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Privacy Policy

1. We value the protection of personal data

 1.1       Pax Adviser SRL (Pax Adviser) gives great importance to the adequate protection of the security and confidentiality of all personal information of customers, business partners or their representatives, as well as of the employees.

1.2       Therefore, Pax Adviser is fully committed to comply with the requirements of applicable data protection legislation, Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“), respectively, and the purpose of this Policy is to highlight our general practices regarding the processing of your personal information in accordance with the law, for the purposes mentioned below, including the types of information we collect, how we use and protect it, and how you can correct this process.

1.3 Pax Adviser processes personal data as a Data Controller, according to the information presented in Section 2 below.

1.4 In principle, the information that Pax Adviser processes about you has been provided directly by you; however, some information may come from other external sources such as our partners.


2. The types of personal data processed and the purposes and grounds on which we process/collect your personal data

Pax Adviser, as a Data Controller, can process/collect the following personal data:

2.1.      Personal data of clients and/or their minor children, for the following purposes:

(i)        for the processing of claims for reimbursement of the cost of the ticket(s), damages and/or compensation from airlines, travel agents, insurance companies;

(ii)       for the financial-accounting purpose in order to develop the contractual relations;

(iii)      for the legal purpose – in order to contract legal services for carrying out the actions of reimbursement, obtaining compensations and/or necessary compensations before the courts and in order to comply with our legal obligations.

2.2.     The personal data of the business partners and of their representatives/employees, in order to keep the contact details of the contractual partners of Pax Adviser.


3. How we can process/collect your personal data

Pax Adviser collects the personal data of the data subjects as of the moment of starting the contractual relations.


4. The types of personal data that we may possibly collect/process

4.1      For the purposes mentioned above at section 2.1., Pax Adviser collects and/or processes the following categories of data regarding customers, and/or their minor children: Name and surname, Name and surname of parents (in the case of minor children), Date of birth, Address, Identity card/Passport information, Phone number, Email address, Nationality, Billing details, Bank details, Flight ticket number, Booking number, Ticket price, Booking code, Flight number, Date and place of departure/return, Flight destination, Hotel name, Insurance number and type, Insurer details, IP address, Cookie information, Site search history.

4.2      For the purposes mentioned above at section 2.2., Pax Adviser collects and/or processes the following categories of data: Name and Surname, Telephone number, Function, Fax number, Email address, Address, Signature.

4.3.     Usually, your personal data will be provided directly by you or by the representatives of the legal entity with which you have working/collaboration relations. If you provide personal data of your employees/representatives to Pax Adviser, make sure you inform them appropriately about this Policy.


5. General principles regarding the processing of information on data subjects

Pax Adviser will comply with the below principles regarding the processing of personal data that it carries out.

5.1      Correct, legal and transparent processing

Your personal data:

(i)        will be processed lawfully, fairly and correctly;

(ii)       will be obtained only for the purposes determined, legitimate, specified and relevant for the fulfilment of the operational needs and shall not be further processed in any manner incompatible with the purpose or purposes for which they are processed;

(iii)      will be processed in a transparent manner.

5.2      Proportionality and minimization of processing

Your personal data:

(i)        will be appropriate, relevant and shall not be excessively processed in relation to the purpose or purposes for which they are processed;

(ii)       shall not be kept longer than is necessary for that purpose or purposes;

(iii)      are relevant and strictly limited to what is absolutely necessary for the purposes for which they are processed.

5.3      Integrity and confidentiality of personal data

Your personal data will be kept in a correct manner and, if necessary, will be kept up to date. The processing of personal data will be done in the safest conditions, which include “protection against unauthorized or illegal processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.”

5.4      Accuracy of personal data

Pax Adviser will take all measures to ensure the validity of the data, and those that prove inaccurate will be updated quickly or deleted.

5.5      Storage limitation

The personal data will be kept as long as they are necessary for the assumed processing, and the longer periods of storage of the personal data are only exceptions associated with the legal provisions.

5.6      Protection of personal data

Personal data will be subject to the appropriate technical and organizational measures reasonably necessary for their protection against destruction, loss, modification, access or other unauthorized or accidental processing.

5.7      Security of data processing

Pax Adviser will take measures regarding the security of data processing and, consequently, will establish its own internal policy for the security of personal data process.


6. Persons authorized for the processing of personal data

6.1.     For the processing of personal data, we can use data processors for this purpose, such as IT solution providers, accounting solutions, business management solutions. Pax Adviser will conclude agreement for the processing of personal data with all the data processors with the processing of personal data in full compliance with the legal norms in force.


7. Recipients of personal data

7.1.     As a rule, Pax Adviser will not provide (by sale or rental) to third parties your personal data. However, Pax Adviser will transfer the information to third parties, when this is necessary for the purpose of data processing, such as the following cases:

(i)        The personal data necessary for the processing of reimbursements by travel service providers will be transferred to third party companies, in order for reimbursement application to be processed.

(ii)       It is possible to cooperate with business partners that offer accounting, legal services, specialized expertise. The data transferred to our business partners are limited to the personal data necessary for the rendering of services and the recovery of amounts, for obtaining compensation, respectively.

(iii)      It is possible to disclose personal data to law enforcement authorities, to the extent required by law.

(iv)      Also, in certain specific situations, when we collect your personal data, we may ask for your consent for the transfer of such data to third parties. In this case, we will inform you about such processing and we will not transmit the data before obtaining your consent.


8. The rights of data subjects

8.1      According to the GDPR, data subjects have the following rights regarding personal data, namely: the right to request information from us about the processing of your data, access to data, rectification or deletion of your personal data (“the right to be forgotten”), the right to obtain the restriction of processing, to oppose data processing, not to be subject to a decision based exclusively on automatic processing, as well as, in certain circumstances, the right to data portability in accordance with the provisions of Art. 12- 22 of the GDPR.

8.2      If the data subjects have given their consent for the processing of personal data, they have the right to withdraw this consent at any time, which will not affect the legality of the processing prior to the withdrawal of consent.

8.3      The data subjects also have the right to submit a complaint to the National Authority for the Supervision of Personal Data Processing (“DPA”) if they consider that the provisions of the GDPR regarding personal data have not been complied with.


9. Data Controller contact details

If you have any requests regarding the way in which your data are processed by Pax Adviser as a Data Controller, you can contact us at the e-mail address:


10. Procedure for resolving the requests of the data subjects

10.1    Pax Adviser has the obligation to notify the reply to the request addressed the petitioner according within 30 calendar days as of the date of registration of the request. This deadline can be extended motivated by Pax Adviser with a maximum of 15 calendar days if Pax Adviser must solve several requests and/or the request is complex.

10.2    Pax Adviser will send to the data subject the reply to his/her request by e-mail.


11. Policy Update

11.1    Pax Adviser periodically verifies that this Policy is correct and thorough with regard to the information to be covered and will update this Policy and publish it here in its up-to-dated version, and this will replace the current version.


Last update: July 22, 2021