When and why do we collect ‘special category of data’?

Certain categories of personal information, such as information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, genetic and biometric information, are special categories of data requiring additional protection under the data protection laws. We try to limit the circumstances where we collect and process such data and we have listed below are a couple of examples where we will do so.

• You need a specific medical assistance from us, such as the provision of wheelchair assistance or oxygen, or you have informed us of any other disability.
• You sought clearance from us to fly with a medical condition or because you are more than 28 weeks pregnant.
• Biometric information (for example, face recognition) may be collected during the security clearance process prior to, and after, flying with us.

You may also have informed us any dietary requirements for your flight meal which is not ‘special category of data, though may imply or suggest your religion, health or other information.

How do we use ‘Aggregated Data’?

We may also collect, use and share Aggregated Data such as statistical or demographic data for market analysis, our advertising strategy or any other business purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.

How is your personal data collected ?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your (or other passenger’s’) Identity, Contact and Financial Data by filling in online/ airport forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • make a flight booking with us;
  • apply to our services in general;
  • create an account on our website and/or applications;
  • subscribe to our service, newsletters and/ or membership loyalty programmes;
  • travel with us (e.g. interactions with staff and cabin crew before or during your flight);
  • request marketing to be sent to you;
  • register for a competition, promotion or survey;
  • interact with our social media pages, such as Facebook, Instagram or Twitter; or
  • give us feedback or contact us.
• Automated technologies or interactions.As you interact with our website or other applications, we will automatically collect Technical Data about your device, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
• Third parties This includes
  • Technical Data from the following parties:
    1. analytics and search information providers such as Google;
    2. advertising networks such as SkyScanner; and
  • Contact, Financial and Transaction Data from payment service providers such as Stripe, Visa, Mastercard or others.

4.

How is Your Personal Data Collected?

We will only use your personal data when the law allows us to. Most commonly, we will use (this is, process) your personal data in the following circumstances:

• Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we are about to enter into or have entered into with you. For instance, we need to use your information so that we can process your booking, fulfil your travel arrangements and otherwise provide services to you.
• Necessary for the purposes of legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This may include responding to enquiries from you or third parties, optimising our website, applications and the overall user experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
• Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
• Necessary to protect the vital interest of you or another person. This may be necessary for emergency medical care where a person is unconscious or otherwise of giving consent to the processing (e.g. a passenger has experienced a severe, life-threatening allergic reaction during a flight and has fallen unconscious).
• Consent. In some circumstances, we may ask for your consent to process your information in a particular way (for example, we will get your consent before sending you direct marketing communications via email or text message, or any third party marketing. You have the right to withdraw consent to marketing at any time by contacting us).

5.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a bullet list, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

• To register you as a new customer
  • a. Type of Data
    1. Identity
    2. Contact
  • b. Lawful Basis & Legitimate Interest
    1. Performance of a contract with you
• To fulfil your travel arrangements and deliver the services you have asked for:
  • Manage the boarding process
  • Manage payments, fees and charges
  • Send flight updates and services communications
  • Provide services tailored to your requirements
  • a. Type of Data
    1. Identity
    2. Contact
    3. Financial
    4. Transaction
    5. Marketing and Communications
  • b. Lawful Basis & Legitimate Interest
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to recover debts due to us)
• To manage our relationship with you which will include:
  • Notifying you about updates to our business terms or privacy policy
  • Sending you technical alerts, security notifications and administrative communications
  • Asking you to leave a review or take a survey
  • a. Type of Data
    1. Identity
    2. Contact
    3. Profile
    4. iv. Marketing and Communications
  • b. Lawful Basis & Legitimate Interest
    1. Performance of a contract with you
    2. Necessary to comply with a legal obligation
    3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
• To enable you to participate in a competition or survey:
  • a. Type of Data
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
  • b. Lawful Basis & Legitimate Interest
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
• To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • a. Type of Data
    1. Identity
    2. Contact
    3. Technical
  • b. Lawful Basis & Legitimate Interest
    1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    2. Necessary to comply with a legal obligation
• To deliver relevant website content and advertisements to you and measure the effectiveness of the advertising we serve to you
  • a. Type of Data
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    6. Technical
  • b. Lawful Basis & Legitimate Interest
    1. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
• To use data analytics to improve our website, services, marketing, customer relationships and experiences
  • a. Type of Data
    1. Technical
    2. Usage
  • b. Lawful Basis & Legitimate Interest
    1. Necessary for our legitimate interests (to identify our target customers, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
• To make suggestions and recommendations to you about services that may be of interest to you
  • a. Type of Data
    1. Identity
    2. Contact
    3. Technical
    4. Usage
    5. Profile
    6. Marketing and Communications
  • b. Lawful Basis & Legitimate Interest
    1. Necessary for our legitimate interests (to develop our services and grow our business, to tailor the contents of the website, applications, emails and other communicants sent to our customers)

Marketing

When we have your permission we will send you marketing communications from Global Airlines Ltd. However, we do sometimes send marketing communications that include a business partners’ products and/or services related to the travel you are undertaking, as well as our own.

We will only allow third parties [or other members of our group] to send marketing communications to you when we have consented to receive marketing from third parties.

We will respect your choice as to what communications you wish to receive and how these are sent.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time. The ways to stop being sent marketing communications are described below:

• You can change your marketing preferences at any time in your account area or by e-mailing us using the contact details below;
• In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop receiving further marketing emails.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase and we may still send you communications about the services you have booked with us, such as messages regarding your travel itinerary or other related bookings.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

6.

Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the section ‘purposes for which we will use your personal data’ above.

• External Third Parties:
  • Airlines and other service providers needed to deliver the services you have asked for where, for instance, part of your itinerary involves a flight operated by a different airline or includes a car hire or hotel booking.
  • Vendors, consultants, and other service providers based In the UK, Europe and the United States of America (USA), who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in UK, Europe or the USA who provide consultancy, banking, legal, insurance and accounting services.
  • Customs and immigration authorities of any country in your itinerary or to which your flight may fly over.
  • HM Revenue & Customs, regulators and other government and/or l.e enforcement authorities based in the United Kingdom

• Business Transfers:
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. In this case we may share and/or transfer customer information, including personal data, in connection with the evaluation of and entry into such transactions and based on our legitimate interest. Also, if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal data may be one of the assets transferred to or acquired by the third party.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

We do not sell your personal data to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.

7.

International Data Transfers

We may share your personal data with third party service providers who are based outside the country in which you are located and outside the UK and the European Economic Area (EEA). The nature of our business requires us to operate worldwide and, therefore, we may have to send your personal information elsewhere to fulfil your travel arrangements or to comply with a valid request from a governmental or regulatory body.

Whenever your personal data is transferred to countries outside the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data as adopted by the European Commission (together with the UK Secretary of State);
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (i.e. EU Standard Contractual Clauses alongside the UK Addendum)
• Where we transfer data to the USA, we ensure that our processors located therein adhere to the EU-US Data Privacy Framework, including as applicable under the UK Extension to the EU-US DPF – for more information, please visit https://www.dataprivacyframework.gov/.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

8.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10.

Data Retention

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

• Request access (commonly known as a "data subject access request") – you have the right to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction- you have the right to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure (“right to be forgotten”) - you have the right to ask us to delete or remove the personal data we hold about you from our records. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons – for example, where we are legally obligated to keep the information or if it is impossible or unproportionate for us to erase the data. In this case, we won’t delete it but we will only keep it for as long as it is needed and we have time limits on our data systems.
• Object to processing– you have the right to object to processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you feel such processing impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing- you have the right to ask us to suspend the processing of your personal data in the following scenarios (a) If you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer– you have the right to ask us to transfer the personal data we hold about you, either to you or a third party you have chosen, in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time(where we are relying on consent to process your personal data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.
• Object to automated processing, including profiling – in some circumstances you can ask us not to reach decisions that produce legal or similarly significant effects on you using automated decision-making, including profiling. Note, however, that the use of algorithms or machine learning techniques in ways that don’t have significant privacy implications on you is unlikely to render you with the right to object such automated processing.

If you wish to exercise any of the rights set out above, please contact us on the contact details set out below.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

11.

Data Retention

If you have any questions about this privacy policy or our practices, please contact us at compliance@globalairlines.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.