The event organiser, KodeeXp Flights, has the legal responsibility to tell ticket buyers and event attendees how their personal information will be collected and used. You can find their Privacy Policy below or contact them to request it.
Last Updated: November 16, 2024
1. INTRODUCTION
1.1 About This Policy
This Privacy Policy explains how Kodee Labs Ltd (trading as 'Kodee Xperience' or 'KodeeXp') collects, uses, stores, and protects your personal data when you use our website and flight booking services.
1.2 Who We Are
UK Entity (Data Controller):
• Company Name: Kodee Labs Ltd
• Company Number: 16373358
• UK Registered Address: 85 Great Portland Street, London W1W 7LT, United Kingdom
Nigerian Entity:
• Company Name: Kodee Industries Limited
• Company Number: RC 1713646
• Nigerian Address: 33 Kofo Abayomi Street, Victoria Island, Lagos, Nigeria
Contact Information:
• Website: https://kodeexp.com / https://flights.kodeexp.com
• Social Media: @Kodeexp
• Newsletter: https://kodeexp.substack.com/
• Contact Email: info@kodeexp.com
1.3 Our Commitment to Privacy
We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy is transparent about how we handle your personal data.
2. PERSONAL DATA WE COLLECT
2.1 Information You Provide to Us
Booking Information:
• Full name (as per passport/ID)
• Date of birth
• Gender
• Nationality and passport details
• Contact details (email, phone number, address)
• Payment information (processed securely via Stripe)
• Special requests (dietary requirements, accessibility needs, etc.)
Newsletter Subscription:
• Email address
• Name (optional)
• Communication preferences
Customer Service:
• Correspondence via email, chat, or phone
• Feedback, complaints, or inquiries
2.2 Information We Collect Automatically
Website Usage Data:
• IP address
• Browser type and version
• Device information
• Pages visited and time spent on site
• Referring website
• Carbon calculator and flight time counter interactions
Cookies and Similar Technologies:
We use cookies to enhance your experience. See Section 10 for more details.
2.3 Information from Third Parties
• Payment verification from Stripe
• Flight operational data from Ascend Airways Limited (our airline partner)
3. HOW WE USE YOUR PERSONAL DATA
We process your personal data for the following purposes:
Purpose |
Legal Basis |
Process flight bookings and issue tickets |
Contract performance |
Communicate about your booking (confirmations, updates, changes) Contract performance |
|
Process payments |
Contract performance |
Comply with aviation regulations and legal requirements |
Legal obligation |
Provide customer support |
Contract performance / Legitimate interests |
Send marketing communications (with your consent) |
Consent |
Improve our website and services |
Legitimate interests |
Calculate and display carbon savings |
Legitimate interests |
Prevent fraud and ensure security |
Legitimate interests / Legal obligation |
Publish newsletter content |
Consent |
4. SHARING YOUR PERSONAL DATA
We share your personal data only when necessary:
4.1 Airline Partner
Ascend Airways Limited (Company ID: 05228762) - Our airline operator requires your booking and passenger information to operate the flight safely and legally.
4.2 Payment Processors
Stripe - Processes payments securely. We do not store full credit card details on our servers. 4.3 Government Authorities
We share passenger data with border control and aviation authorities as required by law, including Advanced Passenger Information (APIS) for international flights.
4.4 Service Providers
We work with third-party service providers who assist us with:
• Website hosting and maintenance
• Email communications (including Substack for our newsletter)
• Customer service tools (live chat)
• Analytics and website optimization
All third-party processors are contractually required to protect your data and use it only for the specified purposes.
4.5 Legal Requirements
We may disclose your personal data if required by law, court order, or to protect our rights, property, or safety.
5. INTERNATIONAL TRANSFERS
Your personal data may be transferred outside the UK and European Economic Area (EEA) when: • Our Nigerian entity (Kodee Industries Limited) processes your booking
• Flights operate to/from Nigeria
• Service providers are located outside the UK/EEA
When we transfer your data internationally, we ensure adequate protection through: • European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Other approved safeguards under UK GDPR
6. DATA SECURITY
We implement appropriate technical and organizational measures to protect your personal data against: • Unauthorized access or disclosure
• Accidental loss or destruction
• Unlawful processing
Security measures include:
• Secure socket layer (SSL) encryption for data transmission
• Secure payment processing via Stripe
• Access controls and authentication
• Regular security assessments
• Staff training on data protection
In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay.
7. DATA RETENTION
We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy:
Data Type |
Retention Period |
Flight booking records |
7 years (legal requirement) |
Payment transaction data |
7 years (tax/accounting requirement) |
Customer service correspondence |
1 year after resolution |
Marketing communications consent |
Until you unsubscribe or 3 years of inactivity |
Website cookies |
As specified in Cookie Policy |
Newsletter data |
Until you unsubscribe |
After the retention period expires, we will securely delete or anonymize your personal data.
8. YOUR LEGAL RIGHTS
Under UK GDPR, you have the following rights:
8.1 Right to Access
Request a copy of your personal data we hold
8.2 Right to Rectification
Correct inaccurate or incomplete personal data
8.3 Right to Erasure ('Right to be Forgotten')
Request deletion of your personal data (subject to legal obligations)
8.4 Right to Restrict Processing
Limit how we use your personal data
8.5 Right to Data Portability
Receive your personal data in a machine-readable format
8.6 Right to Object
Object to processing based on legitimate interests or for direct marketing
8.7 Right to Withdraw Consent
Withdraw consent where processing is based on consent
8.8 Right to Complain
Lodge a complaint with the Information Commissioner's Office (ICO)
To exercise your rights, contact us at: info@kodeexp.com
We will respond to your request within one month. We may need to verify your identity before processing your request.
9. COOKIES
Our website uses cookies to:
• Ensure the website functions properly (essential cookies)
• Analyze website traffic and usage (analytics cookies)
• Remember your preferences (functionality cookies)
• Deliver relevant marketing (marketing cookies - requires consent)
Essential cookies are necessary for the website to function and cannot be disabled.
Non-essential cookies require your consent. You can manage your cookie preferences through our cookie banner or browser settings.
10. THIRD-PARTY LINKS
Our website may contain links to third-party websites, including:
• Social media platforms (where we operate as @Kodeexp)
• Our Substack newsletter (https://kodeexp.substack.com/)
• Payment processors
• Partner websites
We are not responsible for the privacy practices of third-party websites. Please review their privacy policies before providing any personal data.
11. CHILDREN'S PRIVACY
Our services are not directed at children under 16. We do not knowingly collect personal data from children under 16 without parental consent. If you become aware that a child has provided us with personal data without parental consent, please contact us immediately.
12. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated 'Last Updated' date. We encourage you to review this Privacy Policy periodically.
If we make material changes, we will notify you by email or through a prominent notice on our website.
13. CONTACT US
For privacy-related inquiries:
• Email: info@kodeexp.com
• Post: Data Protection Officer, Kodee Labs Ltd, 85 Great Portland Street, London W1W 7LT, United Kingdom
To lodge a complaint with the supervisory authority:
Information Commissioner's Office (ICO)
• Website: https://ico.org.uk
• Helpline: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
14. SPECIFIC INFORMATION FOR FLIGHT PASSENGERS
14.1 Sharing with Ascend Airways
Your booking information is shared with Ascend Airways Limited, our airline partner, for: • Flight operations and safety
• Compliance with aviation regulations
• Customer service during your journey
Ascend Airways processes your data as an independent data controller. Their privacy policy is available at: https://www.ascendairways.aero
14.2 Passenger Rights
As a passenger, you have rights under UK aviation law regarding flight delays, cancellations, and denied boarding. For more information about passenger rights, see our Terms and Conditions.
14.3 Advanced Passenger Information (APIS)
We are legally required to provide passenger data to border control authorities for international flights. This includes:
• Full name
• Date of birth
• Nationality
• Passport details
• Travel itinerary
By using our website and services, you consent to this Privacy Policy.