Privacy Policy

Introduction

MIRAI Limited Registration number 100074 is committed to protecting your privacy and ensuring you have a positive experience when using the services we provide, which we generally refer to as Mirai Flights or Mirai services.

Scope of this Privacy Policy

This policy explains how we handle data, including what we collect and how we obtain it, how we use it, when and if we disclose it, and some of your options for managing your data with Mirai with regard to:

the services we provide at our website https:\\mirai.flights
the services we provide at our mobile app Mirai Flights for iOS and Android
our promotional and marketing campaigns

Who are we and how to contact us?

This Privacy Policy explains how personal data is processed by MIRAI Limited Registration number 100074, a company incorporated in Malta and having its registered office at Avenue 77, Block E, Level 2, Commerce Street, Zone 3, Central Business District, Birkirkara, Malta. The words “we”, “our”, “us”, refer to MIRAI Limited. Our representative in the British Economic Area is Mirai Flights UK, 79 Essex road London United Kingdom N1 2SF. You may contact it by [email protected]. Our Data Protection Officer is Evgeny Chuprov. You may contact him by [email protected].

You can contact us:

by post, to the postal address given above;
using our website support form;
by phone, on the contact number published on our website or
by email, using the email address published on our website

What data, for what purposes, how long, and based on what grounds do we process as a Controller?

Purpose of Processing	Data Subjects: Categories of Data	Storage Period	Legal Basis
to proceed your orders	Our website visitors, and service users: phone number, location data, order data (flight date, flight time, quantity of passengers, luggage, flight price, jet type), payment details (cardholder name, expiration date, card number)	5 years after the termination of a contract	processing is necessary in order to take steps at your request prior to entering into a contract We will not be able to provide you with our service if you fail to provide the data
to create an account for you	Our service users: phone number	until the termination of a contract or until the deletion of account whichever happened earlier, and within the terms specified by law
to provide you with the opportunity to edit your account	Our service users: name, surname, email- address, photo (avatar), your balance, your payment data (payment system, bank name, card number, expiration date, CVC code)	until the termination of a contract or until the deletion of account whichever happened earlier, and within the terms specified by law	processing is necessary for the performance of a contract to which you are party We will not be able to provide you with our service if you fail to provide the data
to provide the passengers that you add with our services	Passengers name, surname, date of birth, document details (type, serial number, date of issue, expiration date, issuing country), flight details (flight date, flight time, luggage, flight price, jet type, food preferences)	until the termination of a contract or until the deletion of data concerning the passengers by service users whichever happened earlier, and within the terms specified by law
to support you with various help queries received from you	Our website visitors and service users: Name, phone number, email- address, troubleshooting and support data (content of a message including files attached)	until the termination of a contract if it is concluded and within the terms necessary to resolve the problem	our legitimate interests to improve the quality of our service
to keep you up to date on the latest service announcements, software updates, upgrades, system enhancements, special offers, and other information	Our service users: phone number, email address, device information	until the termination of a contract and within the terms specified by law or until the customer unsubscribe from mailing list and (or) disables push notifications whichever happened first	processing is necessary for the performance of a contract to which you are party We will not be able to provide you with our service if you fail to provide the data
to send you direct email marketing communications about our service	Our website visitors and service users: name, email address	until you unsubscribe from our mailing list, until the end of campaign, or until the purpose of processing personal data is achieved whichever happened earlier	your consent to receive our newsletter You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you
to better understand your preferences, to help you navigate our website, to personalize and provide a more convenient experience to you, to analyze which pages you visit, and to measure advertising and promotional effectiveness	Our website visitors: IP- address, GEO (country or town), OS type and version, browser type and version, type of device and its display resolution, traffic source for the visitor, OS and browser language, which buttons are being clicked and what pages are being opened	14 months or until you withdraw your consent whichever happened earlier	your consent to store cookies in your browser You may withdraw your consent at any time by changing the settings of your web browser.

Who do we share your data with?

We have partnered with a number of authorized service providers, whose services and solutions complement, facilitate and enhance our own guarantees under written data processing agreements to ensure that the requirements of the GDPR will be met and the rights of data subjects are protected.

Should we transfer your data to third countries in the absence of an adequacy decisions regarding such countries (Kazakhstan, Russia, the USA), we also conclude the EU Standard Contractual Clauses with such recipients.

We share your data with the following recipients:

Data Recipients, their Location and the Link to Privacy Policy / Website if applicable	Purpose of Transfer
Affiliated companies (Cyprus, Kazakhstan, Malta, Russia, the UK), website	Service Providers
Airlines	Transportation Service Provider
Webim.ru LLC (Russia), Privacy Policy	Service Desk Provider
DigitalOcean, LLC (the USA), Privacy Policy	Hosting Provider
Ecommpay Limited (the UK), Privacy Policy	Payment Service Provider
Mixpanel, Inc. (the USA), Privacy Policy	Product Analytics Service Provider
Twilio Inc. (the USA), Privacy Policy	Messaging Service Provider
Severo-Zapadnaya Kompaniya “Infosvyaz” d/b/a Stream Telecom, Privacy Policy	Messaging Service Provider
Google LLC (the USA), Privacy Policy	Web Analytics Service Provider (Google Analytics, Google Tag Manager)
Yandex LLC (Russia), Privacy Policy	Web Analytics Service Provider (Yandex Metrica)

Automated decisions

We do not make any automated decisions about you that would result in legal or other similarly significant effects on you.

Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a 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.

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and thirdparty advertisers.

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

What can you do if you do not want storing cookies to be set or want them to be removed?

You are able to withdraw the consent to store cookies by changing the settings of your web browser.

You may see the cookie management instructions published by the browsers vendors at Google Chrome, Safari ( Desktop, Mobile), Firefox, Internet Explorer respectively.

We use the following cookies and tracking technologies, including cookies from our partners and service providers:

Name	Provider	Duration	Category
app_lang	https:\mirai.flights	Persistent	Unclassified
country_code
WEBIM_ENABLE

Your rights

Your rights under the GDPR are:

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

Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Amendments to this Policy

We regularly update this Policy in case there are significant changes in the way we process your personal data.

You will receive a notification prior to such significant changes become effective by email if you provided us with your email address or by pop-up notice on our website.