We have developed and implemented internal policies and procedures designed to provide adequate protection of the personal information in our possession and we review these on a regular basis.
We educate our employees about the importance of protecting personal information by providing them with training on this topic and by issuing directives outlining their role and obligations in this regard. We take reasonable measures to ensure that our agents, mandataries, representatives and employees comply with the provisions of the privacy protection legislation in force.
The provisions of this Policy apply to all personal information collected and processed by our agency within the framework of its activities, unless otherwise indicated when collecting such personal information.
If certain sections of our website refer you to other websites operated by third parties, the information collected by said third parties on these other sites are not subject to this Policy, when it is not used by us. We therefore encourage you to review the privacy policies of these websites.
Personal information is any information that identifies you or can be used to identify you. Your personal information may include, for example, your name, your contact details or information relating to your travel itinerary (e.g. your booking reference number). This information may be collected from you during any interactions you have with us, for example when you visit our website, make a booking, call us or send us an email or enter a contest.This information may also come from travel counsellors.
We may collect and process the following categories of personal information:
Your name, date of birth, gender, nationality and passport number. If your minor children are included in the booking, we will collect their identification information.
Your telephone number, physical address and email address.
During the booking process we collect information about your booking that may include your date of travel, flight reservations, hotel reservations, payment details and any ancillary services such as Option Plus, upgrades and extra baggage.
When you do business with us, we collect and process information in relation to your travel such as your travel itinerary, check-in information, electronic boarding pass, medical needs, special dietary requirements and any additional assistance or preferences.
When you communicate with us via email, online or via social media, we store your communication and, if relevant, each attachment such as pictures and/or videos. When you contact us by telephone, we may record your telephone calls for training purposes or to prevent fraud. We also collect your questions or complaints.
We collect information about services we have provided to you in the past, including your previous travel arrangements (flights and other bookings), interactions and customer feedback.
When you navigate on our website, use our mobile app or subscribe to our newsletter (if relevant), we may collect your IP address, browser type, operating systems, referring website, preferred language, web-browsing behavior, universally unique identifier (UUID) and app use. We may also receive your location data. Please refer to the Section “How do we use cookies and tracking technologies?” for additional information about our use of cookies.
We collect information that you enter during contests or comments that you choose to share on our social media platforms. Depending on your social network settings, we may receive information from your social network provider.
When providing services to you, we may collect personal information that is considered sensitive as it could reveal your racial or ethnic origin, physical or mental health, religious beliefs or criminal convictions or offences. For example, should you request special medical assistance during a flight (e.g. need for a wheelchair or oxygen), this may reveal information about your health. In addition, your religious beliefs may be revealed when you request special meals or advise us of other dietary requirements. Likewise, your travel document details may contain information that may reveal your racial or ethnic origin. When providing sensitive personal information, explicit consent to the processing of this information must be given. This sensitive personal information will be used strictly to allow us to provide any special services requested and to fully perform our obligations.
A third-party booking is when a family member, friend or another person (hereinafter the “Third Party”) makes a booking on your behalf. This Third Party will necessarily provide us with the same personal information that we would collect from you directly in order to complete your booking. In such circumstances, the Third Party will have ensured that you have been made aware of the content of this Policy and that you consent to supply your personal information to us.
We use your personal information for the following purposes:
We may use your personal information to process and manage your booking and to fulfil your travel arrangements and purchases. For example:
To ensure you receive specified dietary requirements; To inform the flight crew and other members of the team that you have purchased Option Plus; etc.
In case of non-provision, objection or restriction to processing or erasure of any information necessary to provide you with our services and those of our partners, or in the event you wish to withdraw consent previously given to us for the collection and use of your sensitive personal information, they as we may not be able to provide certain or all of our services to you. In such circumstances, cancellation fees may apply
We may need to contact you by email and/or by telephone for administrative or operational reasons. For example:
We will also use your contact information for commercial prospecting and to send you marketing communications, if you agreed to receive such communications.
Your opinion is very important to us, so we may seek your feedback on our services via email, social media or surveys.
We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you and to improve our services and experiences for customers.
We may use the communications you exchange with us and information about how you use our website to improve our products and services and to ensure that you receive commercial communications from us that are relevant to you.
We may use personal information about your use of our website through cookies and other technologies and mobile applications to:
The legal basis for processing your information will depend on the reasons your information was collected. We will only process your personal information where we have a legal basis to do so. According to privacy laws, the legal basis for processing your information may be:
We will only keep your information for as long as we reasonably need it for the purpose it is being collected or processed for in accordance with this Policy or in order to comply with the law.
For example, your personal information related to your booking will be retained to fulfil the specific travel arrangements you have made. Afterwards, we will keep the information for a period of time which enables us to handle or respond to any complaints, queries, concerns or legal procedures relating to the booking.
We will actively review the information we hold and delete it securely or anonymize it, when there is no longer a legal, business or customer need for it to be retained.
We have implemented a combination of material, organisational and technological means to ensure the confidentiality of the personal information that we hold, to protect such information against loss or theft and to prevent any unauthorized access, transmission, reproduction, use or amendment there of.
We use industry standard SSL (Secure Sockets Layer) encryption for the transmission of personal information on our website, for example when you pay by credit card online. You can verify this protection by looking for the padlock symbol on many browsers. SSL allows a secure connection between your internet browser and our internet server, using a private (or secret) key to encrypt the information.
When we share personal information with a third party, we take appropriate security measures to ensure such third party’s compliance with the undertakings and rules set forth in this Policy
If you are a resident of a member state of the European Economic Area (hereinafter the “EEA”), your personal information may be accessed and processed outside of the EEA by our agency, whose servers are located in Canada, and/or by one of our trusted third party service providers. Except as provided for in article 49 of the General Data Protection Regulation n° 2016/679 (hereinafter the “GDPR”), when your personal information is transferred outside of the EEA, we require that an adequate level of protection is in place according to the data protection legislation in force.
To ensure that we can provide you with the products and services you have requested from us, we may need to disclose your personal information to trusted third parties, including:
In an effort to continuously improve the quality of the services offered on our website and to better meet your expectations, we may use cookies, which are text files used to identify your device when connecting to one of our services.
By accessing our website, mobile site or mobile applications, if relevant, and continuing to browse same after having been advised of our Cookies Policy via a notification, you acknowledge that you have read the information provided to you regarding the purpose of any process accessing, through electronic transmission, information already stored on your device (electronic communications terminal), or recording information in such device (cookies), and further acknowledge that you are aware of the means at your disposal to refuse such process. You acknowledge that the appropriate configuration of your web browser constitutes your acceptance of the implementation and use of cookies.
Our website uses cookies or advertising IDs for the purpose of advertising. This enables us to show our advertisements to visitors who are interested in our products on partner websites, apps and emails.
Re-targeting technologies use your cookies or advertising IDs and display advertisements based on your past browsing behavior.
Please refer to our “Cookies policy” for additional information about our use of cookies.
In light of the obligation to ensure the security and confidentiality of the personal information being processed, two valid pieces of identification must be provided in support of any request made pursuant to the rights listed hereunder.
You have the right to access and rectify your personal information. You also have the right to withdraw your consent to processing of your personal information. Accessing the personal information contained in your file and rectifying such personal information is free of charge. Accuracy and rectification of your personal information
We make every effort to keep the personal information in our possession accurate, complete, and up to date. However, you are in the best position to quickly inform us of any changes to your personal information, and we therefore ask you to inform us of any amendments, if applicable.
At any time, you may request that the appropriate corrections be made to the personal information that we hold about you. If applicable, we will forward the amended information to the third parties that have access to your personal information. Withdrawal of consent to process personal information
When we process your information based on consent you have previously given, you may withdraw said consent at any time.
EEA residents Rights to data portability, to object, to restriction of processing and to erasure In addition to the rights detailed above, if you reside in a member state of the EEA, you shall have the right, with regards to your personal information, to erasure, to restriction on processing, to object on legitimate grounds to processing as well as to obtain data portability, in circumstances described in the GDPR. A small fee may be required, upon notice from us, to cover the administrative costs of processing such requests.
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