Last Updated: 21/03/2026
Introduction
Welcome to ComforTravel LLC (“we,” “us,” or “our”). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile applications, and AI-powered services to search for flights, hotels, and attractions across the world.
It sets out the personal data which we will or may collect about you, how and why we collect, store, use and share your personal data, in addition to your rights and how the law protects you. That said, it contains important information and we encourage you to read it carefully.
Personal information may be held by us on paper or in electronic format. We are committed to being transparent about how we handle your personal information, to protecting the privacy and security of your personal information and to meeting our data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this Privacy Notice is to make you aware of how and why we will collect and use your personal information. We are required under the GDPR to notify you of the information contained in this Privacy Notice.
This Privacy Notice sets out, in line with GDPR, the types of data that we collect and hold on. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This policy applies to all visitors and users of our services. By using our services, you agree to the terms of this Privacy Policy.
Data protection principles
Under the GDPR, a data controller decides why and how personal data is processed, while a data processor handles data strictly on the controller’s instructions. In our business model, we act as the data controller by determining the purposes and means of processing customer information to deliver travel search and booking services. Our third-party partners—such as flight, hotel, or analytics providers—act as data processors, processing personal data only as needed to support our services and always under our direction
We will comply with Data Protection Laws, which says that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.
Information We Collect
We collect information to provide and improve our services. The types of information we collect include:
Contact Information: Name, email address and other contact details you provide when registering or contacting us.
Travel Preferences: Information about your travel interests, destinations, dates, and other preferences.
Booking and Payment Information: If you make a booking through our services, we may collect payment details, passport information, and other relevant travel documentation.
Technical Data: IP address, device information, operating system, and usage data collected through cookies and similar technologies.
Communication Data: Information you provide when you contact our support team or use our AI-powered services, including chat logs and feedback.
Third-Party Inventory & Service Data: We do not own or maintain our own inventory of travel products (e.g., hotel rooms, airline seats, car rentals, tours, etc.). Instead, we receive real-time availability, pricing, and policy information from our trusted partners (such as airlines, hotels, tour operators, global distribution systems, and API providers) for the following purposes:
Display & Search: To show you the most up-to-date options and prices when you search.
Booking & Fulfillment: To place reservations on your behalf and send you confirmations, tickets, or vouchers.
Status Updates: To notify you of any changes (e.g., cancellations, amendments, refunds) initiated by either you or the partner.
Analytics & Improvement: To power aggregated, anonymized insights that help us optimize search results and recommend better offers.
Legal Basis: We process this data as necessary to perform our contract with you (booking travel services) and under our legitimate interest in providing and improving our offerings.
Data Security & Retention: All third-party data is transmitted over secure channels (e.g., HTTPS), stored only as long as needed to fulfill your booking (up to 90 days after service completion, unless otherwise required by law or partner agreement), and is accessible for correction or deletion upon your request.
Location Data: When you use the map or navigation features within our app, we collect your device's precise location data for the following purposes:
ar rentals, tours, etc.). Instead, we receive real-time availability, pricing, and policy information from our trusted partners (such as airlines, hotels, tour operators, global distribution systems, and API providers) for the following purposes:
Turn-by-Turn Navigation: To provide real-time driving, walking, or cycling directions to your selected destinations using the Google Navigation SDK.
Map Display: To show your current position on the map and help you find nearby points of interest and plan routes.
Route Planning: To calculate distances and estimated travel times between your current location and planned destinations.
Location data is collected only while you actively use the map or navigation features. The app may continue to access your location briefly in the background during an active navigation session to ensure uninterrupted turn-by-turn directions. We do not store your location history on our servers or sell your location data to third parties. Location data is shared with Google Maps services solely to provide navigation and mapping functionality.
3. How We Use Your Information
We use your information for the following purposes:
Providing Services: To deliver, maintain, and improve our AI-powered travel search and booking services.
Personalization: To tailor search results, recommendations, and offers based on your preferences and behavior.
Customer Support: To respond to your inquiries, provide support, and resolve issues.
Analytics and Improvement: To analyze usage trends, monitor service performance, and develop new features.
Marketing: To send you relevant travel offers, updates, and promotional materials, subject to your preferences and applicable laws.
Compliance: To comply with legal obligations and protect the rights and safety of our users and company.
Navigation: To provide real-time turn-by-turn navigation and location-based map features using your device's GPS data.
These reasons are underpinned by a “legal basis” under the GDPR, further details of which can be found below.
In the event that you work with us in another way – for instance, enrol in a specific event, program, apply for a position, or are a member of staff, there may be a separate Privacy Policy which describes why we collect and how we use that data.
Data retention
We generally do not retain your personal data. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Details of retention periods for different aspects of your personal information are available upon request.
To determine the appropriate retention period for personal data, we consider:
The amount, nature and sensitivity of the personal data.
The potential risk of harm from unauthorised use or disclosure of your personal data.
The purposes for which we process your personal data and whether we can achieve those purposes through other means.
The applicable legal requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you. Once you are no longer a customer, employee, worker, volunteer or contractor of the Company, we will retain and securely destroy your personal information in accordance with our Data Retention Policy.
How we collect personal data
Account Registration: When you create an account or profile on our platform, you provide personal information such as your name, email address, and contact details.
Booking and Reservations: When you search for or book flights, hotels, or attractions, you may provide information such as travel dates, destinations, payment details, and passport information.
Customer Support: When you contact our support team via email, chat, or phone, we collect information related to your inquiry and any additional details you provide.
Feedback and Surveys: If you participate in surveys, reviews, or provide feedback, we collect the information you submit.
Usage Data: We automatically collect information about your interactions with our website and mobile applications, such as IP address, device information and operating system.
Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to collect data about your use of our services, preferences, and to personalize your experience. You can manage your cookie preferences through your browser settings.
Third-Party Partners and APIs: We may receive information about you from third-party service providers, such as airlines, hotels, payment processors, and travel partners, as necessary to fulfill your bookings and enhance our services.
Social Media and Connected Accounts: If you choose to connect your social media accounts or use third-party authentication (such as Google or Facebook), we may collect information as permitted by your privacy settings on those platforms.
AI-Powered Services: Our AI systems may analyze your search history, preferences, and interactions to generate recommendations and personalize your experience.
Sharing Your Information
We may share your information in the following circumstances:
Third-Party Service Providers: We partner with third-party APIs and service providers to deliver our travel search and booking services. These partners may process your information on our behalf, but only as necessary to fulfill your requests.
Travel Partners: When you make a booking, we may share your information with airlines, hotels, and other travel providers to complete your reservation.
Legal Requirements: We may disclose your information if required by law, regulation, or legal process.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.
International Transfer of Personal Data
We may share your personal information with recipients located in the following jurisdictions, as necessary to provide our services and fulfill our contractual obligations:
European Economic Area (EEA)
United States
United Kingdom
Ukraine
Other third countries where our service providers, partners, or cloud hosting solutions operate
These transfers may occur, for example, when we use third-party service providers, partners, or cloud hosting solutions located in different countries. To ensure that your personal data remains protected when transferred internationally, we implement one or more of the following safeguards in accordance with applicable data protection laws:
Adequacy Decisions: Where a country has been officially recognized as providing an adequate level of data protection, we may transfer your data to organizations in those countries without additional safeguards.
Standard Contractual Clauses (SCCs): For transfers to countries without an adequacy decision, we use approved Standard Contractual Clauses to ensure your data is protected to a high standard.
EU-US Data Privacy Framework (DPF): For transfers to certified organizations in the United States, we may rely on the EU-US Data Privacy Framework, which provides recognized data protection safeguards.
Binding Corporate Rules (BCRs): Where applicable, we may use Binding Corporate Rules that govern transfers within our corporate group.
Other Legal Mechanisms: In specific cases, we may rely on your explicit consent, the necessity of the transfer for the performance of a contract, or other legal grounds as permitted by law.
Data Security
We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction.
We take the security of your personal data seriously and have established robust procedures to detect, respond to, and document any personal data breaches. If a data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach. If the breach poses a high risk to you, we will also inform you promptly. All breaches are thoroughly documented, including the facts, impact, and remedial actions taken, in accordance with applicable data protection laws.
Your Rights and Choices
You have various rights regarding the personal information we hold about you. These rights may include:
Accessing your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a Subject Access Request for access free of charge by contacting us via email, by telephone, or through the contact form on our website.
Changing consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time. You can withdraw consent by contacting us via email, by telephone, or through the contact form on our website.
The right to erasure: You have the “right to be forgotten” by asking us to delete your personal information where it is no longer necessary for us to use it, after you have withdrawn consent, or where we have no lawful basis for keeping it. To do so, please contact us via email, by telephone, or through the contact form on our website.
A right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. You can contact us via email, by telephone, or through the contact form on our website.
A right to rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you by contacting us by email, telephone or website form.
Preventing automated decision-making: You can ask that we no longer process your data automatically to decide whether particular marketing activities are likely to be of interest, or recommending destinations or offers based on your previous searches recommending destinations or offers based on your previous searches. This is known as profiling, and helps us to ensure that our marketing is relevant and appropriate. We do not currently carry out any automated decision-making.
Regulatory and Contact Information for Complaints
If you have concerns about how we process your personal data or wish to lodge a complaint, you may contact us directly or reach out to the relevant data protection authorities listed below.
Authority / Contact Point
Jurisdiction / Purpose
Contact Details
ComforTravel LLC Data Protection Officer (DPO)
Company DPO / All queries
Illia Shkurenko
Email: illiatict@gmail.com
Phone: +380686897387
Ukrainian Parliament Commissioner for Human Rights
Ukraine
European Data Protection Board (EDPB)
EU-wide guidance
Your Local EU Data Protection Authority
EU Member State
https://edpb.europa.eu/about-edpb/about-edpb/members_en
UK Information Commissioner’s Office (ICO)
United Kingdom
US Federal Trade Commission (FTC)
United States
Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the updated policy on our website or through other communication channels.
Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us by email support@tictglobal.com.