Refundmore Privacy Policy

Refundmore treats your personal data according to the law of data protection (General Data Protection Regulation) and under EU Regulation 216/679 concerning the rules on handling personal data.

Which personal data is handled?

We collect the data which we need in order to handle and assess your legal case. The collection of personal data is limited to the necessary information.

That means that you are only required to inform us of the data necessary for the case handling on the specific legal step on which the case is placed.

• For example, you do not need to hand over your personal ID number / social security number when opening a case. But if Refundmore at a later point has appraised the case to proceed to court, the court at the jurisdiction for your case might require your personal ID for verification.

Though, at the case's opening procedure, we will encourage you to fill in your address, bank information, and social security number / personal ID, even if it is not required at that step. This is to reduce the procedure time and offer swift case management.

When you open a legal case with Refundmore, you will be asked to fill in personal information in category 1 to begin assessing your legal case.

Category 1

• Name
• Telephone/mobile number and/or email address
• Booking number

Your name and booking number will be passed on to the specific airline, which we regard as the receiver of your legal claim.

We will use the contact information which you have provided us to contact you concerning an update on your case - or if we need further information from you.

Subsequently, during the process of opening your legal case, you will have the possibility to fill in your personal information in category 2:

Category 2

• Address 
• Bank account number / IBAN number
• Social security number / Personal ID
• Photo ID

Information in category 2 can become necessary for assessing your legal case at a later time during the claiming process.

It will be required that you inform Refundmore of your information in category 2 if we regard it necessary for the assessment procedure.

As an example, we can conclude that your case will proceed to court or other authorities that, for example, will need your personal ID. Another example could be if we receive the monetary compensation/ refund from the airline and need your bank details to transfer your share to you.

You can be asked to send some photo ID as some airlines require ID verification to assess your claim.

In those cases, you will receive a guide on blurring personal data that is not relevant for the airline to receive.

If you have not adequately blurred the ID, we will provide your photo ID with an extended blurring before handing it over to the airline.

We treat your personal information according to the nature of the agreement and contract which we have entered with you - or as a consequence of our legal obligation to you.

For which purpose do we collect your personal information?

The purpose of collecting your personal information is to gain compensation or a refund for you from the airline, according to the EU-regulation 261/2004.

In the case that you breach your contract with Refundmore (cf. Refundmore's terms), your personal information will be used in the process of a possible claim directed to you.

Your bank information will only be used for transferring your monetary compensation/refund to you.

In some cases, the airline wishes payout to you directly, for which purpose your bank information will be shared with the airline. Neither Refundmore - nor business partners or airlines - have access to deduct money from your bank account.

For how long do we keep your data?

Refundmore conserve your personal information as long as your information is needed.

The time frame for the conservation of your personal data depends on various factors that are according to:

• which type of personal information is in question,
• which is the outcome of your case.

We erase category 2 information faster than category 1 information.

Concerning the outcome of your case, it could mean that there has been a bank transaction connected to your case. In this situation, we are legally obliged to conserve your personal data for five years, cf. the Accounting Act in Denmark.

Another outcome could be that we early on in the process of assessing your case have determined that you are not eligible for a payout. In that situation, we will close your case and shortly after erase all of your personal information.

You have at all times the right to gain an insight into how long we are keeping and protecting your personal information, cf. the section further below, which informs you of your right to an insight into the data we have on you.

Sharing of data to a third party

Your personal information can be shared with the airline, the airline representatives, our business partners in other EU- or ØES countries, and state-owned authorities, such as the courts.

We share information only as a necessity to legally assess your right to a monetary payment.

Your data is shared with Refundmore’s parent company, Flightright GmbH, who enters it into the internal case handling system, CMA. The system is used by Refundmore to collect your claim against the airline.

At Refundmore, we demand that all of our business partners, who receive personal information to support your case for you, comply with the legislation's rules. For this reason, Refundmore has entered data protection contracts with our business partners to ensure that they also treat your personal data according to the rules.

Sharing of data outside of the EU

The sharing of personal information outside of the EU borders can lead to certain risks, as the so-called third countries are not covered by the General Data Protection Regulation.

If Refundmore had determined that your claim of a refund or compensation will need to be directed to a non-European - and non-EØS based airline - your claim would be sent to this third country based airline.

In this case, some of your personal information will have to be shared with the airline in question - an airline based in a third country.

The airlines are not Refundmore's business partners. For this reason, it is not possible for Refundmore to enter an agreement with the airline on how they may treat your personal data.

We only share the specific data necessary to gain compensation and/or a refund for you.

You have the right to an insight into how we handle your personal data.

Your personal information will be treated in a transparent matter for you. This means that you, at all times, have the right to require an insight into how we contain and treat your personal information.

If the information which we have collected from you is incorrect or misleading, you have the right to correct the information. Equally, you have the right to have all of your personal information erased, as long as you have met the requirements in the General Data Protection Regulation, article 17.

All inquiries regarding insight into your personal data, correction or removal of your data, must be addressed to [email protected]. Please mark your email with Personal Information in the headline.

Safety

Refundmore has incorporated appropriate technical and organizational safety measurements to ensure that your personal information is handled correctly.

Your personal information is kept securely. We have made all possible safety measurements to ensure that your data is not erased, made public, lost, devaluated, or will be in touch with unauthorized personnel. Furthermore, measures have been made to ensure that your personal information will never be accidentally nor purposely treated in unlawful manners.

Refundmore's employees have been thoroughly instructed in following guidelines on how to handle the different varieties of personal information when working with cases that contain personal information.

You have the possibility of delivering a complaint to the Data Inspectorate in Denmark if you find that Refundmore has treated your personal data against the legislation.

Contact: