Privacy Policy

Full Privacy Policy
Our commitment

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.

What is the scope of application of this policy and controller?

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.

What is considered personal information?

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.

What personal information do we collect?

We may collect and process the following categories of personal information:

Identification

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.

Contact information

Your telephone number, physical address and email address.

Booking details

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.

Travel details

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.

Interactions

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.

Previous bookings with us

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.

Use of our website and mobile app

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.

Social media

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.

Sensitive personal information

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.

Third Party bookings

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.

How do we use your personal information?

We use your personal information for the following purposes:

To provide you with our services

We may use your personal information to process and manage your booking and to fulfil your travel arrangements and purchases. For example:

To identify you in order to issue your ticket;

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

To communicate with you and keep you informed

We may need to contact you by email and/or by telephone for administrative or operational reasons. For example:

  • To send you confirmation of your bookings and your payments;
  • To inform you about your travel itinerary;
  • To notify you when check-in is available or to advise you of disruption and changes to your flights; etc.

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.

To personalise and improve your customer experience

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.

To improve your shopping experience on our website

We may use personal information about your use of our website through cookies and other technologies and mobile applications to:

  • Track and analyse your usage of our website to improve the relevance of our website content and to understand what is relevant to you;
  • Measure the effectiveness of and to improve the relevance of our advertisement and promotions;
  • Conduct markets, products or sales research and analysis to improve our products and services;
  • Customize our marketing communications to you, if you agreed to receive such communications;
  • Execute relationship marketing campaigns and retargeting using social media and other advertisement partners;
  • Contact you to offer you more information about a product or service, if you agreed to receive such communications.

What is our legal basis for processing your information?

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:

  • To process and manage your booking, fulfil your travel arrangements and otherwise perform the contract we have with you;
  • To comply with a legal obligation;
  • Because you have consented to us using your information for a particular purpose;
  • Because it is in our legitimate interest to use your personal information, in particular, to enhance and improve our products and services, personalise our offers, develop new products and prevent fraud

How long do we retain your personal information?

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.

How do we keep your personal information safe?

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

When our agency does business with people in Europe:

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.

In this respect, we specify that :

  • Canada has been recognized by the European Commission as ensuring an adequate level of protection;
  • With regard to the transfer of data to the United States, your personal information will only be transferred to third-parties who undertook to provide guarantees as to the secure processing of personal data in accordance with the Privacy Shield (data protection shield) recognized by the European Commission as ensuring an adequate level of protection; for additional information, please refer to the website privacyshield.gov;
  • For other countries, we have ascertained that the recipients of your personal information have put in place the appropriate safeguards in order to ensure that your personal information is adequately protected, the whole in accordance with the data protection legislation in force.

With whom do we share your information?

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:

  • Regulatory authorities and law enforcement agencies such as immigration, customs, airport authorities, border security control for legal compliance and to ensure the safety of our customers, passengers and employees;
  • In accordance with applicable laws, reservation, checking and boarding data collected from passengers (PNR/API) may be transmitted to national public services and competent authorities of a particular country (including, when applicable, France, in accordance with Article L232-7 of French Internal Security Code and under the conditions as defined in the Decret No 2014-1095 dated 26/09/2014);
  • Service providers, such as reservation agents, catering agents, travel service providers, freight providers, car rental, hotel providers or airport ground handling services to facilitate your travel and any other requests you have made;
  • Other passengers named on your booking as part of the online check-in process; Technology service providers, whose systems we may use to process your booking and travel, enhance your customer experience, conduct customer surveys or provide you with personalized marketing communications on our behalf;
  • Forensic and investigatory service providers for investigating a data breach or incident. Affiliates or their service providers, as part of providing the travel services or offering you ancillary products.

How do we use cookies and tracking technologies?

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.

Your rights concerning your personal information

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.

When our agency does business with people in Europe:

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.