BUSOLA.ai Privacy Notice

1. Data Controller

BUSOLA.ai is currently operated by Mert Berberoglu, acting in an individual capacity as the personal data controller.

BUSOLA.ai is not currently operated through a separate legal entity.

For any question or request concerning your personal data, you may contact the controller using the details above.

2. Personal data we may process

Depending on how you use BUSOLA.ai, we may process:

• travel-request information, including destination, departure airport, travel dates, date flexibility, budget and travel preferences;
• number of adults and children's ages where relevant;
• free text that you choose to enter;
• email address or other contact information where you voluntarily provide it;
• your choice regarding whether BUSOLA may contact you;
• technical and security information necessary to operate and protect the service and prevent abuse;
• structured and aggregated information used to understand travel demand and improve BUSOLA.ai.

The current BUSOLA request flow does not ask for payment-card details, passwords, passport numbers or identity-document information.

Please do not enter unnecessary sensitive personal information into free-text fields.

3. Purposes

We process information in order to:

• record and understand your travel request;
• develop and improve BUSOLA.ai;
• evaluate demand for travel destinations and services;
• protect the platform and prevent abuse;
• contact you about your request when you have chosen to allow us to do so;
• comply with applicable legal obligations.

4. Legal basis

For the operation, security and improvement of BUSOLA.ai and for structured travel-demand analysis, we currently rely primarily on our legitimate interests under Article 6(1)(f) GDPR.

Where you expressly agree that BUSOLA may contact you, processing of your contact information for that purpose is based on your consent under Article 6(1)(a) GDPR.

You may withdraw contact consent at any time.

5. Retention

Original free-text request content (rawInput) is retained for no longer than 30 days, after which it is removed/redacted under BUSOLA's operational retention policy.

Structured travel-request data may be retained for as long as necessary for product validation, demand analysis, service security and applicable legal requirements. Its continued necessity will be reviewed periodically, after which it will be deleted or anonymised when it is no longer required.

Contact information provided on the basis of consent will be retained only for as long as necessary for the requested communication or until consent is withdrawn, unless a legal retention obligation applies.

6. Recipients

BUSOLA.ai does not sell personal information.

Personal data may, where necessary, be processed by categories of technical providers such as hosting and infrastructure providers, email/communications providers, and security or operational service providers.

BUSOLA.ai does not currently transmit personal data automatically to travel suppliers.

If BUSOLA later sends personal information to a travel supplier in order to facilitate an offer, handoff or booking journey, the privacy notice will be updated and appropriate information will be provided before that transfer.

7. International transfers

BUSOLA.ai's principal application infrastructure and database are hosted in the European Union.

If a technical provider involves processing outside the EEA, any transfer will take place only using an appropriate GDPR transfer mechanism.

8. Your rights

Subject to GDPR conditions, you may have the right to:

• access your personal data;
• correct inaccurate data;
• request deletion;
• request restriction of processing;
• object to processing based on legitimate interests;
• request data portability where applicable;
• withdraw consent at any time;
• lodge a complaint with a data-protection supervisory authority.

Requests may be sent to mert@busola.ai.

9. Supervisory authority

10. Automated decisions

BUSOLA.ai does not currently perform automated decision-making that produces legal effects or similarly significant effects concerning users.

11. Changes

This notice may be updated as BUSOLA.ai introduces new functionality, suppliers or integrations. The current version will be published on BUSOLA.ai.