Privacy Policy
This Privacy Policy explains how ETT Solutions DMCC ("upsell.travel", "we", "us") processes personal data in connection with the upsell.travel browser extension, the website and related services (the "Service"). The Service is intended for business users (travel agencies and their agents). Orders placed through the Service are fulfilled through the easy to travel platform operated by the same company; the easy to travel Privacy Policy applies to that platform in addition to this Policy.
By installing the extension from the Chrome Web Store, creating an account or otherwise using the Service you acknowledge this Policy and, where consent is the applicable legal basis, consent to the processing described in it.
1. Data we process
- Account data. Name, business email address and authentication data of agency users.
- Booking data. When you use the Service alongside your reservation system, the extension uses the itinerary details of the booking you are working with (flight segments, dates, airports and passenger names) to show relevant services and to place orders. This takes place in your browser. Booking details reach us only as part of an order you actually place.
- Order data. Passenger names, service details, dates, prices, vouchers and, where required by a specific product, a contact email for delivery of the voucher.
- Payment data. Card payments are processed by a third-party payment processor. We receive confirmation of payment and limited card metadata; we do not store full card numbers or CVC codes.
- Support data. Messages, attachments and order references you send to our support team through the Service, together with your name and business email so we can reply.
- Technical data. Log data, device and browser information and usage statistics needed to operate, secure and improve the Service.
2. Data of third parties
Agency users enter and use personal data of third parties, in particular passengers, on whose behalf or in whose interest they act. Such data is processed under the same conditions as the user's own data. By providing third-party data you confirm that you are authorised to do so, that the passenger has been informed about the processing connected with the ordered service and that any consent required by applicable law has been obtained.
3. Purposes and legal bases
We process personal data to provide the Service and perform our contract with the agency; to process orders, payments, refunds and support requests; to comply with legal obligations (including accounting and tax); and on the basis of our legitimate interests in securing and improving the Service. We do not sell personal data and we do not use booking data for advertising.
4. Sharing of data
We share personal data only as necessary: with the suppliers performing the ordered airport service, such as lounge operators, airports and meet-and-assist providers (to the extent required to render it, e.g. passenger name and flight details); with banks and payment systems; with cloud computing, data storage, support and other IT service providers acting on our documented instructions; with financial and accounting tools; and with authorities where required by law. All processors are bound by data processing agreements.
5. International transfers
We are established in the United Arab Emirates and process personal data there and, through our service providers, in other countries. When transferring personal data outside the UAE or the European Economic Area we do so in accordance with applicable transfer regulations: to countries recognised as ensuring an adequate level of protection, or otherwise under appropriate safeguards such as contractual protection clauses, and only to the extent necessary for the purposes described above.
6. Retention
We retain personal data only as long as necessary for the purposes set out in this Policy: order and accounting records for the periods required by applicable law; account data for the duration of the business relationship and a reasonable period thereafter; technical logs for a limited period appropriate to security purposes. Data no longer required is deleted or irreversibly anonymised.
7. Security
We apply technical and organisational measures appropriate to the risk, including encryption in transit, access controls and the principle of least privilege. No method of transmission or storage is completely secure; we cannot guarantee absolute security.
8. Your rights
Subject to applicable law, data subjects may request access to, rectification or erasure of their personal data, restriction of or objection to processing, and data portability. Agencies remain responsible for the accuracy of passenger data they submit and for informing travellers about the processing connected with an ordered service. Requests can be submitted using the contact details in Section 12; we will respond within the timeframes required by law. You also have the right to lodge a complaint with a competent supervisory authority.
9. Cookies and similar technologies
The website uses only technically necessary cookies and similar technologies required for its operation. If analytical or marketing technologies are introduced in the future, this Policy and, where required, a consent mechanism will be updated beforehand.
10. Children
The Service is not directed at children. Passenger data relating to minors is processed solely to fulfil an order placed by an authorised business user.
11. Changes to this Policy
We may update this Policy from time to time. The current version is always available on this page; material changes will be announced through the Service or the website. The date of the latest revision is indicated above. You will be deemed to have accepted a revised Policy by your continued use of the Service after the revised version is posted.
12. How to contact us
ETT Solutions DMCC
Office 1701, Prime Tower, Business Bay, Dubai, United Arab Emirates
Unit No. 1103, DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates, PO Box 340505
Support: support@easyto.travel
Personal data requests: ab@easyto.travel
Representative in the European Union: Färber Str. 20, 90402 Nürnberg, Germany, ab@easyto.travel.