notify you if this is the case at the time.

4.how do we collect your personal data?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data and other individuals personal data on your booking, by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you do the following:

  • Purchase our travel agency services;
  • Create an account on our website;
  • Subscribe to our services or communications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our Cookie Policy for further details.

 

Other sources of personal data:

If you log-in using your social network credentials to connect to our platforms and online services e.g. Facebook, Twitter, and/or YouTube, your user details may be shared with us. For example, your name, email address, date of birth, location, and any other information you choose to share with us.

5.how do we use your personal data?

We will only use your personal data when the law allows us to, most commonly, in the following circumstances:

  • Where we need your personal data to provide the travel agency services in accordance with our terms and conditions.
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation. 

Below we have set out a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

 

Purpose

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

 

(a) Identity Data

(b) Contact Data

Performance of travel agency services in accordance with terms and conditions

 

To supply products and services you request

To charge for products and services requested

(a) Identity Data

(b) Passenger Data

(c) Emergency Contact Data for Booking

 (d) Contact Data

 (e) Special Data

(f) Financial Data

(g) Transaction Data

(a) Performance of travel agency services in accordance with terms and conditions and explicit consent for processing Special Data

(b) Necessary for our legitimate interests (to recover any sums owed to us)

 

To manage our relationship with you and administer your account which will include:

 

(a) Notifying you about changes to our terms and conditions or privacy policy

 

(b) Detecting and preventing crime and terrorism

(c) Asking you to leave a review or take a survey

(d) Manage any concerns that you raise to our customer care department

(e) Quality assurance and monitoring purposes

 

(a) Identity Data

(b) Passenger Data

(c) Contact Data

(d) Profile

(e) Marketing and Communications

(f) Customer Care

(g) Usage

 

(a) Performance of travel agency services in accordance with terms and conditions

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to participate in a competition or complete a survey for purely market research purposes (non-promotional)

 

(a) Identity Data

(b) Contact Data

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of travel agency services in accordance with terms and conditions

(b) Necessary for our legitimate interests (to study how customers use our products/services to serve better products to them)

 

To market products and services to you

To complete a survey (promotional)

 

(a) Identity Data

(b) Your Contact Data  

(c) Marketing and Communications

(d) Profile

(a) Legitimate interest to process marketing data (to serve our products to our customers) and consent for sending electronic marketing communications for new customers or an existing customer relationship to send electronic marketing communications

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant for clients, to inform our marketing strategy so that we serve our customers with better products and services)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity Data

(b) Contact Data

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to inform our marketing strategy so that we serve our customers with better products and services)

 

 

Marketing

You will receive marketing communications from us either if you have consented to receive them or you have purchased LycaFly products or services, and in each case, you have not opted out of receiving that marketing.

6.how can you manage your marketing preferences?

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us mydata@lycafly.com  

 You may also contact us let us know whether you're happy to hear from us by email, text, or telephone.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other purposes. 

7.to whom do we disclose your personal data?

We may have to share your personal data with the parties set out below for the purpose explained:

  • Other Lyca entities who provide sales, call centre support and administrative services for the fulfilment of your orders and resolving customer services issues.
  • External third parties who provide IT technical services, data centre services, call centre support, back office support and email marketing automation services.
  • Suppliers for travel arrangements, including flight booking, temporary accommodation, transport and visa arrangements.
  • So that you can travel, in certain circumstances, it may be mandatory (as required by government authorities at the point(s) of departure and/or destination) to disclose and process your personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate.

If a change happens to our business where we may choose to sell, transfer or merge parts of our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Where applicable, we require all external third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8.where is your data transferred to?

Some of our service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguard is implemented:

 

Category of Recipient

Location of Recipient

Safeguards in place or lawful ground for processing

Associated Lyca entity for Customer Support

 

Delhi, India

Customer's consent

Technical services provider

 

Chennai, India

Model Clauses

Associated Lyca entity for compliance services

 

Delhi & Chennai

Model Clauses

Suppliers for travel arrangements -Also known as Destination Management Companies

Sri Lanka

Malaysia

India

Thailand

Vietnam

Dubai & UAE

 

[Kindly note that this list may get updated depending on the destination that customers choose].

Transfer based on requirement to perform travel agency services requested by the customers in accordance with terms and conditions

 

 

 

For those countries where there no appropriate safeguards in place, the EU recognises that these countries do not provide the same level of data protection as provided in the EU. As such, we take steps to ensure your privacy rights are at least as compliant with the requirements of EU law, including by requiring appropriate security measures from such third parties, set out in a contract between us, to protect your personal data.

Please email us as mydata@lycafly.com  if you want further information.

9.how secure do we keep your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff members or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.

We also work with carefully selected suppliers that carry out certain functions on our behalf. We only share the minimum personal data that enable our suppliers to provide their services to you and us and we have contractual arrangements in place with them.

10.how long do we retain your personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, we may use this information indefinitely without further notice to you.

11.What are your privacy rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data which are as follows:

  • Access to your personal data - This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Correction of your personal data - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Erasure of your personal data - This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

 Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data - This right can be exercised where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Transfer of your personal data -This enables you to ask us to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of the rights set out above, please send your request to mydata@lycafly.com  

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

12.How to contact us?

You may contact our Customer Services Department on 020 7132 3232 or email the Customer Services Department at  cs@lycafly.com.

For compliance questions in relation to this policy, please email us at mydata@lycafly.com

You have the right to make a complaint at any time to the relevant data protection supervisory authority.

We would, however, appreciate the chance to deal with your concerns first before you approach the supervisory authority, so please do contact us in the first instance.

 

Changes to the policy

This privacy policy applies from 23 May 2018 until such time it is updated again. You can contact us for historic versions.


Privacy Notice

It's important to us that you understand what personal information we have, how we use it and how you can check and update some of your information. This is why we are providing you with a snapshot of the main points in our privacy policy.

If you would like to read the full policy, you can find it here

So, what information do we have about you?

We collect, use, store and transfer different types of personal data about you and other individuals on your booking and we have grouped them in various categories. Some information can be sensitive and we use this category of information for specific purposes only.

Please read our privacy policy for more information.

Why do we collect your personal information?

We keep your personal information secure and use it to provide you with the products and services you are interested in, help us administer your account, improve our products and services and manage our business.  It also helps us to tell you about our new products and services. We are required by law us to keep some information as well.

We collect personal information from you when you sign up with us or contact us and also when you use our products and services, for example, when you register as a LycaFly customer to use our products and services and visit our website.

For a detailed explanation of why we collect and how use your personal information, please visit our privacy policy.

Who do we share your data with and where is it transferred to?

We may share your information with others who help us run our business and provide you with our services. This could mean sharing your information with others, such as Lyca affiliated companies and third parties for call centre support, technical support and regulatory bodies, and destination management companies.

Some of these organisations are based outside the EU.  These countries do not provide the same level of data protection as in the EU. Your privacy matters to us. We have implemented appropriate safeguards, where required.

Where there are no appropriate safeguards in place, we have taken steps to ensure your privacy rights are protected, at least in accordance with the requirements of the General Data Protection Regulation in the EU, including requiring appropriate security measures, setting out contractual obligations to protect your personal data and monitoring of compliance.

Please read our privacy policy for more information.

How can you manage your marketing preferences?

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us mydata@lycafly.com

You may also contact us let us know whether you're happy to hear from us by email, text, or telephone.

Privacy & Cookies Policy

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