Claim Winger Privacy Policy

General provisions

This Privacy Policy sets out the rules for the processing and protection of personal data of users using the services provided on the claimwinger.com website (hereinafter referred to as the 'Website') by Claim Winger Sp. z o.o. (registered in Poland under REGON number 543436257 and NIP number 7011289798) (hereinafter referred to as the 'Administrator').

The Administrator processes personal data in accordance with applicable law, including Regulation (EU) 2016/679 of the European Parliament and of the Council ('GDPR'), making every effort to protect your privacy and ensure the security of the data you provide.

Scope of data collected

The administrator may process the following personal data:

• first name and surname,
• contact details: postal address, e-mail address and telephone number,
• data concerning your journey (which may, under specific circumstances, be considered personal data), including data concerning who you travelled with,
• other personal data if disclosed in documents or messages sent to the Administrator, the use of which for the purpose of providing services to you will be justified (the Administrator will make every effort to minimise the amount of such additional data and will request its transfer only if requested by the airlines responsible for the flight, or if it is otherwise particularly justified for the effective pursuit of your claim).

The data processed by the Administrator will be collected by means of:

• Forms on the Website.
• Forms in advertising campaigns:
  • Facebook Lead Ads (Meta Platforms Ireland Ltd.),
  • Google Ads – Lead Form Extensions,

In addition to personal data, the Administrator will process automatically collected information about the user's activity on the Website obtained using cookies and similar technologies (e.g. IP address, device data, browser type, time spent on the Website, clicks, source of entry, location data, user activity, navigation path). This data may be used to create user profiles, analyse behaviour and customise content and advertisements.

Purpose of personal data processing

Personal data will be processed for the following purposes:

• Provision of services to Website users, in particular for the purpose of pursuing claims against airlines (Article 6(1)(b) of the GDPR).
• Ensuring the proper functioning of the Website, including the handling of forms and enquiries (Article 6(1)(b) and (f) of the GDPR).
• Contacting the User, in particular in response to enquiries sent through contact forms on the Website or advertising forms (Facebook Lead Ads, Google Lead Form Extensions) (Article 6(1)(b) of the GDPR).

Data retention period

Users' personal data will be stored for a period justified by the purpose of data processing indicated in point 4 above. In particular, users' personal data will be processed for the period of providing services by the Administrator for their benefit. Users' personal data will be deleted after the expiry of the limitation period for any claims the user may have against the Administrator, with the exception of data whose storage may be required by law.

User rights

At any time, the user has the right to:

• access their data and obtain copies of it,
• correct or remove your data,
• request restriction of the processing of your data,
• if the basis for data processing is the user's consent, to withdraw it at any time,
• object to the processing of data,
• submitting a complaint to President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).

Data security

The Administrator shall implement technical and organisational measures to protect personal data against loss, unauthorised access, alteration or destruction, including SSL encryption and restricted access to systems.

Users' personal data will not be transferred to third parties, except where necessary due to the nature of the services provided by the Administrator.

Administrator contact details

Please send all correspondence regarding personal data protection or possible breaches of data security to the following e-mail address: contact@claimwinger.com.

Marketing and advertising campaigns

With the user's consent (Article 6(1)(a) of the GDPR), their e-mail address may also be used for marketing and advertising purposes (however, it will only be made available to external entities in encrypted form, preventing it from being read and further used). The above applies in particular to:

• running campaigns on Google Ads, Meta Ads (Facebook, Instagram), TikTok Ads, as well as running campaigns on other advertising, affiliate and mobile networks,
• creating advertising profiles and personalising marketing content,
• conducting remarketing and retargeting activities,
• measuring the effectiveness of advertisements and analysing campaign results.

The user may withdraw their consent to the processing of data for marketing purposes at any time.

Cookies and similar technologies

What are cookies?

Cookies are small text files stored on the user's device when using the Website. They are used, among other things, to identify the browser, analyse activity, remember preferences, compile statistics and deliver tailored advertising content.

What data do we collect through cookies?

The following data may be collected, among others:

• IP address, device identifier, browser type, operating system,
• data concerning activity on the Website: visited subpages, clicks, visit duration, source of entry, interactions with website elements,
• data on user behaviour in advertisements (e.g. clicks on advertisements, views, conversions).

This data may be combined with other information that the user voluntarily provides (e.g. via contact forms) in order to better customise content and advertisements.

Types of cookies used

The website uses the following types of cookies:

• technical (necessary) – ensure the proper functioning of the website,
• analytical – enable the analysis of user traffic and behaviour,
• marketing and advertising – allow for the display of personalised advertisements and remarketing in advertising systems,
• functional – used to remember user settings and preferences.

Analytical and advertising tools

The controller may use tools provided by:

• Google Ireland Ltd. (Google Ads, Google Analytics, Tag Manager),
• Meta Platforms Ireland Ltd. (Meta Pixel, Facebook Ads, Instagram Ads),
• TikTok Technology Ltd. (TikTok Pixel),
• Taboola, Outbrain, Admitad, Awin, TradeDoubler, Impact and other affiliate or advertising networks.

Data may also be processed as part of campaigns carried out on other advertising networks, but only if the nature and purpose of the processing comply with this Policy.

The user may at any time:

• manage cookie permissions using the cookie banner available on the Website,
• change your browser settings, including deleting or blocking cookies,

Disabling cookies may affect the functioning of the Website or restrict access to certain features.

Changes to the Privacy Policy

The Administrator reserves the right to make changes to this Privacy Policy. The latest version of the document will be published on the Website with the date of the last update.