Privacy Policy – Reclaim

At Reclaim, we consider privacy to be a fundamental aspect of any business activity. Our privacy statement and practices prioritize the appropriate and lawful handling of personal data, ensuring confidentiality, integrity, and availability at all times.

This Privacy Policy applies to www.reclaim.com and to our mobile application(s), owned and operated by the main operating entity of Reclaim, namely BOSC PROJECT SL, located at Calle Guillermo Cabrera, Urbanización La Reserva, 5, 2ºC, 29680, Estepona (Málaga), Spain. For the purposes of this Privacy Policy, the terms Reclaim, “we”, or “our” refer either to the group as a whole or to individual companies, as applicable.

This Privacy Policy constitutes the full online privacy policy applicable to our activities. It explains the types of information we collect, how we use, share, and protect the information you provide, and describes your options regarding the use, correction, or access to your personal data.

Your personal data is processed lawfully. Our activities are governed by applicable data privacy and data protection laws (collectively, “Data Protection Laws”) in relation to the services we provide. Depending on the context, relevant Data Protection Laws may include the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, “LGPD”), and other relevant legislation and regulations.

Reclaim acts as the data controller and determines the purposes and means of processing personal data.

Definitions

In this Privacy Policy, unless otherwise stated, capitalized terms shall have the same meaning as in our Terms and Conditions.

Personal Data

Personal data means any information relating to an identified or identifiable natural person. This includes, but is not limited to, names, dates of birth, addresses, email addresses, phone numbers, etc.

Principles

Our privacy policy is based on the following data protection principles:

Personal data shall be processed lawfully, fairly, and transparently.
Personal data shall be collected only for specific, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
Data collection shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
Personal data shall be accurate and, where necessary, kept up to date.
Inaccurate data shall be erased or rectified without delay.
Personal data shall be stored for no longer than necessary.
Personal data shall be kept confidential and stored securely.
Personal data shall not be shared with third parties unless necessary for Reclaim to provide its services under the agreement.
You have the right to request access, correction, deletion, restriction, or objection to the processing of your personal data, and data portability.

Collection and Use of Personal Data

To use our services, you may be asked to provide personal data via our website, email, other electronic or software solutions, mobile apps, post, or telephone. Data is collected in accordance with applicable laws and processed only as necessary for specific, explicit, and legitimate purposes or as required by law.

Collected data may include names, birth dates, addresses, emails, phone numbers, passport/ID numbers, etc., for the purpose of providing services such as eligibility checks, information services, compensation services, and any other agreed service.

With your explicit consent, our mobile app may automatically retrieve flight data by securely accessing your calendar and email to detect bookings, scanning entries from known online travel agencies. Reclaim remains the data controller and ensures full GDPR compliance. The legal basis is your consent (Art. 6(1)(a) GDPR), which can be withdrawn at any time. Data will be deleted when it is no longer necessary or required by law.

We may also use personal data for administrative purposes, communication, IT and physical security, support systems, and internal project coordination.

We purchase non-personal flight data from third parties, such as information on delays or cancellations. This is combined with personal data only to inform users about potential compensation eligibility. Services are provided only upon request.

If you share flight companion data with us, you must ensure they have consented under applicable regulations. You must also give them access to this policy.

We may request additional information or documents related to companions. If not provided, we will delete such data and cannot offer our services to those individuals.

Use of Personal Data

We use personal data only for the purposes for which it was collected and retain it no longer than necessary. Data access is restricted to authorized Reclaim personnel and subsidiaries bound by contractual obligations.

Automated Processing and Profiling

Reclaim does not use automated processing under Art. 22(1) GDPR for profiling. Your data will not be used for profiling unless explicitly stated and only with your consent.

We may use automated technology to enhance service quality and speed. These processes are regularly assessed to avoid unjustified impacts. Any queries can be directed to our Data Protection Officer (DPO) at: privacy@reclaim.com.

Cookies

Our website, mobile app(s), and partners use cookies or similar technologies to optimize user experience, track trends, manage the site, monitor usage, and collect demographic data.

See our Cookie Policy for full details.

Sharing of Personal Data

We share personal data with third parties only when:

You have given consent;
It is necessary to fulfill the purpose of collection;
It is required to prepare, negotiate, or fulfill a contract;
It is required by law or court order;
It is needed to protect legal claims or defend rights;
It is necessary to respond to lawful public authority requests (e.g., law enforcement);
It is essential for security or to prevent misuse or illegal activity.

We may engage partners inside or outside the EEA for legal or technical support. Where appropriate, we may use AI models (within secure infrastructure like AWS Bedrock) to improve services, under Art. 6(1)(f) GDPR, based on our legitimate interest.

We sign written agreements with third parties to safeguard data as per law. Service providers only receive data necessary for their tasks and are not permitted to market directly to our users.

If you do not wish your data shared in this context, contact our DPO at: info@reclaim.com.

Data Security

Your data’s security is important to us. We apply appropriate technical and organizational measures to prevent unauthorized access, accidental loss, or unlawful processing. Queries regarding data security may be sent to: info@reclaim.com.

Your Data Protection Rights

You have the right to access, rectify, delete, restrict, or object to the processing of your personal data, and the right to data portability. Please inform us of any changes to keep your information accurate.

Contact our DPO at info@reclaim.com for any such requests. We will respond within a reasonable time.

Job Applications

Applications are managed through a third-party tool. Reclaim acts as data controller for applicant data and does not retain it longer than necessary. For access, correction, or deletion of application data, contact: info@reclaim.com.

Marketing Preferences

We may send marketing emails if you have given explicit consent. You can withdraw consent at any time, at no cost, by using the unsubscribe link in emails or contacting us at info@reclaim.com.

We work with external partners to display ads on our website and on social media, using cookies to tailor ads to your interests. You may opt out of interest-based advertising but may still see generic ads.

Responsibility

Our legal team oversees compliance with this Privacy Policy, with the DPO monitoring all personal data matters. Reclaim complies with Data Protection Laws and maintains a record of processing activities available to authorities upon request.

All privacy queries should be directed to: info@reclaim.com

Complaints

You have the right to file a complaint regarding the processing of your personal data. Complaints will be handled promptly by our DPO. If you believe your data is being processed unlawfully, you may also lodge a complaint with the relevant data protection authority.

Changes to this Policy

We may update this policy as needed, for example, due to legal changes or organizational updates. Significant changes will be communicated by email or via our website. Please review this page regularly.

Contact

Reclaim
BOSC PROJECT SL
Calle Guillermo Cabrera, Urbanización La Reserva, 5, 2ºC
29680, Estepona (Málaga), Spain
Email: info@reclaim.com

Last updated: June 28, 2025
Version: PP1