Privacy Policy

Effective as of xx August 2025, Version 1.0  

This policy explains how we handle your personal data. Here’s a quick summary first, with key takeaways. It is not a substitute for reading the full policy, along with our Terms of Use.

Safeguarding Your Data: TravelCare dedication to Privacy and Security 

We are committed to upholding high standards of privacy and information security. At Travel Care, we understand that when you use our services, you trust us with your personal data. That’s why we’ve implemented robust technical and organisational measures to keep your information safe and your privacy respected. We are transparent about how your data is handled, and we continuously work to strengthen our privacy programme in line with recognised international principles and best practices. Your trust means everything to us.

If you consent, we may use cookies and similar technologies to collect technical information about your device and how you interact with our website (such as your device’s unique identifier, subscription status, email address, and browsing behaviour).

This information helps us analyse the performance of our services, improve functionality, and ensure that your experience on our website is relevant, efficient, and user-friendly.

Data that helps to serve you

When you use the Travelcare service, we collect certain personal data to help us continuously improve the quality, reliability, and relevance of our services. This allows us to better understand your needs, enhance your user experience, and ensure that the information and support we provide are accurate, timely, and tailored to your journey.

You’re in control and can reach out to us

We believe in transparent and open conversation – you can access, modify, correct, erase, and update your personal data by emailing us at privacy@skycop.com.  Where we rely on your consent to process your personal data, you can withdraw your consent. If you have any questions about this Privacy Policy, let us know.

Introduction

This Privacy Policy explains how UAB Skycop.com, legal entity code 304423851, registered address at Dariaus ir Gireno st. 21A, Vilnius, the Republic of Lithuania, and its affiliated entities (“TravelCare” or “we” or “us”) complies with the provisions of the General Data Protection Regulation (“GDPR”), and any other applicable data protection laws and regulations. This Privacy Policy explains how TravelCare collects, stores, uses, transfers, and shares personal data from our clients (“you”) in connection with the provision of service and TravelCare website, including all subdomains, products and services related to it (the “Website”) (all collectively, the “Services”) and interact with our advertising campaigns, including Google and Facebook Lead Ads. UAB Skycop.com is a Lithuania registered data controller of the Services.

By participating in the Program, the Customer’s personal data provided via the TravelCare Website is collected in accordance with this Privacy Policy. The Customer also acknowledges and agrees that such data may subsequently be processed by Skycop under its [Privacy Policy] in the event of a service being triggered (e.g., flight disruption claims). For the SmartDelay service specifically, personal data may also be shared with Collinson Service Solutions Limited, which acts as an independent data controller, and processed in accordance with the SmartDelay [Privacy Policy].

We may change this Privacy Policy from time to time. If the changes are material, we will notify you by email. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. In some cases, you will be given a choice to accept changes to this policy. If you do not accept the terms of the updated Privacy Policy, please do not use the Services. 

In case of any inquiries or if you would like to exercise any of your rights provided in this notice, you may submit such inquiries and requests by means provided in Contacts section.

You may contact our data protection officer or contact us regarding privacy matters at privacy@skycop.com.

1. What data we collect?

Personal data we collect from you

We collect personal data about you when you interact with the Services. This can be directly from you or from other sources and third parties.

1.1. Personal data you provide to us directly:

    • General information as your account data. When you sign up to use the Services, we may collect personal data such as your name, email address, phone number, password, country of residence and  language, date of birth and other data that you provide while registering. We process account data for the purposes of operating our website, providing our services, ensuring the security of our website and services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract as well as our legitimate interest, namely monitoring and improving our website and services.
  • Subscribing to our email messages and newsletters. When you subscribe, we may process personal data such as your name, email address, phone number to send you the relevant messages and newsletters. The legal basis for this processing is your consent. Also, if we have already provided services for you on our website and you do not object, we may also process messaging data on the basis of our legitimate interest, namely on seeking to maintain and improve customer relations.
  • Information relating to any communication that you send to us such as communication content and metadata associated with the communication. The correspondence data is processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, ensuring uniform and high quality consultation practice and for investigating disputes between you and our employees.

1.2. Personal data we collect automatically when you access or use the Services, we may automatically collect the following information:

  • Data about your use of the Services, including: the frequency and patterns of service use, areas and features of the services accessed, payment transaction information (excluding full payment card details), and engagement with specific features. This data may also include technical details such as your browser type and version, operating system, referral source, visit duration, page views, and website navigation paths. We obtain this data through cookies and similar technologies to better understand how you use our website and services. The legal basis for this processing is our legitimate interest in monitoring and improving our website and services and, where applicable, your consent based on the type of data. To collect this and other information, we may use cookies and other similar technologies. See more in our Cookie Policy.
  • Location information: IP address for an approximate location (not precise location). The legal basis for this processing is our legitimate interest in monitoring and improving our website and services.

1.3. We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

1.4. We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

1.5. In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2. How we use your personal data?

2.1. Principles of processing

Data minimization and purpose limitation: We will not process personal data in a way that is incompatible with the purposes for which it has been collected or authorized by you or collect any personal data that is not needed for the mentioned purposes.

No sale of personal data: We will not sell or rent your personal data for monetary gain. We will not disclose your personal data except as otherwise described in this Privacy Policy. We will share your personal data with our service providers who support our Services as described in this Privacy Policy.  

2.2. Legal basis of processing

Account Data

Name, email address, phone number, password, country of residence, date of birth

Performance of contract

Legitimate interests (monitoring and improving website and services)

Subscription Data

Name, email address, phone number

Consent

Legitimate interests (maintaining customer relations if services already provided)

Communication Data

Communication content and metadata

Legitimate interests (website and business administration, quality assurance, dispute investigation)

Usage Data

Browsing behavior, browser type, operating system, page views

Legitimate interests (monitoring and improving website and services)

Consent (depending on data type)

Location Data

IP address (approximate location)

Legitimate interests (monitoring and improving website and services)

Payment Data

Payment transaction information (excluding full payment card details)

Performance of contract

Legal Claims

Any personal data

Legitimate interests (protection and assertion of legal rights)

Insurance & Professional Advice

Any personal data

Legitimate interests (business protection against risks)

 

2.3. When we provide your data to others?

  • We may disclose your personal data to any member of our group of companies and partner companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice.
  • We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  • We may disclose your personal data to our payment service providers. We will share service provision data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers].
  • We may disclose your personal data to other service providers insofar as it is reasonably necessary to provide specific services (including, website hosting service providers, courier service providers, providers of servers and maintenance thereof, email service providers). We take all the necessary measures to ensure that such subcontractors would implement proper organisational and technical measures to ensure security and privacy of your personal data.
  • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  • Persons indicated in this Section may be established outside Lithuania, European Union and European Economic Area. In case we will transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured.
  • Some personal data provided via the TravelCare Website may be shared with Collinson Insurance Services Limited, which acts as an independent data controller, solely for the purpose of providing the SmartDelay service. Personal data shared with Collinson will be processed in accordance with the Collinson’s Privacy Policy [Hyperlink to their PP].

 

2.4. Here are some of the main processors we rely on:

Infrastructure and security

Cloudflare, Inc.

Cloudflare Privacy Policy

All personal data

Security of the website, content delivery

Email communications

Listserv Inc. 

Lsoft Privacy Policy

Email address

To reach you with our newsletters and notifications

Analytical tools

Google LLC (Google Tag Manager & Google Analytics 4) 

Google Privacy Policy

Google Analytics Data privacy and security

Website usage data

To monitor our performance and understand how you use the Services on our Website, while applying suitable privacy protections. 

Customer support

Zendesk Inc., USA

Zendesk Privacy Policy

Email address

Content of the emails, account data

To process and sort all emails received from you

Payments

Link, Inc., USA

Link Privacy Policy

Payment and banking information

Personal identifiers

To collect and process payments for certain Website 

 

2.4. How do we delete your data?

We use industry-standard methods and procedures to ensure that we securely and permanently delete your personal data from our systems so that it is no longer capable of recovery. These procedures can include automated notifications to some of our processors who process your personal data on our behalf.

2.5. Security of your personal data

General security measures

We implement technical and organizational measures in an effort to protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the nature of the personal data that we process and risks associated with special categories of personal data we collect. This includes:

  • encryption of your personal data in transit and in rest;
  • systematic vulnerability scanning and penetration testing;
  • protection of data integrity;
  • organizational and legal measures: For example, our employees have different levels of access to your personal data and only access your personal data for limited and necessary purposes required for the operation of the Services. We impose strict responsibility on our employees for any disclosure, unauthorized access, alteration, destruction, or misuse of your personal data; and
  • conducting periodical data protection impact assessments in order to ensure that the Services fully adhere to the principles. 
  • Please protect your password. Do not share it with others or allow anyone to use your device. 

No security system is perfect. Therefore, we cannot guarantee the absolute security of the Services or that your information will not be intercepted while being transmitted to us.

Security breaches

If we learn of a security systems breach, we may either post a notice or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential personal data breach, together with other actions referred to in the Privacy Policy, we will take actions to remedy the breach as appropriate under the circumstances and performing other reasonably necessary activities.

If you want to report a security incident related to the Services, please email us at security@skycop.com

Transfers of personal data outside of the EEA 

Personal data in the EEA is protected by the GDPR. When transferring personal data outside EEA, we will always apply appropriate safeguards in accordance with the law to ensure your personal data is protected. For example, we enter into data transfer agreements that incorporate the European Commission approved Standard Contractual Clauses and carry out transfer risk assessments. For further information, please email us at privacy@skycop.com.

3. How long we store your data?

3.1. Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case, it shall be kept for no longer than:

  • access data will be retained for no longer than 3 (three) years following your last update on the account or 10 (ten) years following the end of provision of services (whichever is the latter);
  • service provision data will be retained for no longer than 10 (ten) years following the end of provision of services;
  • messaging data will be retained for no longer than 2 (two) years following the provision of consent or, in case, the messaging data is being sent to the present clients in order to maintain and improve customer relations, for no longer than 2 (two) years following the end of provision of the respective services;
  • communication data will be retained for no longer than 2 (two) months following the end of such communication.

3.2. Usage data (e.g., information about how you use our website or services) is retained for different periods depending on how it is collected:

  • Usage data collected via cookies or similar technologies is retained for the periods specified in our Cookie Policy.
  • Usage data collected through server logs or other technical means (e.g., IP address, browser type, error logs) is retained for 6 months for security, troubleshooting, and analytics purposes, after which it is deleted or anonymised.

3.3. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

4. Your rights

4.1. In this Section, we have summarised the rights that you have under data protection laws. Some of the rights are complex thus we only provide the main aspects of such rights. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

4.2. Your principal rights under data protection law are the following:

  • the right to access data;
  • the right to rectification;
  • the right to erasure of your personal data;
  • the right to restrict processing of your personal data;
  • the right to object to processing of your personal data;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

4.3. The right to access data. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data. 

4.4. The right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

4.5. In some circumstances you have the right to the erasure of your personal data. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defence of legal claims.

4.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however, we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.

4.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

4.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

4.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

4.10. The right to data portability. To the extent that the legal basis for our processing of your personal data is: (i) consent; or (ii) performance of a contract or steps to be taken at your request prior to entering into a contract, necessary to enter into such, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

4.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by the State Data Protection Inspectorate of Lithuania, registered office at L. Sapiegos str. 17, LT-10312, www.ada.lt.

4.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

4.13. In addition to specific measures provided in this Section or the website, you may also exercise any of the rights indicated herein by contacting us via Contacts.

5. Marketing messages

5.1. In case you consent, we will send you marketing messages via email and/or SMS to inform you regarding any relevant information related to what we are up to.

5.2. Also, if we already have provided services to you and you do not object we will inform you about our other products that might interest you including other information related to such.

5.3. You may opt-out of receiving marketing messages at any time.

5.4. You may do so by (i) choosing the relevant link in any of our marketing messages or (ii) contacting us via means provided in the Contacts section.

5.5. Upon you having fulfilled any of the provided actions we will update your profile to ensure that you will not receive our marketing messages in the future.

5.6. Please be informed that as our business activities tend to consist of a network of closely related services, it may take a few days until all the systems are updated, thus you may continue to receive marketing messages while we are still processing your request.

5.7. The opt-out of the marketing messages will not stop you from receiving messages directly related to the provision of services.

6. About cookies

6.1. Cookies are small textual files containing an identifier that is sent by a web server to your web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

6.2. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

6.3. Cookies may serve different purposes (e.g., functional, performance, analytics, advertising), and their retention periods vary depending on the type. Some cookies are set by third parties, such as social media platforms, analytics providers, or advertising networks, which may collect information about your browsing behavior across different websites. The detailed types, purposes, and retention periods of all cookies we use are provided in this Cookie Policy.

7. Third party websites

On the website you may find links to and from partner sites, information sources and related party websites. Please take note that such third party websites that you will visit by clicking on links have their own privacy policies and we take no responsibility regarding such privacy policies. We recommend familiarising with privacy policies of such websites before providing any personal data to such.

8. Automated decision-making and profiling

8.1. No Automated Decision-Making

TravelCare does not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you as defined under Article 22 of the GDPR.

8.2. What This Means

All decisions that may affect your rights, interests, or access to our services are made by human reviewers. We do not use automated systems, algorithms, or artificial intelligence to make decisions that would:

  • Have legal consequences for you
  • Significantly affect your rights or interests
  • Determine your eligibility for our services
  • Affect the terms and conditions of service provision

8.3. Analytics and Performance Monitoring

While we use automated tools for website analytics, performance monitoring, and technical optimization (as described in sections 1.2 and 2.3), these activities are purely for technical and statistical purposes and do not involve decision-making that affects you individually.

9. Children personal data

9.1. Our website and services are targeted at persons over the age of 16.

9.2. We process personal data of younger persons than provided above only upon the parent rights holder providing consent to do so.

9.3. If we have reason to believe that we hold personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.

10. Updating your data

Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Changes to the notice

Any changes to this notice will be published on the website and, in case of material changes, we may inform you about such via email.

12. Complaints and dispute resolution

We commit to resolve complaints about our collection and use of your personal data. Individuals with inquiries or complaints regarding privacy issues should first contact us by emailing us at privacy@skycop.com. 

13. Contact us

If you have any questions or concerns about your privacy, you may contact us or our data protection officer by writing to us at:

Skycop.com UAB, Dariaus ir Girėno St. 21, Vilnius, LT-02189, Lithuania

Or by emailing us at privacy@skycop.com.

You may also contact your local data protection authority. You can find a list of local data protection authorities here