Privacy Policy

We recognise the importance of your privacy and take your privacy very seriously. Please read this Privacy Policy carefully, which sets out how we collect, use, store and disclose your data, including how we use cookies.

As a global company, we operate in jurisdictions with varying data privacy laws. In particular, we comply with Regulation No. 2016/679, commonly known as the General Data Protection Regulation ("GDPR").

In this Privacy Policy, we, as the data controller, means Instacoins Ltd, a company registered in Malta with the registered business name Instacoins Ltd, a company registered under the laws of Malta, registration number C 86830, with its registered address at 86, Main Street, St. Julian's STJ 1015, Malta, having its current offices at Valley Towers Unit 11, Valley Road, B'Kara, Malta (henceforth "instacoins.travel").

1. Personal Information We Collect

We collect personal information about you in order to provide you with our services, including to facilitate your travel bookings and arrangements, which are accessible at instacoins.travel (the "Website").

In doing so, we may collect the following types of personal information:

• contact information, including your name, mailing or residential address, email address, telephone number and other contact details;
• passport and/or Identity (ID) information, including your passport/ID number, passport/ID expiration date, and date of birth;
• loyalty program details (such as frequent flyer details);
• information about your health (if disclosed);
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the Website, ad data, IP address and standard web log information;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• any additional information relating to you that you provide to us through your use of our Website, in person or through other websites or accounts from which you permit us to collect information;
• information you provide to us through customer surveys or feedback; or
• any other personal information that may be required in order to facilitate your dealings with us.

2. When We Collect Personal Information

We may collect personal information either directly from you, or from third parties, such as when another person makes a travel booking on your behalf (e.g. a family member or friend). We may collect this information when you, or a third party acting on your behalf:

• places an order on our Website;
• communicates with us through correspondence, chats, email, or when you share information with us from other social applications, services or Website; or
• otherwise interacts with our Website, services, content and advertising.

In addition, when you apply for a job or position with us, we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees.

3. How We Use Your Information

We may use the information we collect from you to provide you with our services and improve your experience with us, including to:

• Personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
• Improve our Website in order to better serve you;
• Allow us to better service you in responding to your customer service requests;
• Administer a contest, promotion, survey or other Website feature;
• Quickly process your transactions;
• Ask for ratings and reviews of services or products; and
• Follow up with you after correspondence (live chat or email inquiries).

4. Disclosure of Personal Information

We may disclose personal information for the purposes described in this Privacy Policy to:

• our related bodies corporate and travel service providers that you have booked with (such as airlines, accommodation providers, tour operators and other travel service providers);
• our employees and agents;
• third party suppliers and service providers (including providers for the operation of our Website and/or our business or in connection with providing our products and services to you);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our services;
• anyone to whom our assets or businesses (or any part of them) are transferred, or will potentially be transferred to; or
• other entities, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

5. Cross-border Disclosure of Personal Information

We may disclose your personal information to international third parties, including countries outside the European Economic Area (EEA) (collectively "Cross-border Disclosure"), generally to arrange travel with a travel service provider on your behalf. Whenever we perform Cross-border Disclosures, we will do so in accordance with applicable law and ensure that a similar degree of protection is afforded to it by implementing appropriate safeguards.

Cross-border Disclosures outside the EEA will only be made:

• to a country recognised by the European Commission as providing an adequate level of protection; or
• to a country which does not offer adequate protection, but whose transfer has been governed by the standard contractual clauses of the European Commission, or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

6. How We Protect Your Personal Information

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. Your personal information is generally stored in accordance with the applicable law and for the duration of the relevant statutory limitation period.

We implement a variety of physical, administrative, and technical measures to maintain the safety of your personal information. While we take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, we cannot guarantee the security of your personal information due to inherent risks associated with the transmission of personal information via the internet and where there has been a hardware or software failure, or where other circumstances arise outside of our control.

7. Cookies

We use cookies and similar technologies to help provide, protect, and improve our services. For full details on how we use cookies, the types of cookies we use, third-party partners, and how to manage your cookie preferences, please refer to our Cookie Policy.

8. CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions;
• Process orders and to send information and updates pertaining to orders;
• Send you additional information related to your product and/or service; and
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

In accordance with the CAN-SPAM Act, we agree to do the following:

• Not use false or misleading subjects or email addresses;
• Identify the message as an advertisement in some reasonable way;
• Include the physical address of our business or site headquarters;
• Monitor third-party email marketing services for compliance, if one is used;
• Allow users to unsubscribe by using the link at the bottom of each email; and
• Honour opt-out/unsubscribe requests quickly.

9. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. If we believe that any changes to this Privacy Policy are material, we will update the Privacy Policy on the Website and notify you by sending you an email about the changes and/or placing a notice on the Website informing you that changes have been made to the Privacy Policy.

10. Your Personal Information Rights

Under applicable law, including the GDPR, you have certain rights in relation to your personal information. These include:

• Requesting access to the personal information that you have provided to us through your use of our services, including the provision of a copy of that personal information;
• Requesting that we add, update, or correct any personal information associated with your account;
• Requesting the deletion of your personal information;
• Restricting the processing of your personal information;
• Objecting to the processing of your personal information; and
• Requesting that we transmit your personal information to a third party.

Personal information provided by you must not be false or misleading. We assume that the information you provide us is accurate and will be updated when the relevant personal information changes. You may choose not to provide certain information to us. Please be aware that, in doing so, your ability to use some parts of our services may be hindered. If you choose to deactivate your account, some of the information associated with your account may be retained for internal purposes, including to backup data, to assist in investigations, and to comply with applicable law.

We reserve the right to deny you access for any reason permitted under applicable law. If we deny access or amendment, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by local data protection laws, will note your request and the denial of the same in our records.

We will respond to any privacy-related requests within a reasonable time. Please note that we may need to verify your identity when you request to access your personal information.

If you would like to make a privacy-related request, please Contact Us.