Privacy Policy & Cookie Declaration

1. Who We Are

FairFerry OÜ
Sepapaja tn 6
15551 Tallinn, Estonia

Email: legal@fairferry.eu
Registry Code: 17337821
Spanish Tax Identification Number (N.I.F.): Not yet assigned

For any questions about how your personal data is processed or to exercise your data protection rights, contact us at: legal@fairferry.eu

FairFerry is a digital service that helps ferry passengers claim compensation for delayed or cancelled ferry journeys under Regulation (EU) No 1177/2010. We act as your representative in pursuing these claims on your behalf.

2. What Data We Collect

We collect only the data necessary to review and process your claim, including:

Contact Data

• Name
• Email address
• Phone number (optional)
• Copy of ID/passport

Travel and Claim Data

• Ferry route, operator, travel date
• Planned and actual arrival time
• Delay or cancellation details
• Ticket price
• Uploaded tickets or booking confirmations

Technical Data (Essential)

• IP address
• Browser and device type
• Technical logs required to operate and secure our platform

We do not request or store identity documents. We do not use analytics, advertising, or social media tracking.

3. Purpose of Processing

We process personal data for the following purposes:

• Review eligibility under Regulation (EU) No 1177/2010
• Assess, prepare, and pursue compensation claims
• Communicate with you regarding your claim
• Send essential transactional emails
• Escalate claims where required
• Comply with legal obligations

We do not sell personal data and do not send marketing communications.

4. Legal Basis (GDPR)

Processing is based on:

• Art. 6(1)(b) GDPR – performance of a contract or pre-contractual measures
• Art. 6(1)(c) GDPR – compliance with legal obligations
• Art. 6(1)(f) GDPR – legitimate interests in operating and securing our service

5. Data Processors

We work with trusted processors, including:

• Supabase – database and authentication
• Vercel – hosting and edge delivery
• ZohoSign – electronic signing of the Assignment Agreement
• ZeptoMail – transactional email delivery
• Xolo OÜ – administrative and accounting services

Processors receive only the data necessary to perform their services and are bound by data processing agreements in accordance with Article 28 GDPR.

6. International Transfers

Data may be processed within the EU or the United States. Transfers to countries outside the European Economic Area are safeguarded through:

• the EU–US Data Privacy Framework, or
• Standard Contractual Clauses approved by the European Commission.

7. Retention Period

• Claim-related data: up to five (5) years from the conclusion of the claim or the last contact with the data subject, whichever is later
• Communication data: until claim completion or deletion request
• Identity documents: not collected

Data is securely deleted or anonymised when no longer required for the purposes stated in this policy, unless retention is required by law.

8. Your Rights

You have the right to:

• Access and rectify your data
• Request deletion or restriction
• Object to processing
• Request data portability
• Lodge a complaint with a supervisory authority

To exercise any of these rights — including requesting deletion of your account and associated data — email us at legal@fairferry.eu. We respond within 30 days as required by GDPR Article 12(3).

Supervisory authority: Agencia Española de Protección de Datos (AEPD)
Address: C/ Jorge Juan, 6 — 28001 Madrid
Telephone: 900 293 183
Website: www.aepd.es

9. Data Security

We use encrypted connections, secure servers, access controls, and monitoring measures to protect your data.

10. Updates

We may update this Policy to reflect legal or operational changes. The latest version is always available on our website.

Cookie Declaration

FairFerry uses only essential cookies required for the operation of the platform. No analytics, advertising, or social-media cookies are used. No cookie banner is required.