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Privacy Policy Newsletter

Last updated July 2024

We recognise the importance of protecting your privacy and User rights in terms of data protection. The Internet is an extremely effective means of transmitting personal information, and the lastminute.com group ('lm group') and all the companies in it are seriously committed to complying with the applicable legislation governing the protection and security of personal data, in order to ensure safe, controlled and confidential browsing for users who visit and/or use our website and/or use our comparison service (hereafter 'Users').

This Privacy Policy describes how we collect, use, process, and disclose your personal data in conjunction with your access to and use of our Website and services and, specifically:

1. Who is the controller of your data?2. What categories of your data do we collect and use?3. Why and how do we collect your data?4. Who sees, receives and uses your data and where?5. How long do we retain your data?6. What are your data protection rights and how can you exercise them?7. Contact details of the data controller8. Contact details of our data protection officer9. Information about cookies

10. Privacy notice for Facebook11. Update and old versions of this privacy policy

It also informs you of how you can exercise Your Rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the section below.

If you see an undefined term in this Privacy Policy (such as “Service” or “Website”), it has the same definition as in our Company's contractual service conditions.

1. Who is the controller of your personal data?

As indicated in the General Terms and Conditions relating to use of the website, the services offered via the website are provided by Blue SAS, which owns the website. Therefore, where the terms 'Company', 'we', 'our' and 'data controller' appear in this privacy policy, they refer in particular to:

Blue SAS, a company incorporated under French law with registration number 490 641 354 and registered office at 75, boulevard Haussmann - 75008 Paris, France, the data controller for processing the personal data of Users in accordance with this privacy policy (hereafter 'Company', 'we', 'our', 'data controller').

2. What categories of your data do we collect and use?

When you visit the Website and use our Comparison Service (you as a 'User'), we collect the categories of personal data as follows:

2.1. Personal data provided by you

  • More specifically:
  • When contact is made between us and the User via the Support Service (where available) or email: personal data provided by the User when he/she connects with us, including name and username, telephone number and email address.
  • When you download and use the app: we do not collect personal data from you directly. Note, however, that some information will be shared via Facebook (section 11.2 of this privacy policy). By installing the app you declare that you have read and accepted the privacy policy and the terms and conditions for the app.
  • The provision of the above personal data, where requested, is necessary for the adequate performance of the requested service and to allow us to comply with our legal obligations except when we rely on consent as legitimate basis for processing and or our legitimate interest. Without it, we may not be able to provide you with all the requested services.

    It is important that all the personal data you give us is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.

    2.2. Personal data collected automatically from our Website, from communication we send, and/or from third parties

    See the cookies section of this Privacy Policy (9. Information about cookies) for further information on the purposes for which we collect and use this information. Please note that your personal information may also be linked to Cookies, i.e. to collect information on how you use our product and services.

  • We may monitor calls to our Support Service (where available), for the purposes of quality control, analysis, staff training and/or to protect ourselves in the event of a legal dispute. Any personal data obtained from the User during the call will be processed in accordance with this privacy policy.
  • To the extent permitted by the applicable law, we may receive additional information about Users, such as information on fraud detection and warnings from third-party service providers and/or partners, to the extent permitted by applicable law, in relation to our fraud prevention activities.
  • 3. Why do we collect your data?

    In general terms, we use your personal data to provide you with the services you request, provide customer service (where available), send you marketing and promotional communications, notify you about important changes to our Website and to deliver our content and ads which we think may be of interest to you. More specifically:

    Why?

    A. n.a.

    **************

    B. n.a.

    **************

    C. To meet the legal, regulatory and compliance requirements and to respond to requests by government or law enforcement authorities conducting an investigation.

    On which legal basis?

    To comply with the law (i.e. to share personal data with regulatory authorities)

    **************

    D. To carry out aggregative statistical analyses on anonymised groups or to analyse identifiable individuals behaviour so that we can see how our Website, products and services are being used and how our business is performing.

    On which legal basis?

    To pursue our legitimate interest (i.e. improving our Website, its features and our products and services)

    **************

    E. n.a.

    **************

    F. To send you personalised and profiled marketing communications

    On which legal basis?

    Only with your prior explicit consent, to share with you via email and/or on our website or third party ones (e.g. using ads) the best deals and offers on products and services we think you might find interesting. If you have already given us your consent to profiling activities through marketing cookies or other means, we may send personalised communications. The personalised service or the offers can be related to the following sectors (please note that we do not share your email address with third parties): tourism, leisure, entertainment, high technology, fashion, decoration, consumer goods, food and beverage, finance, banking, insurance, energy, environment, communication, mass media, real estate, pharmaceuticals, clothing and textiles, education and training, energy, publications and publishing, information and communications technology, retail, sport, telecommunications and general services.

    For this purpose we may:

    - analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you.

    - combine the information you give us via cookies and other tracking technologies with information related to your purchases.

    - analyse information about the way you engage with communication material you receive from us, such as data on when emails have been opened or to determine if you have viewed or interacted with an ad, to record the number of times you have viewed each ad, to prevent a single ad being shown to you too frequently etc.

    - temporarily share an encrypted version of your email address, with carefully selected partners who may combine this information with other forms of online identifiers or other personal data in order to present you with our offers cross device or cross channel, for example on social networks (Facebook, Pinterest, Instagram, Twitter).

    - use automated decision making to segment and target product offers based on your demands and needs. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant. You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. For further details, you may contact our Data Protection Officers whose details are provided in this privacy policy.

    On which legal basis?

    Where you give your consent (by ticking the appropriate checkbox or by inserting your email address into the proper field to receive personalised communications about us and our selected third parties).

    **************

    G. n.a.

    **************

    H. To keep our Website and systems secure and to prevent and detect fraud, security incidents and other crime.

    On which legal basis?

    To pursue our legitimate interest (i.e. ensuring the security of our Website)

    **************

    I. To verify compliance with our terms and conditions and for the establishment, exercise or defence of legal claims.

    On which legal basis?

    To pursue our legitimate interest (i.e. compliance with our terms and conditions, protection of our rights in the event of any dispute or claim)

    **************

    J. To tailor and personalise online marketing notifications and advertising for you based on the information on your use of our Website, products and services and other sites collected through cookies (please see the Cookies section of this Privacy Policy for further information).

    On which legal basis?

    Where you give your consent (i.e. through the cookie banner or by your browser's settings)

    **************

    K. n.a.

    **************

    Where we rely on legitimate interest as a basis for processing your personal information, we carry out an assessment to ensure that our interest in the use of your data is legitimate and that your fundamental rights of privacy are not outweighed by our legitimate interests (‘balancing test’). You can find out more information about the balancing test by contacting our Data Protection Officer at to [email protected].

    4. Who sees, receives and uses your data and where?

    4.1. Categories of recipients of your data

    We share your personal data, for the purposes described in this Privacy Policy, to the following categories of recipients:

  • Our third-party service providers (including other entities of the lmastminute.com group), which process your personal data on our behalf and under our instructions for the purposes described hereinabove acting as data processors, such as those providing us with IT and hosting services and customer support, analytics and administration services etc.
  • Our business partners who are social media platforms when it is explicitly requested by you (e.g. when you share information generated from our website onto those platforms), when using social media authentication methods or downloading our App whereby you agree either with our privacy policy or with the platforms that we may share information about your online activity with these partners even when you are not logged in to the social media platform). or when these business partners that provide us with functionality capabilities request information about the specifications of the device that the App has been installed on, which they have obtained the right to do. The information you share will be governed by the social media's privacy policy. Please check clause 2.3 of this Privacy Policy for more information.
  • Competent authorities when we are required to do so by the current law.
  • Competent authorities and Law and enforcement third parties when this is necessary so that we can enforce our terms of use and protect and defend our rights or property or the rights or property of any third party.
  • Third parties that receive the data (e.g. business consultants, professionals for delivering due diligence services or assess value and capabilities of the business) when it is necessary in connection with any sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners.
  • The complete list of parties to which your personal data may be disclosed is available at our registered office and may be requested by writing to [email protected].

    4.2. International transfer of your data

    Users’ and/or Customers’ personal data is processed in at the Data Controller’s registered office (see point 1), on the lm group servers, and at the offices of other entities to which data may be provided in order to provide the services requested of the Data Controller.

    Given the fact that we are an international travel company, we also transfer your personal data to:

  • Countries outside the European Economic Area (EEA) where data protection laws may provide less protection than EEA legislation. This happens when:
  • we communicate data to independent data controllers who may process data outside the EEA to provide a service requested by the User;
  • we communicate the data to our service providers who act as data controllers on our behalf and who may be in countries outside the EEA. When such transfers take place, we ensure that they are done in accordance with this privacy policy and that this is governed by the standard contractual clauses approved by the European Commission to ensure adequate protection for data subjects. Our suppliers who act as data controllers may be involved in activities such as responding to requests, providing advertising and marketing services on our behalf and providing assistance services via electronic communications or call centres.
  • Any Users requiring further details regarding the safeguards put in place should email us at [email protected]

    5. How long do we retain your data?

    We retain your personal data for as long as is required to achieve the purposes and fulfil the activities as set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law. Further information about the retention period is available here:

    DATA USED FOR MARKETING PURPOSES (CRM)

    Data used for marketing activities to customers/users subject to the consent.

    Retention period: 5 years from the consent or the renewal of the consent via interaction with marketing communications

    DATA COLLECTED VIA TAG

    Technical cookies

    Retention period: Max 3 years from the date of browsing on our websites

    Non-Technical cookies

    Retention period: Max 1 year from the date of consent

    6. What are your data protection rights and how can you exercise them?

    You can exercise the rights provided by the Regulation EU 2016/679 (Articles 15-22), including the right to:

    Right of access - To receive confirmation of the existence of your personal data, access its content and obtain a copy.

    Right of rectification - To update, rectify and/or correct your personal data.

    Right to erasure/right to be forgotten and right to restriction - To request the erasure of your data or restriction of your data which has been processed in violation of the law, including whose storage is not necessary in relation to the purposes for which the data was collected or otherwise processed; where we have made your personal data public, you have also the right to request the erasure of your personal data and to take reasonable steps, including technical measures, to inform other data controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

    Right to data portability - To receive a copy of your personal data you provided to us for a contract or with your consent in a structured, commonly used and machine-readable format (e.g. data relating to your purchases) and to ask us to transfer that personal data to another data controller.

    Right to withdraw your consent - Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes.

    Right to object, at any time - You have the right to object at any time to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement , or where we are using your data for direct marketing.

    Right not to be subject to a decision based solely on automated processing, including profiling - You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you.

    You can exercise the above rights at any time by:

  • As for direct marketing, please note that you can also object at any time by clicking the unsubscribe link which we provide in each communication sent to you
  • As for online targeted ads and the withdrawal of your consent please refer to our Cookie section of this Privacy Policy.  
  • Your rights in relation to your personal data might be limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process your personal data which you have asked us to delete.

    You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Data Protection Supervisory Authority.

    7. Contact details of the data controller

    The contact details of the Data Controller of the data processing described hereinabove are:

    Blue SAS, a company incorporated under French law with registered office at 75, boulevard Haussmann - 75008 Paris, France (Commercial Registration no. 490 641 354)

    8. Contact details of our data protection officer (DPO)

    Our Data Protection Officer (or 'DPO') is available at:

    [email protected]

    75, boulevard Haussmann - 75008 Paris, France

    9. Information about cookies

    For any information about Cookies please read the following Cookie Policy.

    10. Privacy notice for Facebook

    10.1. Facebook Custom Audiences - Facebook pixelWe use the remarketing function “Custom Audiences” of Facebook Inc. (1601 Willow Road, Menlo Park, California 94025) or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. This function allows us to show our Users and/or Customers of our website interest-based ads when they visit Facebook (“Facebook ads”), and to analyze such Facebook ads for statistical and market research purposes, which helps us optimize future advertising. This allows us to serve more relevant advertising.

    For this purpose we use the so-called Facebook pixel for our website.

    When a User or a Customer visits our website and takes an action (for example, buying something), the Facebook pixel is triggered and reports this action. This way, we will know when a customer took an action after seeing our Facebook ad. We will also be able to reach this customer again by using a Custom Audience. Therefore, this pixel allows user behavior to be tracked after they have been redirected to our Website by clicking on a Facebook ad. This way, we will know when a customer took an action after seeing our Facebook ad. We will also be able to reach this customer again by using a Custom Audience.

    Therefore, this enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy. Such data may allow Facebook and its partners to show ads on or off Facebook. A cookie may also be stored on your computer for these purposes.

    11. Update and old versions of this privacy policy

    We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our Website and update the “Last Updated” date at the top of this Privacy Policy.

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