Privacy Policy

Farel, Inc. (“Farel”, “we”, “us”, or “our”) respects privacy and is committed to protecting personal information. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you:

• visit our website at farel.io and related websites;
• request a demo, contact us, attend an event, or otherwise communicate with Farel;
• use Farel products and services as an authorized user of an airline or other business customer; or
• interact with communications and other functionality provided through the Farel platform on behalf of one of our customers.

If you have questions about this Privacy Policy or our privacy practices, you may contact us at partners@farel.io.

1. Scope of This Privacy Policy

Farel provides software and technology services to airlines, including reservation, passenger-service, operational, communications, and related functionality.

Our role with respect to personal information depends on the context.

When Farel acts as a controller

Farel generally determines the purposes and means of processing when we process personal information relating to:

• visitors to farel.io;
• prospective customers and partners;
• Farel customers’ business contacts and account administrators;
• people who communicate directly with Farel;
• sales, marketing, recruiting, security, billing, and corporate administration.

In these situations, Farel generally acts as the controller or business responsible for the personal information.

When Farel acts on behalf of an airline customer

When an airline uses the Farel platform to manage reservations, passengers, flights, communications, or related services, the airline generally determines why and how its passenger and customer information is processed.

In those circumstances, Farel generally acts as a processor, service provider, or similar contracted data-processing entity on behalf of that airline.

The airline’s own privacy policy applies to its collection and use of passenger information. Questions or requests concerning information that Farel processes solely on behalf of an airline should generally be directed to that airline. Where appropriate, we may forward a request to the relevant airline or assist the airline in responding.

2. Personal Information We Collect

The information we process depends on how you interact with Farel and which Farel services are being used.

Information you provide directly to Farel

We may collect information such as:

• name;
• business email address;
• telephone number;
• company or organization;
• job title;
• account credentials;
• demo or sales-request information;
• support requests;
• correspondence and communications with Farel;
• information submitted through forms, surveys, events, or meetings;
• any other information you choose to provide.

Website and device information

When you use our websites or online services, we may automatically collect information such as:

• IP address;
• browser type;
• device type and characteristics;
• operating system;
• referring URLs;
• pages viewed;
• timestamps;
• approximate location derived from IP address;
• cookie and similar technology identifiers;
• usage, diagnostic, performance, and security information.

Information processed through the Farel airline platform

At the direction of our airline customers, Farel may process information associated with airline reservations, passengers, flights, and customer service, including:

• passenger name and contact information;
• telephone number and email address;
• reservation and booking identifiers;
• itinerary, route, flight, and travel information;
• booking status and travel history;
• passenger preferences and service requests;
• check-in and operational information;
• purchased services and ancillary products;
• payment-related transaction information, subject to applicable security and payment-processing requirements;
• customer-service interactions;
• information required by an airline to provide transportation or related services.

The exact categories of information depend on the airline, the services it enables, and the nature of the passenger’s journey.

Communications and messaging information

Where Farel or an airline customer enables business messaging functionality, including WhatsApp, we may process:

• telephone numbers;
• WhatsApp Business account and phone-number identifiers;
• sender and recipient information;
• message content;
• message attachments and media;
• message timestamps;
• message identifiers;
• replies and conversation context;
• delivery, read, failure, and other message-status information;
• information used to associate a conversation with an authorized user, customer, passenger, reservation, or business record.

For Farel’s own business communications, messages sent or received by authorized Farel personnel through connected business messaging services may also be synchronized with Farel’s customer relationship management systems.

Authentication and security information

Where authentication functionality is enabled, we may process information necessary to send and validate authentication or verification communications, such as:

• telephone number or other destination identifier;
• verification request and delivery information;
• authentication status;
• timestamps;
• fraud, abuse, and security signals.

Authentication codes are processed only as necessary to provide and secure the relevant authentication service and are subject to appropriate security controls.

3. Sources of Personal Information

We may receive personal information:

• directly from you;
• from our airline and other business customers;
• when you use Farel products or websites;
• from authorized users of customer accounts;
• from communications providers;
• from Meta and WhatsApp where WhatsApp functionality is enabled;
• from payment, infrastructure, analytics, security, and other service providers;
• from business partners;
• from publicly available business sources where permitted by law.

4. How We Use Personal Information

Depending on the context and our role, we may process personal information to:

Provide and operate Farel services

• operate, maintain, and improve the Farel platform;
• provide reservation, passenger-service, flight, operational, and related functionality;
• authenticate authorized users;
• manage customer accounts;
• provide support;
• diagnose technical problems;
• maintain availability, reliability, and security.

Provide passenger communications on behalf of airlines

At an airline customer’s direction, Farel may facilitate communications including:

• booking confirmations;
• reservation updates;
• payment or transaction confirmations;
• authentication and verification codes;
• flight schedule changes;
• delays;
• cancellations;
• check-in notifications;
• boarding, gate, terminal, or other operational updates;
• customer-service communications;
• other transactional or service-related passenger notifications.

Where supported, passengers may also reply to messages or interact with the airline through the same channel.

Provide business messaging and CRM functionality

We may process communications to:

• send and receive authorized business messages;
• route messages to the appropriate representative or customer;
• maintain conversation history;
• synchronize communications with customer-management systems;
• provide delivery and read-status information;
• support customer service;
• maintain continuity when responsibility for a business relationship changes.

Security and fraud prevention

We may use information to:

• protect accounts and systems;
• authenticate users;
• detect fraud or abuse;
• investigate suspicious activity;
• prevent unauthorized access;
• enforce applicable terms and policies;
• protect Farel, our customers, passengers, and others.

Analytics and product improvement

We may use appropriate information to:

• understand how our products and websites are used;
• measure performance and reliability;
• improve user experience;
• develop and improve functionality;
• troubleshoot errors;
• analyze aggregate service trends.

Where Farel processes customer data as a processor, such activities are performed subject to our agreements with the relevant customer and applicable law.

Business communications and marketing

For business contacts, we may use information to:

• respond to inquiries;
• arrange demonstrations;
• manage commercial relationships;
• send product, service, administrative, or event information;
• send marketing communications where permitted by law.

You may opt out of Farel marketing emails using the unsubscribe mechanism in the message or by contacting us.

Legal and corporate purposes

We may process information where necessary to:

• comply with law;
• respond to lawful requests;
• establish or defend legal claims;
• enforce contracts;
• complete audits;
• satisfy accounting, tax, regulatory, or compliance requirements;
• evaluate or complete a merger, financing, acquisition, reorganization, sale, or similar corporate transaction.

5. WhatsApp and Meta Platform Data

Farel may integrate with the WhatsApp Business Platform and other Meta services to provide messaging capabilities for Farel and our airline customers.

When an airline connects its WhatsApp Business account to Farel, the airline authorizes Farel to access the WhatsApp business assets and information necessary to provide the requested service.

Depending on the enabled functionality, Farel may use Meta Platform Data to:

• connect an airline’s WhatsApp Business account to Farel;
• identify authorized WhatsApp Business accounts and telephone numbers;
• send messages requested by the airline;
• receive passenger or customer replies;
• receive messages sent through supported WhatsApp Business interfaces;
• monitor sent, delivered, read, and failed message status;
• manage or synchronize approved message templates;
• display communication history and status within Farel;
• troubleshoot and secure the messaging integration.

Farel uses Meta Platform Data only for legitimate purposes related to providing, securing, supporting, and improving the services authorized by the relevant business.

Farel does not use passenger WhatsApp message content obtained on behalf of an airline for Farel’s independent advertising or to build advertising profiles across different airline customers.

Use of WhatsApp is also subject to applicable WhatsApp and Meta terms and privacy practices.

Airline customers are responsible for ensuring that communications they initiate through Farel comply with applicable law and applicable WhatsApp requirements, including any notice, consent, or opt-in requirements.

6. Legal Bases for Processing

Where the European Economic Area, United Kingdom, or another jurisdiction requires a legal basis for processing, Farel may rely on one or more of the following when acting as a controller:

• Contract: processing necessary to enter into or perform a contract;
• Legitimate interests: processing necessary for legitimate business purposes, including operating, securing, supporting, and improving our services and managing business relationships;
• Consent: where you have given consent for a specific activity;
• Legal obligation: where processing is required to comply with applicable law;
• Protection of rights and safety: where necessary to protect individuals, Farel, our customers, or others.

Where Farel acts as a processor for an airline or other customer, the customer is generally responsible for determining the lawful basis for its processing of personal information.

7. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients where appropriate.

Farel customers

Where we provide services on behalf of an airline or other customer, information may be available to authorized personnel of that customer.

Service providers and subprocessors

We may use service providers for functions such as:

• hosting and cloud infrastructure;
• communications and messaging;
• payment processing;
• security;
• monitoring;
• analytics;
• customer support;
• authentication;
• email delivery;
• data storage;
• professional services.

These providers may process personal information only as necessary to provide services to Farel, subject to applicable contractual and legal requirements.

Meta and WhatsApp

Where WhatsApp functionality is used, relevant information is transmitted to and received from Meta and WhatsApp as necessary to provide messaging services.

Professional advisers

We may disclose information to auditors, lawyers, accountants, insurers, and other professional advisers where reasonably necessary.

Legal and regulatory authorities

We may disclose information where we reasonably believe disclosure is required by law or necessary to:

• comply with legal process;
• respond to lawful governmental requests;
• investigate fraud or security incidents;
• protect legal rights;
• protect the safety of users or others.

Corporate transactions

Information may be disclosed or transferred in connection with a merger, financing, acquisition, restructuring, bankruptcy, sale of assets, or similar corporate transaction.

8. Sale and Advertising Use of Personal Information

Farel does not sell personal information.

Farel does not share personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. state privacy laws.

We do not use airline passenger information processed on behalf of our customers to independently advertise Farel products to those passengers.

9. Cookies and Similar Technologies

We use cookies and similar technologies on our websites to:

• operate website functionality;
• maintain security;
• remember preferences;
• understand website usage;
• measure performance;
• improve our website and services.

Where required by law, we obtain consent before using non-essential cookies.

You may be able to manage cookies through browser settings or other controls made available on our website.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to satisfy contractual, legal, accounting, security, and regulatory requirements.

Retention depends on the context.

Customer and passenger data

Where Farel processes information on behalf of an airline or other customer, retention is generally determined by:

• the customer’s instructions;
• the applicable customer agreement;
• the nature of the service;
• applicable legal requirements.

Farel-controlled information

Where Farel acts as controller, we retain information for as long as reasonably necessary for the relevant business purpose and applicable legal obligations.

When information is no longer required, we delete, anonymize, or otherwise securely dispose of it.

Where immediate deletion from backup or archival systems is not technically feasible, information may remain securely isolated until it is overwritten or otherwise deleted in accordance with our retention practices.

11. International Data Transfers

Farel and our service providers may process information in countries other than the country where the information was originally collected.

Where required, we use appropriate safeguards for international transfers of personal information, which may include contractual protections such as approved standard contractual clauses or other legally recognized transfer mechanisms.

Where Farel acts as a processor, international transfers are also governed by our agreements with the relevant customer.

12. Security

Farel uses technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include, as appropriate:

• access controls;
• authentication;
• encryption;
• network and infrastructure security;
• logging and monitoring;
• vulnerability management;
• secure software-development practices;
• incident-response processes;
• employee and contractor access restrictions.

No system can guarantee absolute security, but we continually evaluate and improve our safeguards based on the nature of the information and the risks involved.

13. Your Privacy Rights

Depending on where you live and applicable law, you may have rights including:

• access to personal information;
• correction of inaccurate information;
• deletion;
• restriction of processing;
• objection to processing;
• withdrawal of consent;
• data portability;
• information concerning how personal information is processed;
• the right to lodge a complaint with a data-protection authority.

Where Farel is the controller, you may submit a request to partners@farel.io.

We may need to verify your identity before fulfilling certain requests.

Passenger or airline-customer data

If your personal information was provided to Farel by an airline or is processed by Farel solely on the airline’s behalf, the airline is generally the controller of that information.

In that situation, please contact the relevant airline directly.

If you send the request to Farel, we may forward it to the appropriate airline or otherwise assist the airline as required by applicable law and our contract.

14. Data Deletion and Connected Business Accounts

You may request deletion of personal information for which Farel is responsible by contacting partners@farel.io.

Please provide sufficient information for us to identify your request.

Where Farel processes information on behalf of an airline, deletion requests may need to be submitted to or authorized by the relevant airline.

Businesses that connect Meta or WhatsApp accounts to Farel may disconnect those integrations through available account controls or by contacting Farel. Disconnecting an integration stops Farel from obtaining new information through that connection, subject to technical processing required to complete the disconnection.

Following a valid deletion request, we will delete or anonymize applicable information within the time required by law, except where retention is permitted or required for legal, security, contractual, fraud-prevention, backup, or compliance purposes.

15. Children and Minor Passengers

Farel’s website, sales, and business-administration services are not directed to children.

However, airlines transport children and minors. As a technology provider to airlines, Farel may therefore process information concerning minor passengers on behalf of an airline when necessary to provide reservation, transportation, operational, safety, or customer-service functionality.

In those circumstances:

• the airline determines the purposes for which the minor’s information is collected;
• the airline is responsible for providing required privacy notices and obtaining parental or guardian authorization where applicable;
• Farel processes the information according to the airline’s instructions, applicable agreements, and law.

Farel does not use minor passenger information processed on behalf of an airline for Farel’s independent marketing purposes.

16. U.S. State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable state law.

Depending on the jurisdiction, these may include rights to:

• know or access personal information;
• correct personal information;
• request deletion;
• obtain a portable copy of information;
• opt out of certain sales, sharing, or targeted advertising uses;
• appeal certain privacy-request decisions.

Farel does not sell personal information or share it for cross-context behavioral advertising.

To exercise applicable rights regarding information for which Farel is the responsible business or controller, contact partners@farel.io.

Where Farel processes information solely on behalf of an airline customer, please direct the request to the relevant airline.

We will not discriminate against you for exercising applicable privacy rights.

17. Do-Not-Track Signals

Some browsers provide a “Do Not Track” signal.

Because there is currently no universally accepted standard governing how these signals should be interpreted, our websites may not respond to all Do-Not-Track signals.

Where applicable law requires recognition of a particular browser or device privacy preference signal, we will process such signals as required.

18. Third-Party Services and Links

Our websites and services may contain links to or integrate with third-party products and services.

Those third parties process information according to their own terms and privacy policies. Farel is not responsible for third-party privacy practices except to the extent required by applicable law or our contractual obligations.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to our products or services;
• new communications channels or functionality;
• changes to our privacy practices;
• changes in law or regulatory requirements.

The revised version will identify its effective date.

Where required by law, we will provide additional notice of material changes.

20. Contact Us

If you have questions about this Privacy Policy or Farel’s privacy practices, contact:

Farel, Inc.
2261 Market Street, Suite 85854
San Francisco, CA 94114
United States
Email: partners@farel.io

For personal information processed by Farel on behalf of an airline, you may also contact the relevant airline directly.