We are registered with the United Kingdom Information Commissioner’s Office under registration number ZA917174.
DATA PROTECTION PRINCIPLES
We adhere to the following principles when processing your personal data:
- Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
- Purpose limitation - data must be collected for specified, explicit and legitimate purposes, and not further processed in a manner that is incompatible with those purposes.
- Data minimisation - data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy - data must be accurate and, where necessary, kept up to date.
- Storage limitation - data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Integrity and confidentiality - data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
INFORMATION WE COLLECT
Information you provide us
The categories of personal information you may provide include:
- first and last name;
- job title and company name;
- email address;
- phone number
- mailing address;
- username (if applicable) and password to register with us and access password-protected areas of our Sites;
- any other identifier that permits us to make contact with you;
- information you provide for us to complete and manage a booking you have made with us or a service you have requested from us;
- information collected during your travel with us and other information pertaining to your travel arrangements;
- information about services formerly provided to you;
- information about online registration and other interactions via our websites and through our agents, for example via Cookies; and
- information about your device and your location if you have been browsing our website.
- you have requested specific medical assistance from us and/or an airport operator, such as the provision of wheelchair assistance or oxygen;
- you have sought clearance from us to fly with a medical condition or because you are more than 28 weeks pregnant;
- you have otherwise chosen to provide such information to us or it has been passed onto us by a third party such as any travel agent through which you made your booking;
- biometric information (for example, facial recognition) may be collected during the security clearance process prior to, and after, flying with us; or
- you provide any other information to us which might, by inference, reveal data about which might be considered sensitive due to revelations with regard to health, or religion etc. for example, any meal choices.
Information we collect from you
We collect, store and use information about your visits to the Sites and about your computer, tablet, mobile or other device through which you access the Sites. This includes the following:
- anonymous information that does not identify you directly or indirectly, and includes statistical information concerning how you use our Sites or information that is linked to a cookie ID or other ID that is not paired in our records with your identifiable information, including name, phone number, or email address;
- information about you and your computer collected automatically using common tracking technologies when you visit the Sites, including your Web browser type and operating system, your IP address, and information regarding the content you view and features you access on the Sites, cookies, analytical tools, or other technologies; and
WHEN WE COLLECT PERSONAL INFORMATION
We collect personal information whenever you use our services, when you travel with us, when you use our website and when you have dealings with us by telephone, by email or in person, including:
- when you voluntarily provide it to us on the Sites or offline;
- when you sign up to receive emails, alerts, or other communications; and
- when you communicate with us either on the Sites or offline.
HOW WE USE YOUR INFORMATION
We use your information which we have collected, as provided in this Policy. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained below.
|Purposes for which we will process the information||Legal Basis for the processing|
|To enable you to register on our Sites and access information, products and services on password-protected areas of the Sites.||It is in our legitimate interests to provide our services to you and to register you at your request. We consider this use to be necessary for our legitimate interests and proportionate.|
|To provide you with information and services that you request from us.||It is in our legitimate interests to respond to your queries and provide any information requested in order to generate and develop business. To ensure we offer a good and responsive service, we consider this use to be proportionate and not prejudicial or detrimental to you.|
|To send you alerts, newsletters, bulletins, e-announcements, and other communications about us.||It is in our legitimate interests to directly market our services to existing users. We consider this use to be proportionate and not prejudicial or detrimental to you. |
For direct marketing sent by email to new contacts (i.e., individuals with whom we have not previously engaged), we will obtain your consent to send you such direct marketing.
|To enforce the Website Terms, the Conditions of Carriage and any contracts entered into with you.||It is in our legitimate interests to enforce our Website Terms, Conditions of Carriage and any other contracts entered into with you. We consider this use to be necessary for our legitimate interests and proportionate.|
|To send you information regarding changes to our policies, other terms and conditions, and other administrative information.||It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and not prejudicial or detrimental to you.|
For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and not prejudicial or detrimental to you.
|To ask you to participate voluntarily in surveys on the Sites for the purpose of monitoring and improving the Sites and our services.|
It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and not prejudicial or detrimental to you.
|For uses or disclosures related to assisting in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.||It is in our legitimate interests to assist in the investigation of illegal or wrongful activity and protect our legal and property rights and the safety of others. We consider this use to be necessary for our legitimate interests and proportionate.|
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or as otherwise required by law. If we need to use your personal information for an unrelated purpose, where we are legally permitted to do so, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.
You may receive marketing communications from us if you have requested information from us or registered to use the Sites and, in each case, where you have not opted out of receiving that marketing (please see above “HOW WE USE YOUR INFORMATION”).
You have the right to opt out of receiving marketing communications at any time by:
- contacting us as provided in “Contacting Us” above; or
- using the “unsubscribe” link with each marketing communication.
- Travel service providers and agents: we share your information with other companies (including any affiliated companies) involved in providing your transportation or related services and facilities. We also share information with our agents in order to provide our services to you.
- Service providers: we use third parties to assist with the running of the Sites and our services including hosting providers, IT providers, software providers, marketing database providers, and accountants etc. In order to obtain these services, we need to share your personal information with such third parties. Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
- Social media networks: we use social sharing and other “widgets” to enable interaction with social media networks. Some of these social media networks track your visit to our Sites (or any other website that uses the widgets) because when you visit those websites, they may place personally identifiable “cookies” in your browser which are then transmitted back to the social network when you visit other sites that happen to use that network’s social sharing widgets (even if you don’t “click” on or interact with the widget).
- Government agencies: we may be required by applicable law to provide your information to Government or Enforcement agencies, such as customs and immigration authorities. Any supply by us of such information to such agencies will be carried out in line with applicable legislation.
- Legal third parties: we may share your information with law firms, law courts, the police or regulatory authorities to enforce or apply any contract with you or to protect our rights, property, customers, staff and/or assets.
- Credit and other payment card companies and screening companies: we may provide information to such companies to effect the purchase by you of services from us, in accordance with the Conditions of Carriage and Website Terms, to process payments and (where necessary) to carry out fraud-screening.
- Other websites and marketing agencies: We may provide usage information (including your personal details) to marketing agencies to enable advertising on websites or social networks. We may also may provide such usage information (but not your personal details) to other websites to indicate you have visited our Sites.
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction;
- if all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation;
- if you we have requested and obtained your consent to such disclosure;
- if necessary to protect the vital interests of a person; and
- to enforce or apply our terms and conditions or to establish, exercise or defend our rights and those of our staff, customers or others.
We aim to action requests to stop being sent marketing communications within 10 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made.
Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications as necessary, for example, to confirm your booking or to provide you with an update on its status.
WITH WHOM WE SHARE YOUR PERSONAL INFORMATION
In addition, We may disclose information about you in the following circumstances:
In the course of providing services to you, it may be necessary to transfer your personal information outside of the European Economic Area (“EEA”). In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us. Where personal information is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information by implementing standard contractual clauses approved by the European Commission.
If you want further information on the specific mechanism used by us when transferring your personal information out of the EEA, please contact us using the details set out above.
SECURITY OF YOUR PERSONAL INFORMATION
We use appropriate physical, technical and organisational security measures to protect personal information both online and offline from unauthorised use, loss, alteration, destruction or modification. We use physical and procedural security measures to protect information.
Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these safeguards, however, we cannot guarantee the security of information.
HOW LONG WE KEEP YOUR PERSONAL DATA
Your personal information will not be kept for longer than is necessary for the purposes for which it was collected and processed. We will retain your personal information for as long as your registration on the Sites is active or as needed to provide you with services or information you have requested.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 7 years.
ACCESS TO AND UPDATING YOUR PERSONAL DATA
You have the right to access information which we hold about you. However, there are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged.
You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller. That right only applies where your personal data is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct, modify or remove information you think is inaccurate by contacting us as provided in the “Contacting Us” section above. Please keep us informed if your personal information changes during your relationship with us.
RIGHT TO OBJECT
You have the right to object at any time to our processing of your personal information for direct marketing purposes.
Where we process your information based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
YOUR OTHER RIGHTS
You also have the following rights under applicable data protection laws.
In certain circumstances, you have the right to:
- request the erasure of your personal information;
- restrict the processing of your personal information to processing in certain circumstances; and
- request that personal information which identifies you be anonymised.
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, subject to applicable law.
For example, we may refuse a request for erasure of personal information where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive or we have other compelling legitimate reasons that override your rights.
EXERCISING YOUR RIGHTS
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
A record of any such request (including any personal information supplied) will be retained in the application used to carry out this request out for 3 years from the date of completion of the same.
For legal reasons, we are unable to erase personal information if you i) have flown with us in the past 13 months or ii) if you hold a forward booking with us. Equally, we will be unable to erase personal information if you have an outstanding complaint against us, or have made such a complaint in the past 6 years. We are required to retain this information in the event that the complaint must be re-opened.
If we comply with your request, we will remove your personal information from our active systems. However, we are obliged by law to retain a separate and restricted copy of the identifying information for 7 years to meet our obligations in respect of law enforcement, national authorities and legal proceedings.
COOKIES, ANALYTICAL TOOLS, AND RELATED TECHNOLOGIES
Our Site uses browser cookies for analytics, functionality, and for various other services. Browser cookies are small pieces of data that are stored on your computer so that our servers can identify your browser software when you visit the Sites. We may also use similar technologies that serve similar purposes such as HTML5 local storage, “Flash” cookies, and web beacons.
We may also use location aware browsing functionality provided by your browser for functionality or analytics.
You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
You can opt-out of the behavioral targeting component of online ads generally by using the resources provided by the Digital Advertising Alliance at http://www.aboutads.info/choices/ or the Network Advertising Initiative at http://www.networkadvertising.org/choices/. Please note, however, that if you delete your cookies, you will need to re-do any prior opt-outs through the Digital Advertising Alliance or Network Advertising Initiative.
The Sites may, from time to time, contain links to and from the websites of our advertisers and affiliates, including social media networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
If you are in located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA. In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/).