Without our users’ data, ClaimCompass Ltd. would not be able to function. That’s why we take the privacy of our users’ data very seriously and we have set a privacy protection policy in place that is robust, secure, and is in compliance with all applicable regulations. Below you will find more information on the types of data we collect and how we use it.
“ClaimCompass Ltd”, in its capacity as data controller, strictly observes the requirements of the General Regulation on Data Protection (Regulation (EU) 2016/679) and the Personal Data Protection Act.
The purpose of this Privacy Notice (hereinafter referred to as "Notice") is to provide the necessary information regarding the processing of personal data that "ClaimCompass" Ltd ("ClaimCompass", "We") carries out within the processes and services, which we provide through this website (the "Platform").
We assume that if you use the Platform, you are familiar with the content of this Notice. We reserve the right to periodically update and change its content, the latest version of which is always available on the Platform.
II. Information about us
Address: 1408 Sofia, zh.k. Ivan Vazov, 12 Emil Bersinski Str., 3rd floor
Email: [email protected]
To contact our data protection officer:
Address: 1408 Sofia, zh.k. Ivan Vazov, 12 Emil Bersinski Str., 3rd floor
Email: [email protected]
III. Information on the supervisory authority
Commission for personal data protection (CPDP)
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
Email: [email protected]
IV. Processes, personal data, purposes and legal bases of processing
All personal data are processed fairly and transparently for specific and lawful purposes only when necessary and in accordance with applicable European and national data protection legislation. The processing of personal data is limited only to the type, volume, and terms established by law and / or necessary to achieve these lawful purposes.
The type and volume of personal data processed are determined by the processes in connection with which We collect and use them.
1. Account registration
The possibility to file claims is available only to registered users who have created an account in the Platform. In this regard, anyone wishing to register must be at least 18 years old and provide:
- details of the flight in respect of which a claim will be made (flight number, flight date, reservation number, e-ticket number, reasons for the flight delay/cancellation);
- e-mail address.
We need this information to carry out an initial assessment on whether you are entitled to compensation in relation to the flight in question, as well as to contact you to inform you of the result of this assessment and, where applicable, to request additional information and all necessary documents to take further action in the direction of filing your claim.
2. Filing a claim
For the purposes of the subsequent filing of your claim before the respective airline, and in case of failure to reach an out-of-court settlement, before national and European institutions responsible for the application of European Regulation 261/2004, ClaimCompass additionally requires:
- address (address, city, country),
- telephone (if provided),
- credit or debit card information, bank account number or other banking and payment information in connection with the payment of the compensation,
- signature (placed on the respective power of attorney),
In case you file a claim against the airlines listed below, we may also collect a copy of an identification document (passport or ID) or a copy of a booking confirmation or e-ticket. The documents are collected in accordance with the Information notice for air transport passengers issued by the European Commission on 09.03.2017 (available here). The documents are collected for the following airlines: Wizz Air, Air France/KLM/Delta, Cathay Pacific, Corsair, Ethiopian Airlines, Finnair, Thomson Airways, Qatar Airways, Royal Air Maroc, Saudi Arabian Airlines, Sky Express, Latam/Lan Airlines, Singapore Airlines, Turkish Airlines, Free Bird Airlines, Sunexpress, Emirates, Onur Air, Tailwind Airlines.
The processing of the above data is necessary to provide you our services, therefore it is carried out for entering into and performance of the contractual relationship with you, as well as to fulfill all our legal obligations arising thereof, including but not limited to consumer protection, electronic communications, and e-commerce, tax and accounting, as in the event of a legal dispute between you and ClaimCompass in connection with the contract for the provision of our services - for the establishment, exercise or defence of/from complaints and legal claims.
Any refusal to provide the above personal data may result in us not being able to enter into a contractual relationship, respectively provide you our services, process your claim, and lodge a claim for compensation on your behalf, respectively to fulfill our legal obligations arising in this regard.
3. Providing feedback
ClaimCompass process personal data to respond to your inquiries, complaints, and requests received through the Platform, including:
- customer number, code or other identifier created for identification;
- e-mail address;
- the information contained in the content of the message/inquiry,
If the inquiry or request concerns issues related to your contractual relationship with ClaimCompass, the processing of this personal data is based on the performance of a contract (with a current customer) or on steps taken at the request of a potential future customer before concluding a contract. In other cases, ClaimCompass processes this information based on the following legitimate interests and goals:
- providing explanations and additional information and answering questions about services of ClaimCompass, as well as supplementing the information provided on the Platform;
- improving the quality of services and facilitating communication with you by receiving feedback and evaluation for them.
In some cases, we may ask you or you, on your own initiative, may decide to leave a comment with an appraisal of ClaimCompass and our services, in which case we process and publish on the Platform:
- country of residence
- flight details
- size of compensation
- the information contained in the content of your message/comment.
This information is processed by ClaimCompass based on your consent, demonstrated by your active actions of publishing an appraisal/comment, which can be withdrawn free of charge at any time by notifying us at the e-mail address indicated above, which shall not affect the lawfulness of the processing carried out so far.
4. Providing notifications for products and promotions
In case you subscribe to our newsletter for our current products and promotions, we will process your email address to send this information. We process this information based on your consent, which can be withdrawn at any time by following the active link contained at the end of each email received, which shall not affect the lawfulness of the processing carried out so far.
5. Administration of the website
- technical and statistical information on visits;
- Internet Protocol (IP) address;
- login information, duration of the visit, a setting of time zones;
- types and versions of the browser;
- traffic and other data.
When this processing is not essential to the proper functioning of the website, we store and/or track cookies after obtaining your consent for each specific category of cookies and the purpose of their use on your first visit to the website through the cookie managing tool, integrated on the Platform.
V. Retention periods
We store your personal data only as long as it is necessary for the purposes for which they have been collected and in accordance with the applicable law, including, but not limited to, consumer protection, electronic communications, and e-commerce, tax and accounting. The retention periods for the different types of personal data depend on the purpose of their processing, such as:
1. Account registration: until the moment of its deactivation, except for the information related to the service contracts concluded with ClaimCompass;
2. Service contract:
2.1. information on the contract and its performance: 5 years after the termination of the contractual relationship, in accordance with the 5-year limitation period for possible claims in its regard;
2.2. invoices and accounting documents: according to the terms under Art. 12 of the Accounting Act;
2.3. Relevant accounting and commercial information: according to the terms under Art. 38 of the Tax and Social Insurance Procedure Code;
2.4. information related to complaints/claims: according to the terms in Section IV of the Consumer Protection Act.
2.5. information related to an arisen legal dispute between you and ClaimCompass: for the period necessary to take appropriate action and establish, exercise or defend legal claims.
3.1. for the period necessary for the administration and response of the respective communication, unless further storage is necessary for the establishment or exercise of legal claims/claims or protection against legal claims;
3.2. in case you have contacted us and for any reason, there has been no final conclusion of a contract or any provision of services: for a period not exceeding 6 months.
3.3. in case you have left your comment and / or appraisal for ClaimCompass: until withdrawal of your consent.
4. Provision of notifications for products and promotions: until the withdrawal of your consent.
VI. Sharing personal data
ClaimCompass uses the services of third parties to support certain activities. In this regard, we may disclose personal information to the following parties:
- the relevant airline to which your claim is addressed;
- the respective nationally designated body under Article 16 of Regulation 261/2004. The full list of national designated authorities under Regulation 261/2004 can be found here.
- crime prevention and detection authorities and other regulatory authorities that have the power to request information;
- lawyers and professional advisers to whom we have referred your claim for initiation of legal actions on your behalf;
- judicial authorities under the terms and conditions provided by the national law of the respective country, when filing a claim on your behalf;
- banks and banking institutions, in connection with the administration of payments;
- our accountants, professional consultants, and auditors;
- service providers for the purposes of providing and maintaining software products for the implementation of certain internal processes, storage, exchange and tracking of information. In this regard, ClaimCompass uses the following software products and similar services:
|Intercom||Intercom||Management of correspondence with clients|
|Mailchimp||Mailchimp||Email campaign management|
|Mautic||Microsoft Azure||Email campaign management|
|Skype||Skype||Connecting with customers|
|Typeform||Typeform||Collection of answers to forms and surveys|
|Google Apps||Google Apps||Sending e-mail correspondence|
|Trustpilot||Trustpilot||Management of user ratings and reviews|
At ClaimCompass we use Microsoft Azure servers located in the European Union / European Economic Area. However, in connection with some processes as well as some tools, some of your data may be transferred outside the European Union / European Economic Area. The transfer of such personal data takes place only with appropriate guarantees to ensure an adequate level of protection and compliance with all provisions of the applicable legislation regarding the transfer. For example, an official decision made by the European Commission that a third country, a territory or one or more specified sectors within that third country, or the international organisation ensures an adequate level of data protection. Also, membership of companies under the "EU-U.S. and Swiss-U.S. Privacy Shield Frameworks " (Privacy Shield) provides an adequate level of data protection when transferring them to the United States. The full text of the Privacy Shield framework can be found here. In other cases, or in addition to the Privacy Shield, the respective providers use the standard contractual clauses approved by the European Commission. You can learn more about them here.
|Platform||Company||Privacy policies||Appropriate guarantees|
|Microsoft Azure||Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA||Available here||Privacy Shield|
|Intercom||Intercom, Inc., 55 2nd Street, 4th Fl., San Francisco, CA 94105, USA||Available here||Privacy Shield|
The Rocket Science Group LLC
675 Ponce De Leon Ave NE Ste 5000
Atlanta, GA, 30308-2172 USA
|Available here||Privacy Shield|
|Sendgrid||Twilio Inc., 375 Beale Street, Suite 300, San Francisco, CA 9410||Available here||Privacy Shield|
|Skype||Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA||Available here||Privacy Shield|
|Typeform||Typeform SL, C/Bac de Roda, 163 (Local), 08018 – Barcelona, Spain||Available here||Standard contractual clauses (where applicable).|
|Google Apps||Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA, 94043, U.S.||Available here||Privacy Shield|
|Trustpilot||Trustpilot, Inc., 245 5th Avenue, 4th floor, New York, NY 10016, USA.||Available here||Standard contractual clauses (where applicable).|
VII: Rights in relation to the protection of personal data
The rights you have in connection with the protection of your personal information are as follows:
1. Right to information: to be notified of the collection and use of your personal data, as is the purpose of this Privacy Notice.
2. Right of access: to request free of charge information on whether personal data relating to you are processed, including but not limited to information on the processors involved, categories of data, origin, purpose, legal basis and processing time.
3. Right of rectification: to request the rectification of incomplete, inaccurate, inappropriate or outdated data.
4. Right of erasure: to request that your data be erased if:
4.1. have been processed unlawfully;
4.2. are no longer necessary in relation to the purposes for which they were processed;
4.3. your consent has been withdrawn if it has served as a basis for processing and there is no other legal basis for processing;
4.4. if you have objected to the processing of your personal data carried out for the purposes of the legitimate interests of ClaimCompass and there are no legal grounds for the processing, and there are no overriding legitimate grounds for the processing;
4.5. the period of data retention prescribed by the applicable legislation has expired;
4.6. the erasure of personal data has been ordered by court or competent supervisory authority.
5. Right of restriction: to request a restriction of personal data if:
5.1. you contest the accuracy of personal data - for the period of their verification;
5.2. the processing is unlawful, but you do not wish the personal data to be deleted, but instead demand restriction of their processing;
5.3. ClaimCompass no longer needs personal data for the purposes of the processing, but you require it for the establishment, exercise or defense of legal claims;
5.5. you have objected to the processing of your personal data for direct marketing purposes;
5.6. when checking whether the legitimate interests of ClaimCompass take precedence over your interests.
6. Right to object: to object on grounds relating to your specific situation against the processing of personal data:
6.1. carried out for the purposes of the legitimate interests of ClaimCompass.
6.2. carried out for direct marketing purposes.
7. Right to object to automated decision-making, including profiling to object to decision-making that is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
8. Right to data portability: to request that we provide you with the personal data we store in a structured, widely used and machine-readable format if they are processed based on your consent or contract and are processed automatically.
9. Right to withdraw your consent to processing: to withdraw your consent, where such consent has been granted for the processing of personal data, at any time, free of charge, bearing that the withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.
10. Right of defense: to seek remedy by:
10.1. lodging a complaint with the Bulgarian Commission for Personal Data Protection;
10.2. bringing legal action before the competent court.
VIII. Contact ClaimCompass
If you have any questions regarding the protection of personal data, you can contact us at our contact details provided above.
To exercise any of the above rights, you should submit your request in person or via proxy:
- on the spot in the office of ClaimCompass;
- on paper by mail, through a licensed postal operator;
Irrespective of the application form, for the request to be accepted and processed, it should contain:
- name, address, PIN;
- description of the request;
- the preferred form of obtaining information;
- date of submission of the application and address for correspondence;
- signature of the sender or of the proxy / legal representative. When applying via proxy, the power of attorney shall be attached to the application.
A request submitted electronically should be duly electronically signed in accordance with the Electronic Document and Electronic Trust Services Act. ClaimCompass may request additional information necessary to verify the identity of the applicant.
“ClaimCompass Ltd”, employs cookies and tools to customize content and ads, provide features, and analyze the traffic and how you use this website (the "Platform").
All visitors of the Platform, regardless of whether they are registered or not, may fall within the scope of some of the cookies and tools used.
What are cookies?
Cookies are small text files that are stored on your computer or mobile device when you visit the Platform. They facilitate its proper operation and visualization, allow to store inputs of preferences (e.g. username, language, font size and other visualization settings) and are able to retrieve certain anonymous statistical information on the use of the Platform.
Types of cookies
Based on their validity cookies can be:
- session cookies: automatically erased when the browser is closed.
- persistent cookies: stored on the computing device until the set expiration time, provided that the user does not delete them earlier.
Based on the source, cookies can be:
- first party cookies: placed by the Platform and controlled by ClaimCompass Ltd.
- third party cookies: the Platform may use external services, links to or embedded content and functionalities from other sites for which separate cookies are employed. Thus, in the course of navigation in the Platform it is possible to place cookies on your device originating from these other sites.
In terms of functionality, cookies can be:
- necessary: help make the Platform usable by enabling basic functions like page navigation and access to secure areas of the website. These cookies cannot be deactivated on their own;
- preferences: enable the Platform to remember information that changes the way it behaves or looks, like your preferred language or the region that you are in. allow the Platform to provide improved functionality and personalization (for example, whether you have accepted (or rejected) the use of analytics cookies, etc.). According to your preferences, they can be activated and, after initial activation, deactivated. However, if you do not enable these cookies, some of the functionality they enable may not work properly.
- statistics: help us to understand how visitors interact with the Platform by collecting and reporting information anonymously. According to your preferences, analytics cookies can be activated, and after initial activation - to be deactivated;
- marketing: used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. According to your preferences, they can be initially activated, and after initial activation - to be deactivated;
- unclassified: cookies that we are in the process of classifying, together with the providers of individual cookies.
Cookies used on the Platform
More information about the specific cookies used on the Platform is available in the integrated cookie management tool, which can be accessed here.
You can manage / delete cookies from your device at any time via the Platform's integrated cookie management tool, as well as to block their future use by changing your browser settings to deny the use of some or all cookies. More information about cookies is available at www.allaboutcookies.org.
Information on how to manage cookies based on the preferred browser may be found as follows:
However, deleting/disabling all cookies may restrict the functionality of the Platform and/or impede access to it or to parts of it.
This page was last updated on: 10.06.2020