Scope and information that this Privacy Policy covers
The website contains links to third party websites, including websites of our independent partners. We do not own, operate or control the websites of such third parties, or Hagaero portal partners or sales associates who are independent third parties. Accordingly, this Privacy Policy does not apply to any website maintained or operated by a third party, nor to the website of the sales representative, collection, use, storage, disclosure or other processing of your Personal Information. By clicking on these links, you will access a third party website, where you will be subject to that website's privacy policy, and we encourage you to read this document. Please be aware that we are not responsible for the privacy practices of these other sites, including those of our independent partners.
- 1. COLLECTION AND USE OF YOUR PERSONAL INFORMATION
- We collect your Personal Information on the Site to improve the services we offer to you, improve the Site and inform you of other services and products that may be available through us, our company and our marketing partners. We collect Personal Information about you when you interact with or use services offered on this Site, such as:
- records for special communications, how to save a search for you and, but only if you request, send new listings that fit your saved search profile;
- requests to find a flight.
- requests to contact us.
- requests to receive periodic sector updates.
- requests to email a listing to a friend.
- name;
- e-mail address.
- phone or cell number.
- location via IP address.
- device being used (for our mobile site).
- cookies and similar technologies.
- other relevant data.
If you submit a request through this Site to locate or book a flight, you will be asked to provide Personal Information and we will forward that information to Hagaero portal partners and their sales associates in the country where the property or sales associate is located to respond to your request. - 2. USE AND SHARING OF PERSONAL INFORMATION
- Whatever the purpose, be it sharing with service providers or other external entities, we only process and share your Personal Information to the extent reasonably necessary to meet your requests and meet our legitimate business and legal objectives. When we disclose Personal Information to external entities to perform support services for us, we contractually establish that we may access your Personal Information only to perform those support services. We can also use what we know about you to offer other products and services. We may combine your information online with information collected from online or offline sources or information we already have. We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose permitted by law.
- 2.1. 21st Century Business Activities
e generally process and may disclose your personal information to others for:- provide products and services, including the authentication of authorized users and marketing of our products and services;
- perform certain services or other transactions initiated by you;
- respond to your questions, complaints or comments about our products or services;
- send you communications about online transactions, product information, advertisements and promotions, electronic newsletters or other requested notices or offers tailored to you;
- allow our advertisers to deliver more personalized content and track the effectiveness of certain advertising campaigns.
- comply with applicable law, obey court orders, cooperate with law enforcement authorities or prevent any suspicious illegal activities;
- help manage our business; or
- for any other daily business purposes, such as product development and site administration.
- 2.2. Location of Servers and Transfer of Information to the United States.
The website is hosted by servers in Brazil and we operate our business nationally, some countries may not provide the same level of data protection as your country of origin. If you are located, for example, in the European Economic Area or Switzerland (collectively, "Europe"), your Personal Information will be transferred to the United States and possibly to other jurisdictions (for example, to the location of a property requested information), which are not considered to provide an adequate level of protection under local data protection laws.
- 2.1. 21st Century Business Activities
- 3. LEGAL GROUNDS FOR THE COLLECTION, USE, SHARING AND OTHER PROCESSING OF PERSONAL INFORMATION
- Certain jurisdictions, including those in Europe, require identification of legal grounds for the collection, use, sharing and other processing of Personal Information. Hagaero Portal is based on the following legal grounds for the collection, use, sharing and other processing of Personal Information, as described in this Privacy Policy:
- necessary to provide information or otherwise perform a contract with you as an individual;
- execution of the contract with our franchisees;
- Implementation and operation of a matrix structure across the group and information sharing across the entire group;
- customer relationship management and other forms of marketing and analysis;
- fraud prevention, misuse of company IT systems or money laundering;
- reporting scheme operations;
- physical, IT and network perimeter security;
- internal investigations;
- intended mergers and acquisitions;
- compliance with legal obligations and / or defense against lawsuits, including those in the area of labor, social security and data protection, tax and corporate compliance laws.
- protection of the vital interests of any individual;
- carrying out a task performed in the public interest or in the exercise of official authority vested in the 21st century; and
- consent, as permitted by applicable law.
- 4. YOUR RIGHTS TO YOUR PERSONAL INFORMATION
- Você tem as seguintes opções em relação ao nosso uso e divulgação de suas informações pessoais:
- Marketing communications - If you no longer wish to receive any marketing communications, remain on a publicity list to which you have previously subscribed, or receive any other communication from the Hagaero portal, follow the unsubscribe link in the relevant communications or contact us using the link on bottom of the message communication. Even after you deactivate or update your marketing preferences, we may still contact you for transactional or informational purposes. This includes, for example, customer service issues, returns or inquiries related to purchased services, surveys or recalls, or any questions about a specific order.
- Cookies and Similar Technologies - Review your browser or computer settings and see some options related to cookies below.
- You are not required to provide all Personal Information identified in this Privacy Policy to use our Site, but certain aspects of our Site will not be available to you. However, you can use our services without consenting to non-essential cookies or direct marketing emails; The only consequence is that our products and services will be less communicated, we may not be able to provide the support you are looking for, and you may miss out on attractive promotions and news about our products and services.
- Europe and other non-Brazilian jurisdictions maintain local data protection regulations that confer certain data protection rights to individuals. The Hagaero portal will address these rights when required by applicable laws. Please note that if you are a partner or employee of a partner, and you gain access to or process your personal information in that context, contact your employer/partner, who will be in a better position to answer your query. If applicable, and you wish to exercise any of these rights, please contact us as described below.
- Right of access - You have the right to obtain confirmation from us that Personal Information relating to you is processed and to request access to Personal Information. Access information includes, among other things, the processing purposes, the categories of Personal Information involved and the recipients or recipient categories for which Personal Information has been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of your Personal Information in process.
- Right to rectification - You have the right to obtain from us the rectification of inaccurate personal information about you. Depending on the purposes of the processing, you may be entitled to have incomplete Personal Information filled out, including providing a supplementary declaration.
- Right to delete (right to be forgotten) - Under certain circumstances, you have the right to have us delete Personal Information about you, and we may be required to delete that Personal Information. Personal data can reside in backup files that must be retained for a longer period, either because it is impracticable to isolate individual data within the file or because it is necessary to retain it for contractual, legal or compliance reasons. Personal information will not be restored to production systems (except in certain rare circumstances, for example, the need to recover from a natural disaster, etc.). In such cases, Personal Information can be restored from the backup, however, all necessary steps will be taken to honor the initial request and delete the primary instance of the data.
- Right to processing restriction - Under certain circumstances, you have the right to obtain a restriction on the processing of your Personal Information from us. In this case, your data will be marked and can only be processed by us for certain limited purposes. Since the Hagaero portal processes and uses your Personal Information primarily to execute a contract for a service relationship, the Hagaero portal may have a legitimate interest in the processing that will void your restriction request, unless the restriction request is related to marketing activities.
- Right to data portability: Under certain circumstances, you have the right to receive Personal Information about you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another entity without impediment from us.
- Right of objection: Under certain circumstances, you have the right to object, for reasons related to your particular situation, at any time, to the processing of your Personal Information by us, and we may be asked to no longer process your Personal Information. When permitted by applicable law, you also have the right to file a complaint with a competent data protection supervisory authority.
- 5. SAFETY
- The security and confidentiality of your personal information are important to us. That is why we have adequate technical, administrative and physical controls to protect your Personal Information from unauthorized access, use, and disclosure. For example, we offer the option to encrypt all of the information you send to us using Secure Sockets Layer (SSL) technology, which helps protect information during transport to our Site. We periodically review our security measures to assess industry best practices and update them accordingly. Even so, despite our reasonable efforts, no security measure is perfect or impenetrable.
- 6. DATA RETENTION
- Depending on the service you request, we will keep your Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Policy or as outlined in our contracts with our franchisees unless a longer retention period is required or permitted by law. This applies to us.
- 7. COOKIES AND SIMILAR TRACKING TECHNOLOGIES
- Information collected through technology - Information is also obtained in other ways through technology. Some of this information may be linked to you personally. In accordance with applicable law, the Hagaero portal uses and allows third parties to use essential and non-essential cookies, online tracking tools, web beacons and similar technologies (collectively, "cookies\”) on our Site. We process this information to help our Site to work properly and better understand our customers' needs.
- The cookies on our website generally fall into the following categories:
- Strictly Necessary Cookies: are necessary for the functioning of our Site. They include, for example, cookies that allow you to log in to secure areas. These cookies are session cookies that are deleted when you close your browser.
- Analytical/performance cookies: they allow us to recognize and count the number of users on our site and see how those users navigate our site. This helps to improve the functioning of our website, for example, ensuring that users easily find what they are looking for. These cookies are session cookies that are deleted when you close your browser.
- Functional Cookies: improve the functional performance of our website and facilitate its use. For example, cookies are used to remember that you have visited the Site before and asked to remain logged in to it. These cookies are session cookies that are deleted when you close your browser.
- Targeting cookies: they record your visit to our site, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the site and on other sites you visit. These cookies qualify as persistent cookies because they remain on your device for us to use during an upcoming visit to our website. You can delete these cookies through your browser settings. We will not collect these cookies from people in Europe without proper consent.
- Use of cookies - we advertise in a variety of ways, including online through managed social media presence and on other non-affiliated sites and mobile apps. To understand the performance of our advertising campaigns, we may collect certain information through cookies on our Site through our advertising service providers. The information we collect includes IP addresses, the number of page visits, pages viewed on our Site, search engine references, browsing activities over time and on other sites after visiting our Site or applications and responses to advertisements and promotions on the websites and apps on which we advertise.
- We also use certain information to identify new visitors to our Site, recognize recurring visitors, advertise on other sites and mobile applications that are not affiliated with us, analyze the effectiveness of our ads, better understand our audience, customers or other visitors to the Site and determine if you may be interested in new products or services.
- Controlling our tracking tools - your browser can give you the ability to control cookies. How you do this, however, depends on your browser and the type of cookie. Some browsers can be configured to reject all browser cookies. If you configure your computer to block all cookies, you may be able to interrupt certain features of the web page and limit the functionality that we can provide when visiting or using our website. (for example, we won't be able to provide you with the surveys you asked us to save). You can change your cookie settings at any time. Some browsers have a "Do not track" feature that allows you to inform sites that you don’t want your online activities to be tracked. These browser features are not yet uniform, so we are not currently configured to respond to these signals.
- Controlling interest-based online ads - we sometimes work with online advertising providers to provide relevant and useful ads. This may include advertisements served on or through our portal. This can also include ads served on other companies' websites. These advertisements may be based on information collected by us or by third parties. These ads may also be based on your activities on our website or on third-party websites.
- For more information about our ad service provider and its cookies, including information on how to disable these technologies, visit http://optout.aboutads.info. In addition, users can prevent the collection of data generated by the use of Google by Google. The website (including its IP address) by downloading and installing a browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=pt-BR.
- 8. CHANGES OR OTHER UPDATES IN THIS PRIVACY POLICY
- We may change this Privacy Policy at any time. If we make any material changes to the way we collect, use, disclose or process personal information, we prominently publish an updated Privacy Policy on our Site. Any significant changes to this Privacy Policy will take effect 10 days after the publication of the updated Privacy Policy or as required by applicable law. When required by law, we may ask for your prior consent for any material changes we make to this Privacy Policy.
- 9. COMMENTS AND QUESTIONS
- If you have any questions or concerns about this Privacy Policy or wish to correct or update your Personal Information or unsubscribe from any sector updates requested by modifying or deleting your profile on the Site, send a message to customer service via email contato@hagaero.com.br.
Last updated on October 02, 2018