SELL AND AUTOMATE SUPPORT WITH AN AI ASSISTANT

Powered by machine learning and artificial intelligence (AI), the Eddy AI Assistant is a fully customizable chatbot widget designed for websites, mobile apps, and social media messaging applications. It allows users to instantly search for the best travel offers from the world’s leading travel companies such as Booking.com, Kiwi.com, and GetYourGuide. The AI Assistant is available for any organization for free to increase conversions, generate more revenue, and reduce support. Get started for free at eddyai.com or contact us to discuss enterprise projects.

Privacy Policy

We understand the importance of protection of your personal data, therefore we collect and process only your data that is connected to our services. We process your personal data lawfully, transparently, and fairly, for the pre-determined purposes and only to the extent necessary to achieve those purposes. When we process your personal data, we make every effort to ensure that they are accurate, secure, confidential, properly stored and protected.

When processing your personal data, we comply with the requirements of the Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”).

1. WHAT IS THIS DOCUMENT?

1.1. This Privacy Policy (the “Privacy Policy”) informs you of our policies regarding the collection, use and disclosure of data when you use our website www.eddyai.com or www.eddytravels.com, our AI travel assistant chatbot integrated in our website and in our WhatsApp, Messenger, Telegram, Slack, Viber, Line, and WeChat instant messaging applications; also this Privacy Policy applies to our Facebook (https://www.facebook.com/eddytravels/), Instagram (https://www.instagram.com/eddy_travels/), Twitter (https://twitter.com/eddytravels), and LinkedIn accounts (https://www.linkedin.com/company/eddytravels/) (jointly – the “Websites” and each separately – the “Website”) and the choices you have associated with that data. The Privacy Policy applies to every person who visits the Websites, as well as to any actions you may take on the Websites.

1.2. Section 6 of this Privacy Policy explains what data we process and how we do it when you use our AI travel assistant chatbot integrated in the websites or mobile applications of our partners (but not the Websites, as defined above).

1.3. Please read this Privacy Policy carefully to find out how we process your personal data, where we get them from and what your rights as a data subject are.

1.4. We consider that if you are using any one of the Websites, you have read and agree with this Privacy Policy and the purpose, manner, and procedures for processing your personal data set out therein. If you do not agree with the Privacy Policy, you are not entitled to use the Websites.

1.5. The term “personal data” as used in this Privacy Policy means any information which could be used to identify you directly or indirectly.

2. WHO ARE WE?

2.1. The Websites are managed and administered by UAB “Eddy Travels”, company code 305252556, registered at Palangos g. 4, Vilnius, 01402, Lithuania. The person responsible for personal data protection: Edmundas Balčikonis, contact telephone number: +370 637 20635, email address: info (at) eddytravels (dot) com

2.2. In accordance with the legal provisions, we are a controller of your personal data.

3. WHAT PRINCIPLES DO WE COMPLY WITH WHILE PROCESSING YOUR PERSONAL DATA?

3.1. While processing your personal data we: 

a) will comply with the requirements of the applicable legislation, including GDPR;

b) will process your personal data lawfully, fairly and in a transparent manner;

c) will collect your personal data for specified, explicit and legitimate purposes and will not further process them in a manner that is incompatible with those purposes, except to the extent permitted by law

d) will take all reasonable steps to ensure that personal data which is inaccurate or incomplete in regard to the purposes for which it is processed, are rectified, supplemented, suspended or destroyed without delay;

e) will keep it in a form which permits identification of you for no longer than is necessary for the purposes for which the personal data are processed;

f) will not disclose your personal data to third parties except as provided in this Privacy Policy or applicable law;

g) will ensure that your personal data are processed in a manner that ensures appropriate security of it, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1. We process your personal data obtained in the following ways:

a) when you provide personal data to us. You provide us with your personal data and other information by using the Websites, the chatbot integrated in it, by writing to us or by communicating with our customer service team by telephone or e-mail, by submitting your complaints and/or inquiries, etc.;

b) when you use the Websites. When you are using the Websites, certain information (such as the type of web browser and/or device used, the operating system you use, the IP address, the number of visits on the Websites, the pages of the Websites viewed, etc.) is collected automatically.

4.2. We may combine personal data we receive from you when you use the Websites with data collected by us from other available sources (for example, we may combine personal data you provide with data obtained through the use of cookies on the Website). 

5. WHAT PERSONAL DATA WE PROCESS AND FOR WHAT PURPOSES?

5.1. We process your personal data for the following purposes:

a) To provide the service. You provide us with your personal data when you use the Websites. Personal data that are processed for this purpose:

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b) To assure quality and communication. You provide us your personal data by writing to us or by contacting us by phone, submitting your complaints and inquiries about the Websites or our services. Personal data that are processed for this purpose.

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c) For direct marketing purposes. With your consent and in order to provide you with newsletters, offers and information about the services and/or goods of us and our partners, or other information, we process your personal data in order to improve our services.  Personal data that are processed for this purpose:

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Read more about the processing of personal data for direct marketing purposes in Chapter 7 of this Privacy Policy.

d) To ensure the functionality of the Websites and to improve them, to offer you better services that are tailored to you. We use your personal data, including personal data and cookies, which we receive when you use the Websites in order to improve and develop the Websites and to offer us better and more personalised services.

For this purpose, we use personal data obtained from you, created for you using the Websites and/or received from other persons.

You can read more about how we use cookies and similar technologies in Chapter 8 of this Privacy Policy.

e) To publish and make available your information. When you send, submit, upload or post any content (e.g. photos, videos, blog posts) (the “content”) to the Website, we will process the personal data you include in the content to publish the content and make it available. Personal data that are processed for this purpose:

Also, by submitting the content you warrant that you have the right (i) to send us the personal data contained in the content and (ii) to give a consent to use the personal data contained in the content as defined in this Section 5.1(e).

f) For other purposes provided for in our internal documents, when your personal data is required to be processed by us by law or there is a legitimate interest.

5.2. We do not collect or process your specific categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as health data or data about your sexual life and sexual orientation. If you provide this personal data to us using the Websites or in any other way (in writing, by e-mail, telephone), this data will be deemed to have been provided with your consent. Accordingly, we will process this personal data of yours in conjunction with the other data you provide in Section 5.1 of the Privacy Policy if those personal data cannot be separated or it would require a disproportionate effort.

6. HOW DO WE PROCESS YOUR DATA WHEN YOU USE OUR CHATBOT ON OTHER WEBSITES OR MOBILE APPLICATIONS?

6.1. We enter into agreements with selected partners to allow them to use our AI travel assistant chatbot on their websites or mobile applications (other than the Websites, as defined above). In such case, any information you enter into chat and submit via the chatbot on the partner’s website will be transferred to us and further to third-party service providers (e.g. travel service providers). However, we do not collect, process, store and transmit to third parties any information which might identify you, and therefore we do not process your personal data.

6.2. You should not input any personal or confidential information into the chat during the conversation with the chatbot. Your conversation may be stored for a period of 30 days and may be reviewed by Eddy Travels for the purposes of improving the chatbot service.

7. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING?

7.1. Yes, we may use your personal data for direct marketing purposes to provide you with offers and information about the goods and/or services of us and our partners that we believe may be of interest to you. However, we will only use your personal data for this purpose with your additional consent.

7.2. For this purpose, we process your personal data specified in Section 5.1 (c) of the Privacy Policy.

7.3. By granting the right to process your personal data for the purpose of direct marketing, you also allow us to contact you for this purpose by appropriate means of communication (e.g. e-mail, telephone, short message service (SMS) or other means of communication (e.g. Skype, Viber, etc.).

7.4. We may combine available information about you with information held by third parties.

7.5. If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyze and improve the effectiveness of the Websites, advertising and market research, and for other marketing and sales purposes of the company. 

7.6. Even if you have given your consent for the processing of your personal data for direct marketing purposes, you can easily revoke this consent at any time for all or part of the processing of personal data. To do this, you can:

a) change the settings on the Website to indicate that you no longer want your personal data to be used for direct marketing, or

b) notify the waiver in the manner indicated in the newsletters and/or offers received by e-mail (for example, in newsletters and/or offers by clicking on the link “unsubscribe from newsletters, offers”, etc.), or

c) send us a request by email info [at] eddytravels.com. The request must clearly state your email which is used for receiving a newsletter and/or offers.

7.7. If you withdraw your consent, we will make every effort to stop processing your personal data for direct marketing purposes as soon as possible.

7.8. Withdrawal of consent does not automatically oblige us to destroy your personal data or provide you with information about the personal data we process, so you shall make such a request separately in order for us to perform these steps as well.

8. HOW DO WE USE COOKIES?

8.1. .We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device’s hard drive and allow to identify you during other visits to the Websites, save your browsing history, options, customize content, speed up searches on the Websites, create a convenient and friendly Websites environment, make it more efficient and reliable. Cookies are common web browsing practices that make it easier to use the website.

8.2. Using cookies we may collect the following information: IP address, type of web browser used, number of visits to the Websites, pages viewed on the Websites, time spent on the Websites, demographic data and, if you have accessed the Websites from a third party website, a link to the page URL, etc.

8.3. We use the information we receive from cookies for the following purposes: 

a) to ensure the functionality of the Websites (e.g. so that you can use the personalization of the Website);

b) so that we can improve and develop the Websites to better meet your needs;

c) to develop our services and analyze the use of the Website;

d) after you specifically consent – for marketing purposes.

8.4. We may combine information obtained through the use of cookies with information obtained about you by other means (e.g., information about the use of the Websites may be combined with personal data provided by you).

8.5. The following cookies may be used on the Websites:

a) Necessary cookies – necessary for the provision of the services. These cookies ensure that information and services are provided securely and optimally.

b) Performance cookies – to monitor visitor behavior and help us improve information and services.

c) Functionality cookies – help to improve your experience by providing more personalized services. These cookies “remember” choices such as language, selected login method, and so on.

d) Targeting cookies – means cookies used to display offers or other information that may be of interest to you.

8.6. All information about the cookies used on the Websites, their purpose, validity and data used is provided in the table below:

8.7. To use targeting cookies we need your separate and specific consent, which you can give to us by clicking on the “Agree” button in the link (bar) on the Website. 

8.8. You may revoke your consent to use targeting cookies at any time. You can do this by:

a) visiting https://www.eddyai.com/privacy-policy and changing the cookies settings there, or by

b) changing your web browser settings so that it does not accept cookies. How you do this depends on your operating system and web browser. You can find detailed information about cookies and their use at http://AllAboutCookies.org or http://google.com/privacy_ads.html.

8.9. In some cases, especially disabling, disagreeing with or deleting technical and functional cookies may slow down the speed of Internet browsing, restrict the operation of certain functions of the Websites, block access to the Websites.

9. TO WHOM DO WE PROVIDE YOUR PERSONAL DATA?

9.1. We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without a legitimate basis, as well as used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy or applicable law. However, we reserve the right to provide information about you if we were required to do so by law or if required to do so by law enforcement authorities or prosecuting authorities.

9.2. We may transfer your personal data to companies that help us operate. From such partners, we require that your data be processed only in accordance with the instructions given by us and the applicable data protection legislation. We enter into agreements with these partners that oblige the parties to adhere strictly to the personal data protection requirements.

9.3. We may disclose the personal data we collect about you to the following third parties:

a) third party service providers (e.g. travel service providers, third parties whose goods and/or services you choose when using the Websites, third party service providers including those who provide us the services for sending of newsletters or other marketing activities and technical service providers in the performance of our agreements with these service providers);

b) third party service providers whose services we normally use for data storage, telecommunications, and website hosting purposes. In some cases, your data may be transferred to the third countries where other personal data protection regulations may apply. We have taken appropriate safeguards to ensure that your personal data remains protected, and we require that our third-party service providers and partners also have appropriate safeguards in place.

9.4. The use of your personal data by the above-mentioned service providers is limited – they may not use this data for purposes other than providing services to us.

9.5. The list of persons and their categories to whom we transfer your personal data (non-exhaustive) is provided in Section 5.1 of this Privacy Policy separately for each purpose of the use of personal data.

9.6. When you choose an offer from our partner – a travel service provider – offered to you on the Websites, you will be taken to a website operated by our partner, where their privacy policy applies. Our partners’ privacy policies can be found here:

• Booking.com: https://www.booking.com/content/privacy.html

• Skyscanner.net: https://www.skyscanner.net/media/privacy-policy

• Kiwi.com: https://www.kiwi.com/en/pages/content/privacy

• Emirates.com: https://www.emirates.com/lt/english/information/privacy-policy

• Priceline.com: https://www.priceline.com/static-pages/privacy-policy.html

• GetYourGuide.com: https://www.getyourguide.com/privacy_policy

• Klook.com: https://www.klook.com/policy/

• Rentalcars.com: https://www.rentalcars.com/PrivacyPolicy.do

• Kayak.com: https://www.kayak.com/privacy

10. HOW LONG DO WE STORE YOUR PERSONAL DATA?

10.1. We store your personal data for no longer than required by the purposes of the processing or as required by law if it provides a longer storage period.

10.2. We strive not to protect outdated personal data, therefore after the update only up-to-date is stored. Historical information is stored if it is required by law or for our activities.

10.3. Section 5.1 of the Privacy Policy specifies the terms of storage of your personal data separately for each purpose of use of personal data.

11. HOW DO WE STORE YOUR PERSONAL DATA?

11.1. The personal data we collect from you will be located within the European Union (EU), but may be transferred or stored outside the EU. They may also be handled by our own or our suppliers’ staff working outside the EU. When transferring your personal data outside the EU, we will take all necessary steps to ensure that your personal data is processed securely and in accordance with this Privacy Policy.

11.2. Unfortunately, the transmission of information over the Internet is not completely secure. Although we make every effort to protect your personal data, we cannot guarantee the security of your data when you transfer data to the Websites – you assume the risks associated with the transfer of data to the Websites. Once we receive your data, we will apply strict procedures and security measures to protect your personal data from unauthorized access.

11.3. Should unlikely circumstances arise and we become aware of a personal data breach that could seriously jeopardize your rights or freedoms, we will notify you immediately as soon as we become aware of it and determine what information has been accessed. 

12. EXTERNAL WEBSITES

12.1. The Websites may contain links to external websites – websites of our business partners or websites that promote our services. By following such links to any of the Websites, please note that these Websites and the services accessed through them have their own separate privacy policies and we do not accept any responsibility or liability for these policies or for personal data collected on these Sites or services, such as contact or location details. Please review these policies before submitting personal information on these sites or using any services.

13. WHAT RIGHTS DO YOU HAVE?

13.1. When processing personal data, we ensure your rights in accordance with the GDPR. As a personal data subject, you have the following rights: 

a) to know (be informed) about the processing of your personal data;

b) to access your personal data that we process;

c) to request the correction or supplementation of incorrect, inaccurate, incomplete personal data;

d) to require the destruction of your personal data when they are no longer needed for the purposes for which they were collected;

e) to demand the destruction of personal data if they are processed unlawfully or if you withdraw your consent to the processing of personal data or do not give such consent, which is necessary;

f) to object to the processing of personal data or to withdraw prior consent;

g) to demand the suspension (other than storage) of your personal data processing in the event of a dispute or verification of the lawfulness of the processing, the accuracy of the data, as well as in cases when we no longer need your personal data but you do not want us to destroy them;

h) to require the submission, if technically possible, of your personal data collected with your consent or for the purposes of the performance of the agreement in an easy-to-read format or request their transfer to another controller.

13.2. We will endeavor to guarantee the exercise of your rights as a personal data subject and to create all conditions for the effective exercise of these rights, but we reserve the right not to comply with your requirements when it is necessary to ensure:

a) the performance of the legal obligations imposed on us;

b) national security or defense;

c) public policy, the prevention, investigation, detection, or prosecution of criminal offenses;

d) important economic or financial interests of the State;

e) the prevention, investigation, and detection of breaches of official or professional ethics;

f) Protecting the rights and freedoms of you or others. 

13.3. You can submit requests related to the exercise of your rights to us in person, by post, or by electronic means. Upon receipt of your request, we may ask you to provide proof of identity, as well as any additional information we require regarding your request.

13.4. Upon receipt of your request, we will respond to you no later than within 30 calendar days from the receipt of your request and the date of submission of all documents required for the response.

13.5. If we deem it necessary, we will suspend the processing of your data, other than storage, until your request has been resolved. If you lawfully withdraw your consent, we will immediately, but no later than in 30 calendar days, terminate the processing of your personal data, except as provided in Section 13.2 of this Privacy Policy and the law, i.e. when we are required to continue to process your data due to our obligations, court decisions or binding instructions given to us by the authorities.

13.6. If we refuse to comply with your request, we will clearly state the grounds for such refusal.

13.7. If you do not agree with our actions or the response to your request, you may appeal against our actions and decisions to the competent public authority.

14. TO WHOM CAN YOU MAKE A COMPLAINT?

14.1. If you wish to make a complaint about our processing of your personal data, please provide it in writing, providing as much information as possible, using the contact details indicated at the end of this Privacy Policy. We will immediately try to resolve any issues.

14.2. If you think that your rights have been violated, you can file a complaint with our supervisory authority – the State Data Protection Inspectorate, more information, and contact details can be found on the Inspectorate’s website (https://vdai.lrv.lt/en/). Although, above all, we seek to resolve all disputes with you promptly and amicably. 

15. HOW WILL WE CHANGE THIS PRIVACY POLICY?

15.1. All changes to our Privacy Policy will be posted on the Websites. We will notify you of them if necessary. The new terms of Privacy Policy may also be posted on the Websites and you may need to read and agree with them in order to continue using the Websites and/or our services.

14.2. If you think that your rights have been violated, you can file a complaint with our supervisory authority – the State Data Protection Inspectorate, more information, and contact details can be found on the Inspectorate’s website (https://vdai.lrv.lt/en/). Although, above all, we seek to resolve all disputes with you promptly and amicably.

16. HOW TO CONTACT US?

16.1. Please send all documents related to this Privacy Policy or contact us at the following contacts:

       • by post – UAB “Eddy Travels”, address: Palangos g. 4, LT-01402 Vilnius, Lithuania;

       • by e-mail – info@eddytravels.com.

This Privacy Policy has been published on July 8, 2021

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