The sort of personal data we collect will be information such as name, address, email address, telephone number, date of birth, and personal travel arrangements. In addition, we may also be required to obtain your passport details for travel arrangements, check-in and security reasons. We will need to collect this information to arrange the travel and other services you are requesting. In some cases, we may also need to collect more sensitive personal data such as information concerning medical conditions, disabilities and special requirements such as dietary requests which may disclose your religious beliefs, so as to be able to consider your particular needs in relations to a booking.
We do not generally collect special categories of personal information from you, but where we do, we seek to minimise the collection and use of it and handle it with extra care. We also share this information with third parties (who help manage our business and other companies who help manager your booking or journey), and we transfer it globally.
Where you (or any passenger travelling) provide us with special categories of personal information you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which is was collected.
If you have any queries about any of our products or services, compliments or complaints, we will need to collect information form you, included your contact details, in order for us to respond to your query or provide you with assistance.
We will collect this information when you send us an email, call our customer service centre, visit a local office or contact us via another form of communication such as through social media on an online chat tool.
We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory obligations, and to protect our property rights and interests as well as the property, rights and interest of other persons.
We also process your personal information for crime prevention and detection purposes, included the prevention of fraud for online payments, for identity verification, for credit checking and credit scoring purposes and accounting or audit purposes.
In each case, we do so in compliance with applicable laws.
We collect personal information from third parties who you have authorised to provide your personal information to us (for example, this may be your travel agent or another person making a booking on your behalf, your travel companion, your travel coordinator, our promotion partners, social media and other digital websites). We also collect personal information from individuals who may refer you as a friend to our products or services. We ask these individuals to confirm that you are happy to hear from us.
We collect different personal information depending on your payment method (such as credit card, bank transfer, cash). For example: for credit card payments, we may collect the card holder name, address, card number, expiry date and CVC code.
We will only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
We share your personal information in the manner and for the purposes described below:
How we use personal information to keep you up to date with our products and services
To protect your privacy and to ensure you have control over how we manage marketing with you and provided that you have indicated that you would like to receive it:
If you unsubscribe completely from our marketing communications, we may be unable to notify you of tailored offers to meet your needs. If you do unsubscribe from marketing communications, you will still receive operational and service messages from us regarding your booking including where you may not have completed a booking and responses to your enquiries made to us.
We aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse website use, to improve our content and products and services, to customize our website’ content, layout, products and services, and to support our business operations and we may appoint third parties to do this on our behalf.
We gather certain usage information like the number and frequency of visitors to our website. This information includes which webpage you just came from, which webpage you next go to, what browser you are using, your device ID and your IP address. This collective data helps us to determine how much our customers use parts of our website, and do research on our users’ demographics, interests and behaviour to better understand and serve you. One of the ways we do this is by installing and using Cookies on your browser or device.
If you use buttons on our website linked to social media or similar sites (for example, “Like” and/or “Share” buttons), content from our Website may be sent back to those sites and, depending on your privacy settings, may be privately or publicly visible (for example, to friends, followers or generally to anyone who has access to your profile page).
We use personal information such as your date of birth, gender, country of residence, transactions (for example, payments made with us and flights taken), information derived from Cookies and your preferences and behaviours for profiling. Some of the legitimate purposes we profile personal information include:
We will take steps to ensure that prior to profiling your personal information for a legitimate interest that our legitimate interest is not overridden by your own interests or fundamental rights and freedoms.
Our offices and service providers are located around the world, which means your personal information may be transferred and stored in other countries which may be outside your country of residence. Some of these countries are subject to different standards of data protection than your country of residence.
We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and we only transfer personal information to another country where:
In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.
You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and safeguard the privacy of such information. For example, the measures we take include:
We keep your personal information for as long as is reasonably necessary for the purposes for which it was collected. For example, to manage bookings and provide you with any relevant products or services, as explained in this Privacy Notice. We will ensure that it is disposed of in a secure manner. In most cases we will destroy your data 7 years after collection in order to comply with UK HMRC rules.
Where no booking is made, data will be removed not more than 12 months after collection.
In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements.
In specific circumstances, we may store your personal information for a longer time so that we have an accurate record of your dealings with us in the event of complaints or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Website and the internet and helps us provide better website services to you.
Cookies may collect personal information about you. Cookies help us remember information about your visit to our website, like your departure point, and other settings and searches. Cookies enable us to understand who has seen which webpages and how frequently, and to determine which are the most popular areas of our website. They can also help us to operate our website more efficiently and make your next visit easier and customise your view of the website to reflect your preferences and activities.
In order to exercise your rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
You can exercise your rights by emailing us at email@example.com or by sending us a communication at firstname.lastname@example.org. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request within 30 days or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
You have a right to request a copy of your personal information that we hold, and you have the right to be informed of:
The source of your personal information; the purposes, legal basis and methods of processing; the data controller’s contact details; and the businesses or categories of businesses to whom your personal information may be transferred.
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it. You can also request that we erase your personal information where:
We are not required to comply with requests to erase personal information if the processing of the information is necessary:
You can object to any processing of your personal information which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.
You can request that we stop contacting you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
If you have joined our mailing list, you can manage your marketing preferences automatically by clicking the “unsubscribe” link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us at email@example.com.
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.
You can ask us to restrict the processing of your personal information, but only where:
We can continue to use your personal information following a request for restriction, where:
You have a right to lodge a complaint with the Information Commissioners Office if you have concerns about how we are processing your personal information.
If you have any concerns regarding data that we hold, please contact the General Manager: firstname.lastname@example.org