Privacy Policy

Edition as of December 01, 2022

WayAway is primarily a metasearch engine for flight tickets, hotels, and other services for travelers that is available through our websites and mobile apps. For the purposes of this Privacy Policy, WayAway shall be considered as the metasearch engine provided to the users via the WayAway mobile app in the Apple, Google, and other app stores from time to time (hereinafter "WayAway").

User privacy is important to us and we do whatever is required to protect it. In terms of Data Processing, we ensure your rights as Data Subjects and observe the regulations of the California Consumer Privacy Act ("CCPA"), California Privacy Rights Act ("CPRA"), Virginia Consumer Data Protection Act ("VCDPA"), Colorado Privacy Act and other applicable legislation of other states along with regulations of relevant state authorities as well as other applicable laws and rules. In this Policy, we aim to openly explain how we will possess your data and what processing standards we follow.

The present Policy includes our policy on processing cookies or similar technologies that are more suitable for use in online mobile apps. This Policy is also closely related to the License Agreement, where you can find information about how the WayAway mobile app functions as well as your rights and liabilities when using the app.

Pay close attention to this Policy. If you have any questions after reading this Policy or if you find any errors or inaccuracies, please contact our legal team. Please describe your problem or question in detail so that we can quickly respond to it, help you, or correct the error and improve our services in the process.

We reserve the right to change this Policy if we make changes to our processing procedure or need to take newly-enacted personal data protection legislation into account. We'll notify you in case of significant changes that may affect your interests, rights, and status. We guarantee that the protection of your personal data is always legitimate and fair, and that your data is secure.

Key terms

For starters, let's clarify some key terms that we will use in this Policy to eliminate the possibility of misinterpretation.

Personal data or personal information refers to any information relating to an identifiable person or household who can be directly or indirectly identified or reasonably linked by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including an email address, identification number, device information, location data, or online identifiers, such as cookie files or similar technologies.

Sensitive information means special categories of personal information, as defined by subdivision (ae) of 1798.140 of California Privacy Rights Act (CPRA), that for instance include such identifiers as passport, social security, driver's license, credit card or debit card numbers and other details of a consumer's personal and financial documents as well as their precise geolocation and biometric data.

Data Processing refers to any operation or set of operations performed on personal data or on sets of personal data, whether by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination (or otherwise making available), alignment, combination, restriction, erasure, or destruction.

'You', 'your', or 'Data Subject' and 'Consumer' refer to users of the WayAway mobile app, subscribers to any service we offer through the app, or prospective/existing clients communicating with us via email or other means.

Data Controller refers to a person who (either alone or jointly with other persons) determines the purposes for which, and the manner in which, any personal data is, or is to be, processed. For the purposes of this Policy, the Data Controller is Go Travel Un Limited, a Hong Kong corporation registered under the number 1658681 with a legal address at 4007 Central Plaza, 18 Harbour Road, Wanchai Hong Kong, doing business as WayAway.

Data Processor, in relation to personal data, refers to any person (other than an employee of the Data Controller) that is considered as a service provider to the Data Controller who processes data on behalf of the Data Controller. We describe how we engage with Data Processors and other third parties that may process personal data on our behalf in "Data Processing Conditions and Principles" section of this Policy.

Profiling refers to any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to Data Subjects. Profiling is done to analyze or predict aspects concerning that specific Data Subject's preferences and interests while using a particular service of ours (within this Policy – users of the WayAway mobile app).

Account refers to a section of the WayAway mobile app (visually represented as the "Profile" section in the app) that is available to you after authorization (signing up) and gives you access to certain services and features, which improve your user experience and cannot be accessed without authorization.

We can use other terms and definitions as well, even if they are not explicitly specified in this section, as long as they are set out in the applicable legislation or in our License Agreement.

Data that we can collect and process on WayAway

When you use our mobile app and its features or when you contact us, we may collect and process any data and information that you provide to us voluntarily, that is collected automatically, or data that we receive from other sources.

Voluntarily provided data

This includes any information you provide to us yourself, such as information provided when you fill out a search form, subscribe to our marketing and commercial communications, enter your account information, enter into contractual relationships with us related to the usage of our products (e.g., WayAway Plus subscription), send us a query or feedback, participate in discussion boards or other social media functions via the WayAway app and marketing special project subdomains, complete promotions or surveys, or report a problem with our mobile app. We may also process data you provide to our partners, including airlines and OTAs, while making a booking after redirection.

Voluntarily provided data may include the following:

Personal information:

- Search data of available products on WayAway, including travel dates and destinations;

- Respective authentication data, including, for example, social network parameters and email addresses;

- Contact data entered by you in the input fields on the airline, hotel, or OTA web-resource after redirection;

- Other personal information contained in your queries and communications with us.

Sensitive information:

- Your personal details and respective data of people who will accompany you on a trip (this may include PNR, your passport or debit/credit card number, etc.) that you directly provide us with in order to receive support with the relevant issue from our support team;

- Particulars of your payment method needed for conducting payments upon a direct agreement concluded between you and the Data Controller (e.g., WayAway Plus Auto-Renewable Subscription Agreement).

Note: in regard to the personal information of the users from Canada, the categories "personal information" and "sensitive information" may be treated differently depending on the context (pursuant to the Personal Information Protection and Electronic Documents Act, 2001).

Automatically processed information (incl. data received from third parties)

This information mostly consists of online identifiers or technical facts about your connection point or in-app events processed or created, for example, via libraries and software development kits incorporated in the mobile app for maintaining certain features or functionality. This information includes device and connectivity information, such as your IP address ( Internet Protocol) , unique device identifiers (such as the IMEI for phones, MAC address of the device's wireless network interface), mobile network information, mobile operating system, your time zone and language settings, local storage, or cookie-like files and parameters.

This data is automatically collected when you use our mobile app. In some cases, this data can be created by our software or third-party programs (mentioned in libraries and SDKs), integrated into the WayAway app.

The list of data categories that may be automatically collected by us includes the following information:

- IP-address and log information (such as error reports);

- Geolocation (meaning country or region in terms of redirection to the appropriate market interface);

- Mobile device information, including device type/model, locale, and OS information;

- Impersonalized booking data after redirection (meaning destination, dates, and prices);

- Cookies and similar tracking technologies, including local storage data, statistics, and analytics on the use of the service and its different features, as well as interaction information and in-app events (scrolling, clicks, timings, etc.).

The category of data received from third parties includes different types of data, mostly online identifiers, which we obtain from airlines, OTAs, GDS, as well as our technical, analytical, marketing, and other partners or integrated software.

For example, we might insert advertising on our partners' web-resources, social networks, or advertising networks that may categorize the WayAway mobile app users with similar characteristics or interests into non-personally-identifiable data segments, which may then be offered to their own clients, visitors, and subscribers.

We might obtain and record information that an ad was requested or shown, how many times said ad was shown, the target geo of said ad (which will not include an IP address or specific personally-identifiable location information), and any user interactions with said ad or information about the page on which it appears. This information is used for statistical purposes, analysis, reporting, and troubleshooting. In most Data Processing situations, such information does not allow us to identify you as a Data Subject and will be processed with an appropriate level of protection and limitations, which the data source establishes.

We also might collect your log-in information when you enter your Account via an applicable authorization tool that is used on WayAway. Such information is provided by a third party depending on what method you use for authorization from the list below:

Google Account ( Learn about how to manage our access to your Google Account. Learn more about Google's practices of securing sharing of user's data);

Facebook Account (Check Facebook's privacy policy here);

Apple ID (See this page to learn how to manage your Apple ID);

WeChat Account (Check WeChat's privacy policy here);

Line Account (Check Line's privacy policy here).

Types of data that we do not process

We do not process data on children, as WayAway is intended only for use by users over the age of 16 (or other age of maturity determined by applicable local laws allowing for the independent use of Internet services like WayAway). If you are under the specified age, you may only use WayAway with the involvement of your guardian or holder of parental responsibility. We do not knowingly collect or process personal information from children under the specified age without the consent of the child's holder of parental responsibility. In case of doubt, we will cease the processing of questionable data and delete it.

We do not collect and process special categories of personal data and genetic data without your direct consent, such as your name, age, email, passport, and payment method details (unless you subscribe to our marketing mailing, purchased WayAway Plus subscription, or log in to your Account), phone number, home address, etc.

We do not process data that you have directly asked us to stop processing or opted out in any other way.

We also do not process any data acquired by third parties on other platforms that you click out to from our mobile app. For instance, by clicking on the ad banner, except for cases and particular data types directly mentioned in this Policy. Your Data Processing on third-party platforms is carried out according to the rules and processes set out by owners of those platforms.

Additional information on Data Processing

Please note that, when you proceed with purchasing flight tickets or other travel services after redirection from our mobile app to the provider carrying out the particular service, we do not acquire, store, transmit, or process any additional information except depersonalized information, such as prices, dates, destinations, and a transaction identifier.

In providing personal data about other individuals (such as someone whose name you are using to enter an Account or subscribe to our marketing promotions), you represent that you have notified them of: (1) the grounds and purposes for which said information will be used (see below), (2) the recipients of their personal data, (3) and how they can access and correct this information. The consent that you give for a third person is considered by us to be the consent of said third person.

Selling and Sharing of Personal Data. We assure that we do not sell personal data to any third party. However, we may share your personal information to our partners for business and commercial purposes as it is described above and in "Data Processing Conditions and Principles" section of this Policy. Read the last section of this Policy to learn more about your right to opt out of sharing your personal information and the ways in which you can exercise this and other rights regarding the subject matter.

Email marketing and communications. We believe that our users would like to get more information concerning travel that is useful to improving their possible travel experience as well as information about the best deals on flight tickets, other travel products, and more (commercial information). In addition, users most probably would like this information to meet their own needs and interests. Upon authorization in the Account or when using a particular feature of the service, we offer you the chance to subscribe to our marketing newsletter to receive such news and third-party ads. You can unsubscribe from direct marketing communications by email at any time by using the opt-out form in one of the received emails or by contacting our support team.

Profiling. It's important for us to understand the WayAway audience, including their needs and preferences, in order to make the service better and more convenient both generally and for each particular user. To achieve these goals, we can create profiles of our users based on the data collected in their interactions with WayAway in order to provide our service in the best possible way or provide personalized ads and marketing communications if we've received your consent. In any case, we never use collected data to make automated decisions that significantly affect your interests or rights as a Data Subject.

We never show our users different prices on the analogous services they may find using our metasearch engine and we never prohibit or block the use of a particular feature of WayAway solely based on your online profile.

Grounds and purposes for Data Processing

Grounds for Data Processing

In this section of the Policy, we outline the legal grounds and purposes for processing personal data during your interactions with WayAway, related domains accessed via the mobile app, or individual features of our product.

We process your data only if there are legal grounds to do so. When applicable, we receive your consent for Data Processing, which you provide through an explicit action, such as clicking a suitable consent-giving button or ticking a relevant box.

In other cases, data is processed (1) in your interest or to provide you with the relevant service or functionality of the service according to the License Agreement. , for instance, to provide search results or resolve an issue; (2) to email marketing information about WayAway or our advertisers; or (3) to fulfill other contractual obligations.

For example: By transferring the relevant information about your chosen flight tickets to our partners, we fulfill our obligations to these partners to properly record bookings and statistics on our end. In addition, user data is processed in our legitimate interests, for example, to improve the performance of WayAway or a particular feature of the metasearch service, prevent fraud, data parsing, etc.

Purposes of Data Processing

Data Processing purposes are largely determined by WayAway's functionality and derived from valid grounds for Data Processing. Primarily, we strive towards improving our service and making your experience with WayAway as efficient, secure, convenient, and personalized as possible. We also want to keep you updated on our new features, products, promo campaigns, special WayAway projects, other interesting and bargain deals in the travel market, and more, by sending you gripping articles and sources with potentially useful information for travelers. In addition, we attract income by displaying third-party ads and process data to track ad performance or select the ads that may suit you better.

To present our Data Processing purposes in a more readable way, we have gathered all the grounds, potentially applicable purposes, and the data being processed on said grounds and for said purposes in the table below:

Data Processing conditions and principles (Privacy management practices)

In accordance with our Privacy management program, we implement the following practices within the processing of your personal information in order to keep it safe and secure.

Confidentiality and security

We believe that the confidentiality and security of our users' data are key to maintaining long-term trusting relationships with them. We are committed to protecting the personal data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your personal data from unauthorized access, use, or disclosure.

At WayAway, we use the services of Data Processors, whose products and solutions are required for hosting our web-resources and products, storage and collection of data, implementing features of our mobile app, analyzing and testing the app, Profiling, email marketing, and supporting interactions with you. Providers of such services are carefully selected based on WayAway's specifics and ensure the safety of data at the appropriate level, according to the present Policy. In most cases, such providers help us collect online identifiers, analytical files and similar technologies.

You can always set up your preferences for collection of cookie files and other online identifiers, including local storage data and in-app events using special settings for the operation system of your device as well as settings for managing your Data preferences (privacy) menu in the Account or by our support team.

Data retention

We retain your Personal Information for as long as required on the grounds of processing purposes. Terms may also differ for particular categories of personal information.

We also reserve the right to store various types of information (without any time limit) to use for analyzing our service performance, improving its features, providing services to you, and protecting the interests of WayAway.

Meanwhile, we give you the opportunity to control and influence the time we store and process your data, as specified in the "Your rights" section of the Policy.

Transferring personal data to third parties

We share personal information about you with third parties or non-affiliated companies until you notify us of your decision to opt out of sharing your personal information, except regarding the processing that takes place in order to provide services you've requested, or under the following circumstances:

We may disclose your information to third parties when we reasonably believe we are obligated to do so by law and/or in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.

In the event we are acquired by or merge with a third party or undergo a change of control, we reserve the right to transfer information, including any personally identifiable information, to the successor entity.

We may disclose or otherwise allow others to access your personal information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant, or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention, and national security.

Your rights

The rights users are given with regard to the collection and processing of their personal data in accordance with California Privacy Rights Act ("CPRA"), and legislation of other states of the USA if applicable (FOR USERS FROM THE USA) as well as in accordance with Personal Information Protection and Electronic Documents Act, 2001 (FOR THE USERS FROM CANADA)

The right to be informed. In this Policy, we provide you with detailed information related to the processing of your personal data.

The right to know what personal information is being collected and right to access personal information. You can request us to disclose an exact description of categories and sources of personal data we collect and what are the purposes of collection and sharing your information, who are the third parties we share your data with and the list of specific pieces of personal information we have collected about you.

The right to correct or rectify your personal data if it is inaccurate, incomplete, or outdated. You are entitled to make corrections on the personal data you have provided us with during the registration procedure using special interface features in your Account at any time.

The right to erasure (deletion or removal) of your personal data. The right to restrict (block) processing. When processing is restricted, we will continue to store your personal data, but not process it any further.

Rights related to automated decision-making, including Profiling. We do not make any decisions that might produce legal consequences for you based on automated processing without legal grounds.

However, you may opt out of automatic processing your data unless this data is not processed by us for business purposes. This right may be exercised via managing your data preferences through the Data preferences menu.

Right to opt out of selling or sharing your data. You can opt out of sharing your personal information to third parties for non-business purposes by managing your data preferences through said Data preferences menu (Do Not Share My Personal Information).

The right to limit the use of your Sensitive Information. Please be informed that we use your sensitive information solely to provide you with the services under the contract that you have entered into. We do not sell or share your sensitive Information for commercial purposes.

The right to withdraw your consent (object) to direct marketing.

The right to lodge a complaint with a supervisory authority (for Canada - with Privacy Commissioner). You have the right to lodge a complaint with your local supervisory authority if you have a concern about our processing practices.

The right of no retaliation following opt-out or exercise of other rights. You have the right to exercise all of the abovementioned rights free of charge and without any following retaliation or discrimination against you. We respect your privacy rights and will not charge or deny you any services should you prefer to keep your personal information private and decide to exercise any of the said rights. However, some of WayAway functionality/products are technically based on processing your data and we may not be able to perform the respective services without certain data about you.

You can exercise all of your above rights (if implied) by contacting us or using the available opt-out or «manage your privacy» functions within the service. You can also forward your complaint or requirement to the Privacy Officer of Go Travel Un Limited, who is the person accountable for the Data Controller's privacy policies and practices, by sending an e-mail to [email protected].