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Privacy Policy

Version of 11 August 2026

This is a translation of the Ukrainian original for convenience. In case of any discrepancy, the Ukrainian text prevails.

Contents

This Policy is an integral part of the Public Offer of the platform www.apl.travel.

It explains what personal data the Platform collects, for what purpose and on what legal basis it processes that data, to whom it is disclosed and what rights the User has. Processing is carried out in accordance with the Law of Ukraine «On Personal Data Protection», and for Users in the EU in accordance with the General Data Protection Regulation (GDPR).

1. Data controller

The controller of personal data is individual entrepreneur Anastasiia Latko (tax ID 3214019927). Contact for data-processing matters: cc@apltravel.com.ua.

2. What data we collect

  • Provided by the User: email address (required for registration) and the information the User gives in the conversation and in their profile (travel preferences, who is travelling and so on).
  • Payment data: processed directly by the payment service (WayForPay). The Platform does not store full card details.
  • Usage data: the history of requests and interaction with the AI agent, from which the profile is passively enriched for a more precise selection; the balance and history of Connect charges.
  • Technical data: IP address, device and browser type, cookies, data from analytics tools.

3. Purposes and legal bases for processing

  • Providing access to the Platform and its features — basis: performance of the contract with the User.
  • Personalisation and selection of travel products (including passive profile enrichment) — basis: performance of the contract and the controller’s legitimate interest.
  • Analytics and improvement of the service — basis: legitimate interest and the User’s consent (for analytics cookies).
  • Meeting accounting and tax obligations — basis: compliance with the law.
  • Communication and support (email, Telegram bot) — basis: performance of the contract.

4. Cookies and analytics tools

4.1. The Platform uses cookies and third-party analytics tools: Google Analytics, Meta Pixel and Hotjar — to analyse traffic and user behaviour and to improve the service.

4.2. Analytics and marketing cookies are set only with the User’s consent, given through the consent banner on the first visit. Consent can be withdrawn in the browser settings or in the banner.

4.3. Technical cookies necessary for the Platform to work (authentication, keeping the session) are set without separate consent, because the service does not function without them.

5. Disclosure to third parties

The Platform discloses personal data only to the extent necessary to provide the service, to the following categories of recipients:

  • APL TRAVEL LLC (the Booking Partner) — when the User moves to booking, the history of their requests and the contact details needed to arrange travel services are passed on.
  • The payment service (WayForPay) — to process payments for Connects.
  • Communication and support services (HelpCrunch, Telegram) — to handle enquiries.
  • Analytics providers (Google, Meta, Hotjar) — anonymised or technical data for analytics.

The Platform does not sell personal data to third parties.

6. Cross-border transfers

Some providers (Google, Meta, Hotjar) may process data on servers outside Ukraine and the EU, including in the United States. Such transfers are made with appropriate safeguards (standard contractual clauses or an adequacy decision).

7. Retention period

Personal data is kept until the User deletes their account. Data required to meet accounting and tax obligations is kept for 3 (three) years after the account is deleted, as required by law. After those periods the data is deleted or anonymised.

8. The User’s rights

The User has the right to: know that their data is being processed; obtain access to it; require that inaccurate data be corrected; require erasure (the «right to be forgotten»); restrict processing and object to it; data portability; withdraw consent previously given; lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights, and for people in the EU with the relevant supervisory authority. To exercise these rights the User writes to cc@apltravel.com.ua; a reply is given within the period established by law.

9. Data security

The controller takes organisational and technical measures to protect personal data from unauthorised access, loss or disclosure, including encryption of transmission channels and restricted employee access.

10. Data of minors

The Platform is intended for persons aged 18 and over and does not knowingly collect data of minors. If such data is discovered, it is deleted.

11. Changes to this Policy

The controller may update this Policy by publishing a new version on the Platform. Continuing to use the Platform after publication means the User has been made aware of the changes.

12. Contacts

Name
Individual entrepreneur Anastasiia Latko
Tax ID
3214019927
Address
3A Baseina St., office 47, Kyiv, 01004, Ukraine
Phone
+380443927425
Email
cc@apltravel.com.ua
Platform
www.apl.travel