Privacy Policy
Last updated: 25 August 2026
1. Who we are
DelayPay is operated by TGT Systems Ltd, a company registered in England and Wales. We act as a referral agency — we check whether your flight may qualify for compensation under EU Regulation 261/2004 or UK Regulation 261, and connect you with a specialist claims partner. We do not process claims ourselves.
For the purposes of UK GDPR and the Data Protection Act 2018, TGT Systems Ltd is the data controller.
Data protection contact: [email protected]
2. What data we collect
| Data | Why we collect it |
|---|---|
| Email address | To send you your claim result and, if you opted in, other compensation notifications |
| Flight number & departure date | To verify your flight delay against aviation data sources |
| Number of passengers | To calculate the potential compensation amount |
| Country of residence | To determine which regulation applies (EU261 or UK261) |
| IP address & user agent | Fraud prevention, rate limiting, and security |
| UTM parameters | To measure which advertising channels are effective (no personal identification) |
| Consent flags | To record your choices about data sharing and marketing |
We do not collect your name, phone number, passport details, or payment information at any stage.
3. How we use your data
We use your personal data for the following purposes:
- To verify whether your flight was delayed by 3 or more hours at arrival, using third-party aviation data providers (FlightLabs, AeroDataBox)
- To calculate the compensation amount you may be entitled to based on flight distance
- To email you the result and, if you qualify, a link to our claims partner where you can start your claim
- If you ticked the marketing consent box, to notify you about other compensation you may be eligible for
- To improve our service, detect fraud, and ensure security
4. Legal basis for processing
We process your data on the following legal grounds under UK GDPR:
- Consent (Article 6(1)(a)): You give explicit consent when you tick the required checkbox and submit the form. You can withdraw consent at any time by emailing [email protected] or clicking the unsubscribe link in any email.
- Legitimate interest (Article 6(1)(f)): For fraud prevention, security, and service improvement. We have assessed that these interests do not override your rights and freedoms.
5. Who we share your data with
We share your data only when necessary and only with the following categories of recipients:
- Claims partners: If your flight qualifies for compensation and you consented to data sharing, we send your email, flight details, and country to our claims partner (currently Compensair, operated by Compensair Pte. Ltd.). The claims partner has their own terms and privacy policy which apply when you use their service.
- Aviation data providers: We send your flight number and date (no personal data) to verify delay information.
- Hosting provider: Our website is hosted by Krystal Hosting Ltd (UK). Data is stored on servers within the UK.
- Meta (Facebook): We use the Meta Pixel for advertising measurement. See Section 7 for details.
We do not sell your personal data to anyone. We do not share your data with third parties for their own marketing purposes.
6. Marketing communications
We only send marketing emails if you ticked the optional marketing consent checkbox. These emails may notify you about other types of compensation you may be eligible for (for example, cancelled flight claims, denied boarding, or travel-related compensation under other regulations).
Every marketing email contains an unsubscribe link. You can also withdraw consent at any time by emailing [email protected]. We comply with the Privacy and Electronic Communications Regulations 2003 (PECR).
7. Cookies and Meta Pixel
We use the following cookies and tracking technologies:
- Meta Pixel: We use the Meta (Facebook) Pixel (ID: 29288455630754424) to measure the effectiveness of our advertising. The Pixel records page views and form submissions (as "Lead" events). It may place cookies on your device and collect data such as your IP address, browser type, and pages visited. This data is processed by Meta Platforms Ireland Ltd in accordance with their Data Policy.
- Session cookie (PHPSESSID): A functional cookie used for rate limiting. It expires when you close your browser and contains no personal information.
We do not use any analytics cookies (such as Google Analytics) beyond the Meta Pixel.
8. Data retention
We retain your personal data for the following periods:
- Qualified leads (flight confirmed delayed ≥ 3 hours): 2 years from submission, to allow for the claims process which can take up to 6 years under some jurisdictions
- Rejected leads (flight not delayed or not qualifying): 6 months, then automatically deleted
- Marketing consent records: Retained for as long as the consent is active, plus 1 year after withdrawal for compliance records
After the retention period, data is permanently deleted from our database.
9. International transfers
Your data is primarily stored on servers in the United Kingdom. If your data is shared with a claims partner based outside the UK (for example, Compensair Pte. Ltd. in Singapore), appropriate safeguards are in place including standard contractual clauses or equivalent measures to ensure your data is protected to UK GDPR standards.
Meta Pixel data may be transferred to Meta's servers in the EU/US under Meta's own data transfer mechanisms.
10. Your rights
Under UK GDPR, you have the following rights:
- Right of access: Request a copy of the personal data we hold about you
- Right to rectification: Request correction of inaccurate data
- Right to erasure: Request deletion of your data ("right to be forgotten")
- Right to restrict processing: Request that we limit how we use your data
- Right to data portability: Request your data in a machine-readable format
- Right to object: Object to processing based on legitimate interest or for marketing
- Right to withdraw consent: Withdraw consent at any time without affecting the lawfulness of processing before withdrawal
To exercise any of these rights, email [email protected]. We will respond within 30 days.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO): ico.org.uk
11. Children
Our service is not directed at individuals under 18. We do not knowingly collect data from children. If you believe we have collected data from a minor, please contact us immediately at [email protected] and we will delete it.
12. Changes to this policy
We may update this Privacy Policy from time to time. The "last updated" date at the top reflects the most recent revision. Material changes will be communicated via email to users who have provided their email address.
13. Contact
TGT Systems Ltd
Data protection enquiries: [email protected]