Privacy &
Data Protection Policy

DEFINITIONS OF THE TERMS USED IN THIS PRIVACY AND DATA PROTECTION POLICY

The terms hereunder shall have the following meaning:

  • "Personal Data" means any information related to an identified or identifiable natural person.The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons .
  • "Service" means the access the SaaS-mode delivered app developed by Fairjungle, that allows users to book transportation tickets (including train and plane tickets)or hotels.
  • "Editor" or "We" or "Fairjungle" means Fairjungle, a French limited liability company (societé par actions simplifiée), whose headquarters are located 5, avenue du général de Gaulle, 94160 Saint-Mandé – France, registered with the Créteil Trade and Companies Register under number 829 964 196.
  • "Sensitive Data" means Personal Data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
  • "User" or "You" means the natural person placed under the supervision (employee, representative etc.) of Fairjungle's client and having rights to use the Service.

ARTICLE 1 - INTRODUCTION AND POLICY'S PURPOSE

The purpose of the present policy is to inform the User about Fairjungle's obligations regarding privacy and protection of the Personal Data we collect as you are using the Service.

Each User shall carefully read the present document to be aware of the reasons why we use your Personal Data and how we use it.

By using the Service, you agree to provide us accurate and verifiable information about you. Supplying inaccurate or false information shall constitute a breach of the present policy.

Please be advised that the present document may be updated at any time in order, for example, to comply with a regulatory, legal or technological change. The date of the modification shall appear clearly on this document.

Any amendment shall be binding once it is published online. We invite you to check this document regularly to be aware of any amendment.

This document also contains a description of your rights regarding Personal Data Protection and Privacy.

ARTICLE 2 – PERSONAL DATA COLLECTED THROUGH THE SERVICE

As part of the Service, we collect the following data: language navigator, IP address, email address, first name, last name, date of birth, gender, nationality, ID number, date of expiry and place of issuance, phone number, number of airline or hotel loyalty card, meal preferences.

The Personal Data collected and processed through the Service is only the Personal Data you provide us voluntarily by filling in the forms available on the Service.

In accordance with GDPR, we collect only the data that is strictly necessary for the purpose mentioned in Article 4.

For some transactions, you might be required to provide your Personal Data to third party companies to use their services, in particular, to make payments. We shall not have access to the said Personal Data. The way this data is collected and processed is governed by the applicable terms and conditions of the concerned companies. We invite you to read carefully their terms and conditions before supplying Personal Data.

Your IP address (the numerical label assigned to each device connected to a computer network that uses the Internet Protocol for communication) is automatically collected. You are informed that the Service uses cookies. You may deactivate cookies by modifying the parameters of your navigator as explained later in this policy.

From a general standpoint, you may visit Fairjungle's Service without providing any Personal Data about you. In all cases, you shall never assume any obligation to communicate us Personal Data. However, should you refuse to provide us some Personal Data, you acknowledge that you might not benefit from certain information or services.

We also collect, use, and share aggregate data like statistics or demographic data. Aggregate data may be obtained using your Personal Data, but they shall not be considered as Personal Data under GDPR since you cannot be identified or identifiable just by using this data. For example, we may aggregate connection data to calculate the percentage of users that access a specific functionality of the Service.

To provide you more valuable contents and services, Fairjungle's Service uses Google's analysis service named Google Analytics. Google Analytics does not monitor your online browsing habits on third party websites. The information to which Google Analytics may access does not contain any Personal Data about you.

Users' information details shall be saved pursuant to GDPR.

Personal Data collection about Users by the Editor does not require any specific declaration to the French data protection authority (CNIL).

We only collect the following Sensitive Data: meal preferences (diabetic meal, gluten intolerant meal, hindu meal, kosher meal or halal meal).

Such Sensitive Date shall be collected with your prior consent only and shall be used for the sole purpose of providing you with a meal adapted to your dietary restrictions, food allergies and/or religious restrictions.

ARTICLE 3 – IDENTITY OF THE DATA CONTROLLER

The data controller is Fairjungle, a French limited liability company (societé par actions simplifiée), whose headquarters are located 5, avenue du général de Gaulle, 94160 Saint-Mandé – France, registered with the Créteil Trade and Companies Register under number 829 964 196.

ARTICLE 4 – PURPOSE OF PERSONAL DATA PROCESSING

The Personal Data identified as mandatory in the forms available via the Service is required to access the corresponding functionalities of the Service.

Personal Data about Users will be collected:

  • To provide the services to which your employer subscribed: booking hotels and transportation tickets; or
  • To provide you with information on the services to which your employer subscribed; or
  • To provide you information to help us improve our Service, products, and functionalities (especially by using cookies); or
  • To be able to contact you regarding the reservations you made.

ARTICLE 5 – RECIPIENT / PERSONAL DATA PROCESSING

The Personal Data we collect is processed to provide the Service.

You may receive emails from our Service, especially the newsletters you chose to receive. You may request to be unsubscribed from our email lists by contacting us at contact@fairjungle.fr or by clicking the link that appears in all the emails you will receive from us and confirming that you do not wish to receive advertising emails from us anymore.

Your Personal Data shall never be communicated to any third party, except to our subcontractors and suppliers as mentioned in Article 9. Neither Fairjungle nor its subcontractors shall be entitled to sell your Personal Data.

Your Personal Data may only be shared with these companies and for the purpose mentioned in the present policy.

We require our subcontractors to ensure the safety of your Personal Data and to process them in compliance with the applicable regulation.

ARTICLE 6 – LEGAL GROUNDS GOVERNING THE PERSONAL DATA PROCESSING

Under GDPR, Fairjungle shall only process Personal Data in the following cases :

  • with your consent;
  • whenever there is a contractual obligation to do so (a contract between you and Fairjungle or between your employer and Fairjungle);
  • to comply with a legal obligation (following EU or local regulation).

ARTICLE 7 – PERSONAL DATA SECURITY

You are informed that your Personal Data might be disclosed pursuant to a law, regulation or decision of a court of law or regulatory authority or if necessary for the Editor to preserve its rights and interests to the extent permitted by GDPR.

We have put in place safety measures to prevent your Personal Data from being lost, used, modified, disclosed, or tp prevent any unathorized access. The access to your Personal Data is subject to a documented safety procedure.

ARTICLE 8 – PERSONAL DATA RETENTION

Personal Data shall be stored on our hosting company's servers that host the Service in accordance with article 9 of the present policy. Personal Data is kept in a form which permits the identification of data subjects for no longer than what is necessary for the purposes for which the personal data are processed. In any case, your Personal Data shall not be kept more than 24 months.

Beyond 24 months, your Personal Data shall be anonymized, archived or deleted.

ARTICLE 9 –SUPPLIERS AND SUBCONTRACTORS

Your Personal Data will be communicated to our suppliers (airlines, railway companies, hotels, hotel bookings office) for the sole purpose of performing the Service.

Also, you are informed that Fairjungle resorts to subcontracting to host the Personal Data under the following conditions:

  • For the authentication and identification of Users, Fairjungle resorts to a sub-contractor located in the European Union and having all the required certifications (ISO27001, ISO27018, SOC 2 Type II)
  • Regarding the hosting of the Service's other data (source code, Users' data, Client's data …), Fairjungle resorts to a subcontractor hosting the data in Frankfurt, Germany and having all the required certification (ISO 27001, SOC 1 and SOC 2/SSAE 16/ISAE 3402).

Fairjungle shall make sure that its subcontractors comply with GDPR.

Fairjungle shall be responsible for including appropriate clauses in its contracts with subcontractors.

No Personal Data is transferred outside the European Union.

ARTICLE 10 – RIGHTS UNDER GDPR

You are informed that you have the following rights under GDPR:

  • The right to be informed: we assume the obligation to inform you about the way we use your Personal Data (as described in the present policy);
  • The right of access: it is your right to request to access your Personal Data and receive a copy of the Personal Data we keep about you. However, as a result of our privacy and safety obligations in the processing of Personal Data, your request will be processed subject that you prove your identity (by providing an electronic or hard copy of your valid ID);
  • The right to rectification: you have the right to request us to rectify the Personal Data we keep about you if such data is incomplete, false, inaccurate, or obsolete. The applicable regulation entitles you to request your Personal Data to be rectified, updated, blocked or erased.
  • The right to erasure, also known as "right to be forgotten": you are entitled to request us to delete the Personal Data we keep about you (except if there is a legal ground that compels us to keep it);
  • The right to restrict processing: you have the rights to request us from suspending any processing of your Personal Data;
  • The right to data portability: you have the right to request us to provide you with a copy of all the Personal Data we keep about you in a widely used format (for example a .csv file);
  • Rights in relation to automated decision making and profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You may exercise these rights in either of the following cases: there is a legitimate ground for you to exercise your rights or you exercise your rights to prevent us from using your Personal Data for commercial prospection or solicitation purposes.

Pursuant to Article 37 of GDPR, the User is informed that Fairjungle does not have the obligation to designate a Data Protection Officer.

Fairjungle's point of contact for data protection issues is Mr. Samir IDRIS. You may contact him to exercise your rights or for any question you may have on the way we collect and process your Personal Data. Mr. IDRIS may be reached via email at contact@fairjungle.com, or by mail at the following address: Fairjungle, 5, avenue du Général de Gaulle, 94160 Saint Mandé.

We will deal with your requests free of charge. However, we may charge you with a reasonable fee for requests that are manifestly unfounded, excessive or repetitive in character. In such a case, we are also entitled to refuse to process your requests.

We can request specific information to confirm your identity and guarantee your right to access your Personal Data (or to exercise any other right you may have). This is a safety measure whose purpose is to make sure that your Personal Data is not disclosed to an unauthorized recipient. We may also contact you to obtain more information about your request to provide you with an answer more quickly.

We make our best endeavors to reply to all the legitimate requests within one month. We might not be able to meet this deadline if your request is complicated or if you made several requests. In such a case, we will let you know that we will not be able to meet this deadline.

ARTICLE 11 – COMPLAINT TO THE DATA PROTECTION AUTHORITY

If you consider that Fairjungle does not comply with its data protection obligations, you are entitled to lodge a complaint with the French data protection authority: la Commission Nationale de Informatique et des Libertés (CNIL). You may send an electronic complaint at https://www.cnil.fr/fr/plaintes/internet.

ARTICLE 12 - COOKIES

When you use Fairjungle's Service for the first time, a banner warns you that browsing information is likely to be saved in alphanumeric files named cookies. Our cookies policy allows you to acquire a better understanding of the measures we put in place regarding navigation on our Service. This policy provides you with information about all the cookies present on our Service, their purpose and how to change settings regarding cookies.

A) GENERAL INFORMATION ABOUT COOKIES ON THE SERVICE

Fairjungle as the editor of the Service may store cookies on your device (laptop, tablet, smartphone etc.) to allow optimum and smooth navigation.

Cookies are small text files that allow us to recognize your computer, tablet or mobile to personalize the services we offer.

The information gathered using cookies do not enable us to identify you as a person. The information is used solely for our internal needs to improve the interactivity and functionalities of our Service and to offer you contents adapted to your interests. None of this information shall be communicated to any third party except when Fairjungle obtained your consent to do so or when disclosure is required by law, or when a court order or an administrative or judicial authority that needs to access this information.

To help you understand better the information contained in cookies, you will find a table identifying the different types of cookies used on Fairjungle's Service, their name, purpose and retention time at the following address (see end of this document).

B) COOKIES EXEMPTED FROM CONSENT

Under the CNIL's recommendations, certain types of cookies do not require your consent since they are strictly necessary for the proper functioning of the Service or are stored for the sole purpose of enabling or facilitating electronic communications. For example cookies that identify your browser, authentification cookies, session cookies, load-balancing cookies, cookies used to customize your interface. These cookies are subject to the present policy since they are stored and managed by Fairjungle.

C) COOKIES REQUIRING YOUR PRIOR CONSENT

Your consent is required for cookies stored by third parties and called "persistent" cookies since they remain in your device until you delete them or the cookies expire.

These cookies are used by third parties, and their storage is subject to the concerned third party privacy policy. This type of cookies includes audience measurement cookies, advertising cookies which Fairjngle does not use or social networks cookies which Fairjungle does not use either.

Audience measurement cookies are used to obtain statistics regarding the audience and use of different elements of the Service (like contents/pages you visited). This data is used to improve service user-friendliness.

D) COOKIES PREFERENCES

You may accept or refuse the storage of cookies at any time. Most navigators have a default configuration that allows cookies to be stored. Your navigator offers you the opportunity to change these parameters to reject all or part of the cookies depending on the issuer.

WARNING: we draw your attention to the fact that refusing cookies might impair your user experience, as well as your access to some functionalities of the Service. In such a case, Fairjungle shall not assume any liability for the consequences on navigation that result from your decision to refuse, block or delete cookies which are necessary for the proper functioning of the Service. These consequences shall not be considered as damage, and you shall not receive compensation for these consequences.

Your navigator also allows you to delete existing cookies on your device or to be informed as soon as new cookies are likely to be stored on your device.

Please find below the applicable procedure for each navigators to help you change the cookies parameters on your terminal.

E) SETTINGS OF YOUR INTERNET NAVIGATOR

Each Internet navigator has its own settings regarding cookies. To know how to change your preferences regarding cookies, please click on the links below depending on the navigator you are using:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr Internet Explorer : https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11 Mozilla Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies Opera : http://help.opera.com/Windows/10.20/fr/cookies.html Safari https://support.apple.com/kb/PH21411?viewlocale=fr_FR&locale=fr_FR

For more information on how to manage cookies: you may browse the CNIL's website at: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

For any question or request for additional information regarding cookies, please contact us.

F) LIST OF COOKIES USED

The detailed list of the cookies we used through the Service is available here.

Fairjungle - All rights reserved – 2020