Privacy Policy

1. INTRODUCTION

1.1. We, TTM NETWORK LTD (“TTM”), are ready to provide our services to any user of the Internet. You can use our service via the website https://ttm.network and/or a Chromium-based web browser extension called TTM, and this Privacy Policy (“Policy”) forms an integral part of their agreement for their use.

2. GENERAL PROVISIONS

2.1. We have developed this Policy to confirm that the TTM service is in compliance with the provisions of the General Data Protection Regulation, i.e., Regulation No. 2016/679 of the European Parliament and of the Council of the European Union “On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC” (“GDPR”) and other legislative acts regulating the procedure for interaction with personal data of Internet users.

2.2. We respect your personal data. By using the TTM service, you trust us with your personal information. We do our best to ensure the security of this data and, at the same time, provide you with the ability to manage it.

2.3. Please note that the Policy applies to all personal data that you provide to us and that we collect on our own in the process of using the TTM service (including with the help of cookies).

2.4. This Policy does not apply to websites that you have accessed using hyperlinks on our website https://ttm.network.

With this Policy, we want to tell you about:

who we are;
how we work with personal data;
what personal data we collect;
what is the purpose of personal data processing;
where and why we transfer personal data;
how long we store personal data;
what rights you have as a data subject;
how we keep personal data confidential;
how to contact us.

2.5. For us, the legal basis for the processing of personal data is, in accordance with Art. 6 GDPR, separately or simultaneously:

consent to the processing of your personal data and personal data of third parties, on behalf of or in whose interests you are acting, in order to provide TTM with its service;
the need to execute a contract where you or a third party are acting as a party, on behalf of or in the interests of which you are acting;
the need, at the passenger’s request, to take actions necessary to conclude a contract with the carrier.

2.6. The processing of a special category of personal data (for example, health data) will be carried out only if there is appropriate consent to the processing of your personal data and personal data of third parties, on behalf of or in whose interests you are acting, and/or the need to provide carriers with special services related to the passenger’s health condition.

2.7. Please note that you, as a user, are solely responsible for the interaction of the Chromium-based web browser extension TTM with programs, extensions, or applications from other developers, and its consistency with their rules and policies.

2.8. We reserve the right to make changes to the Privacy Policy at any time and for any reason. The date of the last update of the Policy will be indicated in the “Last update” line at the beginning of this page.

3. PERSONAL DATA OF THIRD PARTIES

3.1. If you use the TTM service on behalf of or in the interests of third parties (for example, your customers), the information you provide about such third parties is collected and processed by TTM under the same conditions on which your personal data is processed.

4. CONSENT TO THE PROCESSING OF PERSONAL DATA

4.1. If, after registering on our website, on the page with information about the need to accept the provisions of the Privacy Policy, as well as the Terms of Use of the website/extension, you clicked the “Accept” button, or downloaded and installed an extension for the Google Chrome web browser called TTM from the Chrome web store, or signed a Partnership Agreement with us, we believe that you:

unconditionally, completely, and without any changes accept the terms of this Policy;
are notified that this website may collect your personal data and personal data of third parties on whose behalf or in the interests of which you are acting, as well as their processing using the technical capabilities of TTM;
consent to the collection and processing of all personal data provided by you for the purposes specified in this Policy;
agree to the automatic collection and transmission of data by the Chromium-based web browser extension TTM;
consent to the processing of a special category of personal data (for example, health data) regarding you or third parties on whose behalf or in whose interests you are acting, if necessary, providing special services directly related to this category of personal data;
consent to the transfer of personal data to third parties in order to fulfill the terms of the agreement and provide the appropriate TTM service;
give consent to the collection and storage of your personal data and personal data of the third parties on whose behalf or in whose interests you are acting, without restriction on validity period, until you or the third parties on whose behalf or in whose interests you are acting submit a claim or request for termination of personal data processing and/or destruction thereof, and/or until the time of termination of the relationship initiated by TTM and/or otherwise in accordance with the provisions of the Policy and requirements of the legislation.

4.2. By accepting the terms of the Policy, you confirm that you are a capable person who has reached the age of 16.

4.3. By accepting the terms of the Policy, you give your consent to the processing of your personal data and personal data of third parties, on behalf of or in the interests of which you are acting, on the terms specified in this Privacy Policy.

4.4. By providing information about third parties, you confirm that such third parties are familiar with the provisions of this Privacy Policy and provide their unconditional and complete consent to the collection and processing of personal data in accordance with the terms of this Policy.

5. PERSONAL DATA WE COLLECT AND PROCESS

5.1. We receive and store any information that you provide through the use of the https://ttm.network website, a Chromium-based extension for web browsers called TTM, inform our support team, provide TTM in any other way to the extent that is necessary to provide a service, improve the quality of such a service, and fulfill contractual obligations to you or third parties on behalf of or in the interests of which you are acting.

5.2. The above information includes:

Information that can be used to identify an individual who directly uses the TTM service, in particular, last name, first name, mobile phone number, email address, name of the employing company, and position;
Information that can be used to identify a passenger, that is, an individual who is transported by an aircraft with the consent of the carrier in accordance with the contract of carriage, and in whose name a ticket (carriage document) is issued, in particular, last name, first name, date of birth, gender, citizenship, mobile phone number, postal address, email address, mile card, loyalty card information, visa information, residence address;
ID data, for example, number and series of the passport, date of issue, expiration date;
Payment card details, including payment card number, expiration date, CVC/CVV code, and name of the payment card holder. We may store payment card data for future use; however, we do not store the CVC/CVV code of the payment card;
Technical information, including the Internet Protocol (IP) address that is used to connect to the Internet, your registration information, browser type and version, time zone, browser plug-in types and versions, operating system and platform;
Profile information (settings, search history, booking, and sales history);
Information about your visit, history of visits, and navigation around our website, history of transition from our site (including date and time), services that you viewed or searched for, page response time, loading errors, length of stay on certain pages, information activity on the page (for example, scrolling, clicks, and mouse hovering), and ways of transitions from the page;
Information we need to improve the quality of the TTM service, which is an integral part of providing the service in general, including the information that you use while working with cloud online distribution systems after logging in (if the Chromium-based browser extension named TTM is installed);
Information obtained in the process of communication with you by phone, email, through our website, social networks, support service, or in any other way;
Information that we need to conclude or execute a contract with you or third parties on behalf of or in the interests of whose you are acting;
Information about transactions with our and your participation, or the participation of third parties on behalf of or in the interests of whose you are acting;
Cookies, which are essential and without which our website cannot function, and cookies that are collected and sent to Amplitude and Intercom so that we can use their tools to improve the website’s performance;
Other information that you voluntarily leave on this site or while working with the Chromium-based web browser extension TTM.

5.3. If you do not want us to work with your personal data or the personal data of third parties on behalf of or in the interests of whose you are acting, please do not use the website https://ttm.network and/or the web browser extension on a Chromium basis called TTM and do not provide us with this information.

5.4. We do not knowingly collect personal data from persons under the age of 16, as they are prohibited from providing information on their own to receive or use our service. If we find out that the personal data was not provided by one of the child’s parents (i.e., persons under 16 years of age), a legal guardian, or a user directly authorized by them, we undertake to delete such data immediately.

6. COOKIES

6.1. Like most, we use cookies—text files containing a small amount of information that are sent to your browser and stored on the computer, mobile phone, or other device from which you visit the site.

6.2. The information provided by cookies is anonymous. We use it to simplify the use of our website and/or a Chromium-based web browser extension called TTM by recognizing the user during a visit or re-session. Cookies are essential for the proper operation of the TTM Chromium-based web browser extension.

6.3. We inform you that you can block or delete cookies, as well as restrict their action in your browser settings. The steps required to do this may vary from browser to browser. Please note that certain pages on our website and/or Chromium-based web browser extensions called TTM are only available through the use of cookies. Disabling cookies may result in restricted access to our content and inoperable website functionality and/or a Chromium-based web browser extension called TTM.

7. THE PURPOSE OF PERSONAL DATA PROCESSING

7.1. We use your personal data and the personal data of third parties, on behalf of or in whose interests you are acting, in order to provide the TTM service in full and the highest quality, in particular, but not exclusively, for the checking, preparation, issuing, or registration of any air ticket, making changes to the ticket, for the calculation and making of ticket refunds, the provision of EMD services, etc.

7.2. We may also use personal data in order to provide you with quality answers or other information from TTM based on your requests or requests from third parties on behalf of or in whose interests you are acting.

7.3. Also, the purpose of processing personal data is their use for marketing and advertising purposes, including for direct marketing, market research, and statistics.

7.4. Personal data may also be used in order to comply with the appropriate laws and regulations, including, but not limited to, checking for sanctions and other restrictions.

7.5. We also use personal data to continuously improve the TTM services and enhance your experience of using our website https://ttm.network and a Chromium-based web browser extension called TTM.

8. PERSONAL DATA TRANSFER

8.1. Your data may be transferred to third parties only for the purpose of proper rendering of TTM services, which could not have been rendered without such transfer of your personal data or the personal data of third parties on behalf of or in whose interests you are acting. For example, personal data may be transferred to carriers for the issuance of tickets (carriage documents).

8.2. We may also provide your personal data and personal data of third parties, on behalf of or in whose interests you are acting, to persons related to TTM, officials, representatives, agents, employees, or partners of TTM in order to provide their services.

8.3. TTM uses on its website:

Amplitude, a web analytics tool, which helps to understand how visitors interact with this site. Amplitude collects data such as browser type, device type, device model, location (country, city), service provider, screen resolution, time spent on the site, language, operating system, pages visited on the site, and more. Amplitude uses the information to study site usage, prepare reports on site activities, and offer other additional services. Please note that Amplitude receives your cookies and cannot work without them. You can read Amplitude’s privacy policy on their official website.
Intercom, a communication tool that helps us gather feedback from our users, answer their questions about TTM services, and provide support. Intercom processes data provided by TTM, such as email address, first name, and last name, to identify you as a user and enable communication with the support team. Intercom also uses cookies and cannot function without them. You can read Intercom’s privacy policy on their official website.

8.4. In addition, we may disclose your information:

In response to a subpoena, court order, or other legal process;
To protect against unlawful claims;
To comply with legal requirements;
If we believe it necessary to investigate or respond to illegal actions against TTM, to protect or preserve our rights, property, or the safety of TTM.

8.5. If data transfer is performed under conditions other than those set forth in this Policy, you will be notified about such transfer and will have the option to enable or disable the transfer of your personal data and personal data of third parties, on behalf of or in whose interests you are acting.

8.6. We always use the most secure and proven methods of transferring personal data.

9. CROSS-BORDER DATA TRANSFER

9.1. You agree that in order to provide the services, TTM may store and process personal data, including conducting security checks of transactions on servers and resources located outside of the European Economic Area (EEA). You give your unconditional consent to the transfer of any or all of your personal data and personal data of third parties, on behalf of or in whose interests you are acting, outside of the EEA to provide the proper level of services.

9.2. The storage and processing of your personal data and the personal data of third parties, on behalf of or in whose interests you are acting, can be carried out on servers and resources owned by TTM or independent contractors that may be located in any country in the world (e.g., USA, Canada).

9.3. By using this website and/or a Chromium-based web browser extension called TTM, you consent to the transfer of your personal data and the personal data of third parties, on behalf of or in whose interests you are acting, outside the European Union and the EEA. You agree that this data may also be transferred to the United States. All cross-border data transfers are limited to the categories of data and recipients necessary to fulfill service requests, contractual obligations, and legal requirements.

10. TERM OF PERSONAL DATA STORAGE

10.1. We store personal data for as long as it is needed for the purposes described above. This depends on the purposes of data collection and any lawful grounds for data storage (e.g., fulfilling contract terms or providing requested services). If we no longer have a reason or lawful grounds to process personal data, we will delete it or anonymize it so that it can no longer identify you.

10.2. The retention of various types of personal data depends on the following factors:

The purpose of collecting personal data;
The time needed to achieve that purpose;
Any specific legal obligations requiring retention for a specified period.

10.3. If you have a user account on our website, we will keep your personal data (e.g., email address, name, surname, employing company name, and mobile phone) as long as your account exists to enable access to our services.

10.4. When determining storage periods for personal data, we also take into account storage requirements necessary to fulfill obligations to you, third parties, and regulatory authorities, as well as accounting and tax reporting.

11. RIGHTS OF THE USER (DATA SUBJECT)

11.1. We respect your rights regarding personal data and strive to help you exercise them. You can contact TTM with a request to exercise your rights using the contact details provided below. We will process your request within a reasonable timeframe, but no later than one month from the date of receipt. This period may be extended to three months if necessary due to complexity or the volume of requests, in which case we will inform you in advance.

11.2. You can exercise the following rights:

Access information related to the processing of your personal data;
Access information within the scope of agreements between you and TTM;
Obtain an electronic copy of processed personal data;
Request clarification and/or correction of your personal data, which we will communicate to all parties with whom the data was shared unless it is impossible or requires disproportionate effort;
Request direct transfer of your personal data from TTM to third parties;
Restrict, fully or partially withdraw, your consent to the processing of personal data;
Request the destruction of your personal data in the event of withdrawn consent or if the need for processing no longer exists.

11.3. If you believe your rights or legal interests have been violated, you have the right to file a complaint with the competent authority.

12. PROTECTION OF THE CONFIDENTIALITY OF PERSONAL DATA

12.1. We implement technical, organizational, and legal measures to protect your personal data from unauthorized or accidental access, collection, storage, usage, transfer, blocking, or destruction, as well as from other unlawful actions or accidental leaks.

For example, we ensure:

Limitation and regulation of employee access to personal data;
Familiarization of employees with legislative requirements regarding personal data protection;
Monitoring and auditing of data protection measures;
Encryption and secure storage of sensitive information;
Investigation of breaches and enforcement of measures to maintain data security.

13. CONTACT US

13.1. You can contact us through the TTM support team via live chat available on https://ttm.network.

13.2. You can also send correspondence to our legal address: