Privacy Policy

Your privacy matters to us. This policy explains what data we collect, why we collect it, and how we handle it.

Last updated: January 23, 2025

FlyTorch is a multifunctional software product offering its users certain online travel related services and features as defined in its Terms of Use. For the purposes of these Privacy and Cookie Policies, FlyTorch shall be considered as a software product at FlyTorch.com as well as at any official FlyTorch third level domains or subdomains (hereinafter “FlyTorch”).

User privacy is important to us and we are doing whatever is required to protect it. In terms of Data Processing, we ensure your rights as Data Subjects and observe the regulations of California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act and other applicable legislation of other states along with regulations of relevant state authorities as well as other applicable laws and rules. In this Policy, we aim to openly explain how we will possess your data and what processing standards we follow.

The present Policy includes our Cookie Policy, which is an integral part of our overall policies. Please note that this Policy is closely related to the Terms of Use, where you can find more information about FlyTorch’ functionality as well as your rights and liabilities when accessing the service.

Pay close attention to this Policy. If you have any questions after reading this Policy or if you find any errors or inaccuracies, please contact us. Please describe your problem or question in detail so that we can quickly respond to it, help you, or correct the error and improve our services in the process.

We reserve the right to change this Policy if we make changes to our processing procedure or need to take newly-enacted Personal Data protection legislation into account. We’ll notify you in case of significant changes that may affect your interests, rights, and status. In spite of everything, we guarantee that the protection of your Personal Data is always legitimate and fair, and that your data is secure.

Key Terms
Data that we can collect and process on FlyTorch
Data Processing Conditions and Principles
Your rights
Your rights
Contact

1. Key Terms

For starters, let’s clarify some key terms that we will use in this Policy to eliminate the possibility of misinterpretation

Personal Data or Personal Information refers to any information relating to an identifiable person or household who can be directly or indirectly identified or reasonably linked by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute Personal Data, including an email address, identification number, device information, location data, or online identifiers, such as cookie files or similar technologies

Data Processing refers to any operation or set of operations performed on Personal Data or on sets of Personal Data, whether by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure, or destruction

“You”, “your”, or “Data Subject” “Consumer” refers to a visitor of the FlyTorch web-resource, authorized user, a subscriber to any service we offer through our web-resources, or prospective/existing clients communicating with us via email or other means.

Data Controller refers to a person who (either alone or jointly with other persons) determines the purposes for which, and the manner in which, any Personal Data is, or is to be, processed. For the purposes of this Policy, the Data Controller is Giant Travel Unicorn Two Limited, a Hong Kong corporation (BRN No. 76803739) with a legal seat at Suite 31/F, Tower Two, Times Square, 1 Matheson Street, Causeway Bay, Hong Kong, doing business as FlyTorch.

Data Processor, in relation to Personal Data, refers to any person (other than an employee of the Data Controller) that is considered as a service provider to Data Controller who processes data on behalf of the Data Controller for business purposes. We describe how we engage with Data Processors and other third parties that may process Personal Data on our behalf in Section 3 of this Policy.

Profiling refers to any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to Data Subjects. Profiling is done to analyze or predict aspects concerning that specific Data Subject’s preferences and interests while using a particular one of our services.

Account refers to a section of FlyTorch that is available to you after authorization (signing up) and gives you access to certain services and features, which improve your user experience, that may not be accessed without authorization.

Assisted Booking refers to the feature of FlyTorch that allows you to start purchasing flight tickets through a special interface by concluding an agreement with the travel service provider without leaving the FlyTorch interface. The interface simplifies filling in necessary data for the booking (surname, name, passport data, contact data), which you uploaded to FlyTorch earlier or when you used this feature for the first time.

We can use other terms and definitions as well, even if they are not explicitly specified in this section, as long as they are set out in the applicable legislation or in our Terms of Use.

2. Data that we can collect and process on FlyTorch

When you use FlyTorch and its features or when you contact us, we may collect and process any data and information that you provide to us voluntarily, that is collected automatically, or that we receive from other sources.

Voluntarily provided data

This includes any information you provide to us yourself, such as information provided when you fill out a search form, subscribe to our marketing and commercial communications, enter your account information, enter into contractual relationships with us related to the usage of some of our products (e.g., FlyTorch More subscription), send us a query or feedback, participate in discussion boards or other social media functions via FlyTorch and our marketing special project subdomains, complete promotions or surveys, or report a problem. We may also process data you provide to our partners, including airlines and OTAs, while using assisted booking or making a booking after redirection.

Voluntarily provided data may include the following:

Personal Information:

• Search data of available products on FlyTorch, including travel dates and destinations
• Respective authentication data, including, for example, social network parameters and email addresses
• Contact data entered by you in the input fields on the airline, hotel, or OTA website after redirection
• Other Personal Information contained in your queries and communications with us

Sensitive Information:

• Your personal details and respective data of people who will accompany you on a trip (this may include PNR, your passport or debit/credit card number, etc.) if you proceed to make a purchase with using Assisted Booking or that you directly provide us with in order to receive a support with a relevant issue from our support team;
• Particulars of your payment method needed for conducting payments upon a direct agreement concluded between you and the Data Controller (e.g., FlyTorch More subscription agreement);

Automatically processed information

This mostly consists of online identifiers or technical facts about your connection point. For example, device and connectivity information, such as IP address (Internet Protocol), unique device identifiers (such as the IMEI for phones, MAC address of the device's wireless network interface), mobile network information, your mobile operating system, the type of browser you use, as well as time zone and language settings. Other types of configuration data include browser type, version, language settings, browser plug-in types, and browser versions.

This data is automatically collected when you visit our websites and/or use our services/features. In some cases, this data can be created by our software or third-party programs, integrated into FlyTorch’ software.

The list of data categories that may be automatically collected by us includes the following information:

• IP-address and log information (such as error reports);
• Geolocation (meaning country or region in terms of redirection to the appropriate market domain);
• Mobile device information, including device type/model, locale, and OS information;
• Impersonalized booking data after redirection or use of Assisted Booking (meaning destination, dates, and prices);
• Cookies and similar tracking technologies, including local storage data, statistics and analytics on the use of the service and its different features, as well as interaction information (scrolling, clicks, timings, etc.)

You can find more information on cookies and similar technologies in our Cookie Policy.

Data received from third parties

This category includes different types of data, mostly online identifiers, which we receive from airlines, OTAs, GDS, as well as our technical, analytical, marketing, and other partners.

For example, we might insert advertising on our partner websites, social networks, or advertising networks that may categorize FlyTorch users with similar characteristics or interests into non-personally-identifiable data segments, which may then be offered to their own clients, visitors, and subscribers.

We might obtain and record information that an ad was requested or shown, how many times said ad was shown, the target geo of said ad (which will not include an IP address or specific personally-identifiable location information), and any user interactions with said ad or information about the page on which it appears. This information is used for statistical purposes, analysis, reporting, and troubleshooting. In most Data Processing situations, such information does not allow us to identify you as a Data Subject and will be processed with an appropriate level of protection and limitations, which the data source establishes.

The data that we don’t process

We do not process data on children, as FlyTorch is intended only for use by users over the age of 16 (or another age of maturity determined by applicable local laws allowing for the independent use of Internet services like FlyTorch). If you are under the specified age, you may only use FlyTorch with the involvement of your guardian or holder of parental responsibility. We do not knowingly collect or process Personal Information from children below the specified age without the consent of the child's holder of parental responsibility. In case of doubt, we will cease the processing of questionable data and delete it.

We do not collect and process special categories of Personal Data and genetic data without your direct consent, such as your name, age, email, passport, and payment method details (unless you subscribed to our marketing mailing, purchased FlyTorch More subscription or entered an Account and use Assisted Booking), phone number, home address, etc.

We do not process data that you have directly asked us to stop processing or opted out in any other way.

We also do not process any data acquired by third parties on other platforms that you click out to from our web-resources. For instance, by clicking on the ad banner, except for cases and particular data types directly mentioned in this Policy. Your Data Processing on third-party platforms is carried out according to the rules and processes set out by owners of those platforms.

Additional information on Data Processing

Please note that, when you proceed with purchasing flight tickets or other travel services after redirection from our web-resources to the provider carrying out the particular service, we do not acquire, store, transmit, or process any additional information except depersonalized information, such as prices, dates, destinations, and a transaction identifier. Whereas, in situations in which you make a payment on the OTA’s or airline’s web-resource using Assisted Booking, we may process all the information you fill in, including your name, passport data, how many people will accompany you, and their respective details, in order to perform our obligations and meet the stated purposes.

In providing Personal Data about other individuals (such as someone whose name you are using to enter an Account or subscribe to our marketing promotions), you represent that you have notified them of: (1) the grounds and purposes for which said information will be used (see below), (2) the recipients of their Personal Data, (3) and how they can access and correct this information. The consent that you give for a third person is considered by us to be the consent of said third person.

Selling and Sharing of Personal Data. We assure that we do not sell Personal Data to any third party. However, we may share your personal information to our partners for business and commercial purposes as it is described above and in section 3 of this Policy. Please, check the last section of this Policy and the Cookie Policy to get the information about your right for opt out of sharing of your personal information and the ways how you can exercise this and other rights regarding the subject matter.

Email marketing and communications. We believe that FlyTorch users would like to get more information concerning travel that is useful to improving their possible travel experience as well as information about the best deals on flight tickets, other travel products, and more (commercial information). In addition, users would like this information to meet their own needs and interests. Upon authorization in the Account or when using particular functions of the service, we offer you the chance to subscribe to our marketing newsletter to receive such news and third-party ads. You can unsubscribe from direct marketing communications by email at any time by using the opt-out form in one of the received emails or by contacting our support team.

Profiling. It’s important for us to understand the FlyTorch audience, including their needs and preferences, in order to make the service better and more convenient both generally and for each particular user. To achieve these goals, we can create profiles of our users based on the data collected in their interactions with FlyTorch in order to provide our service in the best possible way or provide personalized ads and marketing communications if we’ve received your consent. In any case, we never use collected data to make automated decisions that significantly affect your interests or rights as a Data Subject.

Just to make sure, we never show our users different prices on the analogous services they may find using our metasearch engine and we never prohibit or block the use of a particular feature of FlyTorch solely based on your online profile.

3. Data Processing Conditions and Principles

Confidentiality and security

We believe that the confidentiality and security of our users’ data is key to maintaining trusting long-term relationships with them. We are committed to protecting the Personal Data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use, or disclosure.

At FlyTorch, we use the services of Data Processors, whose products and solutions are required for hosting our web-resources and products, storage and collection of data, implementing our features, analyzing and testing particular resources, Profiling, email marketing, and supporting interactions with you. Providers of such services are carefully selected based on FlyTorch’ specifics and ensure the safety of data at the appropriate level, according to the present Policy. In some cases, such providers help us collect cookies and similar technologies. You can learn more about them in the (Cookie Policy).

Data retention

We retain your Personal Information for as long as needed on the grounds of processing purposes. Terms may also differ for particular categories of Personal Information.

We also reserve the right to store various types of information (without any time limit) to use for analyzing our service performance, improving its features, providing services to you, and protecting the interests of FlyTorch.

Meanwhile, we give you the opportunity to control and influence the time we store and process your data, as specified in the “Your Rights” section of the Policy.

Transferring Personal Data to Third Parties

We share Personal Information about you with third parties or non-affiliated companies until you notify us about your decision to opt out of sharing your Personal Information, except of the processing that takes place in order to provide services you've requested, or under the following circumstances:

• We provide information to trusted third parties, who provide us with services and work on our behalf under confidentiality agreements. These companies may store, maintain, or process your data. These companies do not have any independent right to process this information.
• We may disclose your information to third parties when we reasonably believe we are obligated to do so by law and/or in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.
• In the event we are acquired by or merge with a third party or undergo another change of control, we reserve the right to transfer information, including any personally identifiable information, to a successor entity.

We may disclose or otherwise allow others to access your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant, or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention, and national security.

4. Your rights

You have the following rights concerning the collection and processing of Personal Data:

The right to be informed. In this Policy, we provide you with detailed information related to the processing of your Personal Data.

The right to know what personal information is being collected and right to access personal information. You can request us to disclose an exact description of categories and sources of personal data we collect and what are the purposes of collection and sharing your information, who are the third parties we share your data with and the list of specific pieces of personal information we have collected about you.

The right to rectify your Personal Data if it is inaccurate, incomplete, or outdated.

The right to erasure (deletion or removal) of your Personal Data. The right to restrict (block) processing. When processing is restricted, we will continue to store your Personal Data, but not process it any further.

Rights related to automated decision-making, including Profiling. We do not make any decisions that might produce a legal effect on you based on automated processing without legal grounds. However, you may opt out of automatic processing of your data unless this data is not processed by us for business purposes (i.e. marketing and functional cookie processing).

The right of no retaliation following opt out or exercise of other rights. You have the right to exercise all of the abovementioned rights for free and without any following retaliation or discrimination against you. We respect your privacy rights and do not put any charges or deny any services to you in case you prefer to keep your personal information private and decide to exercise any of the said rights. However, some of FlyTorch functionality/products are technically based on processing of your data and we may not be able to perform the respective services without certain data about you.

You can exercise all of your above rights (if implied) by contacting us or using the available opt-out or «manage your privacy» functionality within the service.

5. Contact