Privacy Policy

Two2Fly s.r.o. attaches great importance to your privacy. This Privacy Policy explains how we collect, use and disclose your personal data. Please feel free to contact us if you have any further questions.

Definitions:

  • The Publisher: the natural or legal person who publishes online public communication services.
  • The Site: all websites, web pages and online services offered by the Publisher.
  • The User: the person using the Site and its services.

Nature of the data collected

When using the Sites, the Publisher may collect the following categories of data concerning its Users:

  • Civil status data,
  • identity data,
  • identification data...

Disclosure of personal data to third parties

Your data is not disclosed to third parties. However, you are informed that it may be disclosed pursuant to a law or regulation, or by decision of a competent regulatory or judicial authority.

Prior information regarding disclosure of personal data to third parties in the event of a merger / acquisition

Prior information and the possibility to opt out before and after a merger / acquisition. If we take part in a merger, acquisition or any other form of asset transfer, we undertake to protect the confidentiality of your personal data and to inform you before it is transferred or becomes subject to new privacy rules.

Purpose of reusing collected personal data

Carrying out customer-management operations relating to

  • contracts; orders; deliveries; invoices; accounting and, in particular, customer account management
  • a loyalty programme within one or more legal entities
  • customer relationship management, including satisfaction surveys, complaint handling and after-sales service
  • selection of customers for studies, surveys and product tests (unless the consent of the persons concerned has been obtained under the conditions provided for in Article 6, these operations must not result in profiles revealing sensitive data such as racial or ethnic origin, philosophical, political, trade-union or religious opinions, sex life or health data)

Aggregation with non-personal data

We may publish, disclose and use aggregated information (information relating to all our Users or to specific groups or categories of Users, combined so that an individual User can no longer be identified or referred to) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes and other commercial purposes.

Aggregation with personal data available on the User’s social media accounts
If you connect your account to an account on another service for cross-posting purposes, that service may provide us with your profile and login information, as well as any other information you have authorised it to disclose. We may aggregate information relating to our other Users, groups and accounts with personal data available about the User.

Collection of identity data

Free browsing
Browsing the Site does not require registration or prior identification. You may browse without providing personal information about yourself (name, first name, address, etc.). We do not record personal data merely because you browse the Site.

Collection of identification data

  • Use of the User identifier solely for access to services.
  • We use your electronic identifiers only for and during the performance of the contract.

Collection of device data

  • No collection of technical data
  • We do not collect or retain any technical data from your device (IP address, Internet service provider, etc.).

Cookies

Cookie retention period

In accordance with CNIL recommendations, cookies are retained for a maximum of 13 months after they are first placed on the User’s device, as is the validity period of the User’s consent to their use. Cookie lifetime is not extended on each visit. The User’s consent must therefore be renewed after this period.

Purpose of cookies
Cookies may be used for statistical purposes, in particular to optimise services provided to the User, based on information concerning access frequency, page customisation, operations performed and information viewed.
You are informed that the Publisher may place cookies on your device. Cookies record information relating to browsing of the service (pages viewed, date and time of viewing, etc.) that we may read during subsequent visits.

User’s right to refuse cookies; disabling them may result in reduced service functionality
You acknowledge that you have been informed that the Publisher may use cookies and you authorise such use. If you do not want cookies to be used on your device, most browsers allow you to disable them in the settings. However, some services may no longer function correctly.

Possible association of cookies with personal data to enable operation of the service
The Publisher may collect browsing information through the use of cookies.

Retention period for technical data

Technical data is retained only for the period strictly necessary to fulfil the purposes described above.

Retention and anonymisation period for personal data

Retention of data for the duration of the contractual relationship

In accordance with Article 6-5° of French Law No. 78-17 of 6 January 1978 on information technology, files and civil liberties, personal data undergoing processing is not retained beyond the time necessary to fulfil the obligations defined when the contract was concluded or the predetermined duration of the contractual relationship.

Retention of anonymised data beyond the contractual relationship / after account deletion

We retain personal data only for the period strictly necessary to fulfil the purposes described in these Terms of Use. Beyond this period, it will be anonymised and retained exclusively for statistical purposes and will not be used in any other way.

Deletion of data after account deletion

Data-purging procedures are implemented to ensure effective deletion once the retention or archiving period necessary to fulfil the specified or legally required purposes has expired. In accordance with French Law No. 78-17 of 6 January 1978, you also have the right to request deletion of your data at any time by contacting the Publisher.

Deletion of data after 3 years of inactivity

For security reasons, if you have not authenticated on the Site for a period of three years, you will receive an email asking you to log in as soon as possible; otherwise your data will be deleted from our databases.

Account deletion

Account deletion on request
The User may delete their Account at any time by simply requesting this from the Publisher OR, where applicable, by using the Account deletion menu in the Account settings.

Account deletion in the event of a breach of the Terms of Use
In the event of a breach of one or more provisions of the Terms of Use or any other document incorporated herein by reference, the Publisher reserves the right, at its sole discretion and without prior notice, to terminate or restrict your use of and access to the services, your account and all Sites.

Information in the event of a security breach detected by the Publisher

Information to the User in the event of a security breach

We undertake to implement all appropriate technical and organisational measures to ensure a level of security appropriate to the risks of accidental, unauthorised or unlawful access, disclosure, alteration, loss or destruction of your personal data. If we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or unauthorised access resulting in the risks identified above, we undertake to:

  • notify you of the incident as soon as possible;
  • investigate the causes of the incident and inform you;
  • take reasonable measures necessary to mitigate any adverse effects and harm resulting from the incident

Limitation of liability

Under no circumstances may the commitments set out above regarding notification of a security breach be construed as an acknowledgement of fault or liability in relation to the occurrence of the incident.

Transfer of personal data abroad

  • No transfer outside the European Union
  • The Publisher undertakes not to transfer Users’ personal data outside the European Union.

Amendment of the Terms of Use and Privacy Policy

If these Terms of Use are amended, we undertake not to substantially reduce the level of confidentiality without first informing the persons concerned. We undertake to inform you of any substantial amendment to these Terms of Use and not to substantially reduce the confidentiality of your data without informing you and obtaining your consent.

Applicable law and remedies

Arbitration clause

You expressly agree that any dispute arising from these Terms of Use, including their interpretation or performance, shall be subject to arbitration under the rules of an arbitration platform chosen by mutual agreement, which you agree to accept without reservation.

Data portability

The Publisher undertakes to provide you, upon simple request, with all data concerning you. The User is thereby given greater control over their data and retains the ability to reuse it. This data must be provided in an open and easily reusable format.

Changes to our Privacy Policy

The Publisher reserves the right to change this Policy at any time. Any major changes will be communicated to Users in writing, but Users are advised to check this page regularly for minor changes.

Contact us

By email: contact@two2fly.eu

By post: Two2Fly s.r.o. - Husitská 344/63, 130 00 Prague 3 - Czech Republic

By telephone: +420 735201675 / +32 (0) 471 57 65 93