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Tomo

Privacy Policy

1. Data Controller

The data controller for personal data processed through this service is Altitudes Group B.V., trading as Tomo Flight Claim, registered with the Netherlands Chamber of Commerce (KVK) under number 93488432, with its registered office at Weezenhof 6745, 6536 BG Nijmegen, the Netherlands. For privacy matters, contact privacy@tomoclaim.com.

2. Data We Collect

We collect the following personal data:

  • Full name and email address (account registration)
  • Flight details and booking references (claim assessment)
  • Correspondence with airlines (claim management)
  • Payment details (settlement processing)

3. Purpose of Processing

We process your data to assess and pursue your EU261/2004 compensation claim, communicate with airlines on your behalf, and transfer compensation payments to you.

4. Legal Basis

We process your data based on the contractual necessity of fulfilling our service agreement (GDPR Article 6(1)(b)).

5. Data Retention

We retain claim data for 3 years after claim resolution, in line with the limitation period for EU261/2004 claims. Account data is retained until you request deletion.

Marketing attribution data (the source, campaign and referring website through which you reached us) is stored with your claim and deleted 90 days after your claim is paid, rejected or withdrawn; aggregated counts per source are kept. Attribution stored with an unfinished claim check is deleted 90 days after your last activity.

6. Your Rights

Under GDPR, you have the right to:

  • Access your personal data
  • Rectify inaccurate data
  • Request erasure of your data
  • Restrict processing
  • Data portability
  • Object to processing
  • Lodge a complaint with a data protection supervisory authority

If you believe we process your personal data unlawfully, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), autoriteitpersoonsgegevens.nl, or with the supervisory authority in your EU country of residence.

7. Third Parties

We share your data with airlines (to pursue your claim) and with the following processors, who act only on our instructions under data processing agreements: Amazon Web Services (Amazon SES) for email delivery and infrastructure hosting, bunq for processing compensation payouts, and Plausible Analytics for privacy-friendly website statistics (Plausible itself sets no cookies). Tomo Growth Engine (operated by us) receives pseudonymous conversion events — a hashed claim identifier, the source and campaign, and the expected or paid fee — never your name, e-mail address or flight details. We do not sell your data to third parties.

8. Cookies

We use two first-party cookies for attribution. tc_attr (30 days) records the source, campaign and referring website through which you first and most recently reached our flight check, so we can learn which publications actually help travellers; it is set only on the flight-check landing page and when you save your progress in the claim wizard, it contains no personal data, is not shared with third parties and has no effect on the service you receive. ref (30 days) is set only when you arrive through a partner link and is needed to deliver the service requested via that partner; it does not change your fee. If your browser sends the Global Privacy Control signal we do not set tc_attr. Functional cookies (session_id for your login, NEXT_LOCALE for your language) are strictly necessary. We do not use advertising or tracking cookies of third parties.

9. Contact

For privacy inquiries, contact us at privacy@tomoclaim.com.