Privacy Policy

Effective 29 April 2026 · Version 2.0

1. Joint Controllers

The following companies are jointly responsible for the processing of your personal data in connection with the enforcement of flight passenger rights claims pursuant to Art. 26 GDPR (joint controllers):

Softclaims Germany GmbH (hereinafter "Softclaims")
Kolonnenstraße 8, 10827 Berlin
HRB 282924, Amtsgericht Berlin (Charlottenburg)
Email: claims@soft.claims

Wynn Capital Management SRL (hereinafter "FlightHelp")
Paringului 72A, Craiova, Dolj, Romania
EUID: ROONRC.J2022002956169
Website: www.flighthelp.eu

The contractual partner of customers for the enforcement of claims is Softclaims Germany GmbH. Softclaims is the assignee of the assigned claims and is registered as a debt collection service provider under the RDG in Germany (details in the Imprint). FlightHelp supports as a marketing/onboarding and service partner for customer acquisition, data capture, technical pre-screening of case data, and customer service.

The joint controllership arises from the fact that FlightHelp and Softclaims jointly organise and coordinate data processing to initiate, process, and enforce flight passenger rights claims. FlightHelp collects and processes personal data via its online platform (in particular data capture, technical pre-screening/eligibility assessment, communication, and customer service) and transmits it to Softclaims. Softclaims processes the data as assignee for further handling and enforcement of the claims, including any required out-of-court and court proceedings. Both parties jointly determine essential means of processing (e.g. which data fields are collected, process design, security measures, access and deletion concepts) under the Art. 26 GDPR arrangement.

2. Arrangement pursuant to Art. 26 GDPR

Softclaims and FlightHelp have concluded an arrangement pursuant to Art. 26(1) GDPR, allocating their respective responsibilities as follows:

2.1 Responsibilities of FlightHelp

• Providing privacy notices pursuant to Art. 13 GDPR at the point of data collection on the platform, including disclosure of the joint controllership and the identity of Softclaims
• Ensuring a lawful basis for the collection and transmission of personal data to Softclaims
• Implementing and maintaining appropriate technical and organisational security measures pursuant to Art. 32 GDPR
• Responding to data subject requests received directly by FlightHelp, and forwarding requests that concern processing by Softclaims

2.2 Responsibilities of Softclaims

• Processing personal data solely for the purpose of enforcing the assigned claim
• Providing supplementary privacy information pursuant to Art. 13 and 14 GDPR in the assignment declaration
• Implementing and maintaining appropriate technical and organisational security measures pursuant to Art. 32 GDPR
• Responding to data subject requests received directly by Softclaims, and forwarding requests that concern processing by FlightHelp
• Deletion or anonymisation of personal data after expiry of statutory retention periods or where no statutory retention obligations or overriding legitimate grounds (e.g. legal prosecution/defence) apply; deletion requests are reviewed and implemented in accordance with the applicable legal requirements.

2.3 Contact Point for Data Subjects

Softclaims is the primary contact point for data subjects within the meaning of Art. 26(1) sentence 2 GDPR. Regardless of this, you retain the right to exercise your rights against both controllers. Data protection coordination: claims@soft.claims

3. Data We Collect

In connection with the enforcement of your flight compensation claim, we collect and process the following personal data as required:

• Identification data: Full name, date of birth (where applicable), address (where applicable)
• Contact data: Email address, telephone number
• Flight data: Flight number, flight date, departure and arrival airports, booking reference (PNR)
• Documents: Booking confirmation, boarding pass, assignment declaration, ID copy (where applicable), and further evidence (e.g. correspondence, receipts)
• Bank details: IBAN for payment of compensation (where a payment is made)
• Communication: Emails and messages relating to your claim
• Technical log data (where applicable): Timestamps, document versions, and log data, insofar as required for contract performance, IT security, or proof of the order placement.

4. Legal Basis

The processing of your personal data is based on:

• Art. 6(1)(b) GDPR — Performance of the contract for the enforcement of your claim
• Art. 6(1)(c) GDPR — Compliance with legal obligations (e.g. tax retention requirements, commercial bookkeeping obligations)
• Art. 6(1)(f) GDPR — Legitimate interests (e.g. enforcement of the claim in court, receivables management)

5. Purpose of Processing

We process your data exclusively for the following purposes:

• Assessment and evaluation of your compensation claim
• Out-of-court and court enforcement against the airline
• Communication with you about the progress of your claim
• Payment of compensation to you
• Fulfilment of accounting and tax obligations

6. Recipients of Data

Your personal data may be disclosed to the following recipients:

• FlightHelp (www.flighthelp.eu) — joint controller for customer acquisition, data capture, technical pre-screening of case data, and customer service (under the Art. 26 GDPR arrangement)
• Airlines — in connection with out-of-court and court enforcement
• Courts and authorities — insofar as required for enforcing the claim
• Lawyers — engaged by Softclaims for court representation
• IT service providers — for technical processing (hosting, email, document management)

All recipients are obliged to treat your data confidentially and to process it exclusively for the stated purposes. Where service providers act as processors, this is done on the basis of contracts pursuant to Art. 28 GDPR and in compliance with appropriate technical and organisational measures pursuant to Art. 32 GDPR.

7. Data Transfers

Softclaims is based in Berlin, Germany (EU). The transfer of personal data between Softclaims and FlightHelp takes place via secure, encrypted channels.

Personal data is only transferred to countries outside the EU/EEA insofar as this is necessary for the enforcement of your claim and appropriate safeguards pursuant to Art. 46 GDPR are in place.

8. Retention Period

We store your personal data only as long as necessary for the purposes stated above. As a rule, data is deleted after completion of the claim proceedings and expiry of statutory retention periods (6 years under commercial law pursuant to § 257 HGB, 10 years under tax law pursuant to § 147 AO).

9. Data Breach

Softclaims and FlightHelp have agreed to notify each other without undue delay and in any event within 24 hours of any personal data breach, in order to fulfil the joint reporting obligations under Art. 33 GDPR (notification to the supervisory authority within 72 hours) and Art. 34 GDPR (notification to the data subjects, where required).

10. Your Rights

You have the following rights under the GDPR:

• Right of access (Art. 15 GDPR) — Right to information about the data stored about you
• Right to rectification (Art. 16 GDPR) — Right to correction of inaccurate data
• Right to erasure (Art. 17 GDPR) — Right to deletion, provided no statutory retention obligations apply
• Right to restriction (Art. 18 GDPR) — Right to restriction of processing
• Right to data portability (Art. 20 GDPR) — Right to receive your data in a structured format
• Right to object (Art. 21 GDPR) — Right to object to processing based on legitimate interests

You may exercise your rights against either of the joint controllers. Preferred contact: claims@soft.claims

11. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority for Softclaims Germany GmbH is:

Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59–61
10555 Berlin
mailbox@datenschutz-berlin.de

You may also contact the supervisory authority of your country of residence.

12. Cookies

This website does not use tracking cookies. Only technically necessary cookies required for the operation of the website are used.

13. Applicable Data Protection Law

The GDPR applies. In addition, the respectively applicable national data protection provisions apply (for Softclaims in particular the BDSG). The guidelines of the competent supervisory authorities and of the European Data Protection Board also apply.

14. Changes

We reserve the right to amend this privacy policy as needed to adapt it to changed legal requirements or changes to our services. The current version is always available on this page.