1. Personal Information
‘Personal Information’ is information which identifies you or can be used to identify you, such as your name, contact details, booking information and transaction history. This may also include information about how you use our sales channels, including in-flight or via our website and mobile application. When we collect and use your personal information, we are regulated under applicable data protection legislation and we are responsible as ‘controller’ for that personal information for the purposes of that legislation.
If you have made a flight booking with another airline, including a Zav Airways flight and one or more flights are to be provided by another airline, that other airline will also separately be considered a ‘controller’ under applicable data protection legislation. In addition, if any of our partners provide services to you such as hotel, holidays, car rental or insurance, they will also separately be considered a ‘controller’. We are not responsible for the privacy practices of any third parties and you can access the privacy policies of our partners or any other third-party providers from them directly.
Additional terms and conditions or privacy policies may apply if you elect to take additional services from us or other third parties.
1. Personal information we collect and use
Information collected by us
We collect personal information from you whenever you use our services, including when you use our website, make a booking with us or make a change to your booking with us, whether through our website, call center, sales shops, in flight or other sales channels. Where you are making a booking on behalf of another person, you must obtain their permission to make the booking and share their personal information with us.
We collect the following personal information from you:
Your full name and contact details including your email address, telephone number(s) and address, your date of birth, passenger name record (PNR), booking reference and reward programme membership number (if applicable) which we collect from you when you make a booking with us, purchase any extras from us, use any services provided by us at an airport or in flight, sign up for our rewards programme or otherwise register with us on our website, or when you check-in online for your flight with us.
We will also collect emergency contact details from you, which we will use in the unlikely event that we need to contact someone on your behalf in an emergency.
Information relating to your booking, including:
· your travel itinerary and services provided by us to you, including prices, date of reservation or booking;
· any special requirements you might have, for example, any special assistance or meal preferences, which may include information about your health;
· any extras you purchase from us either prior to your flight or onboard, or from any of our partners; and
· any changes you make to your booking.
Information about other passengers in your booking which we collect from you when you make a booking or purchase any extras from us on behalf of other passengers.
Information relating to your rewards programme activity, including your membership number, accrual and redemption activity, your account and journey preferences and information about members of your Travel Club or Travel Club Head.
Information relating to payment of your booking, including payment method, which may also include your payment card details provided to us when you purchase Zav Airways products or services.
Advance Passenger Information (“API”), which will include the full name, nationality, date of birth, gender (if required) and passport details (or equivalent) of all passengers included on the booking and which we are legally required to collect from you for certain routes.
Our communications with you, be it by email, SMS, through our call centre, or through interaction with us on social media, including any feedback you provide to us by participating in any surveys we might issue. Where you call us, we may also record the call for training or quality purposes.
Information relating to your preferences when you fly with us, which we also collect when you are a member of our rewards programme, in order to offer you a more personalised service when next travelling with us.
Information on how you use our website or our mobile application to search for flights, make a booking with us or make changes to an existing booking, which may also include collecting your IP address or location data.
Information collected from other sources
We also obtain personal information from other sources who you have authorised to provide your personal information to us, including as follows:
· When you make a booking through a third party, including via a travel agent or third-party platform;
· When you purchase any extras from third parties who are our partners and are contracted by us to provide services to you;
· Other companies involved in your travel plans, including other airlines involved in your prior or onward travel, relevant airport operators, customs and immigration authorities;
· Third parties who participate in our rewards programme; and
· Depending on your settings, when you use social media or other digital platforms and mention us.
Special Categories Personal Information
In certain circumstances, it may be necessary for us to collect, use or share special categories of personal information (for example information relating to your race or ethnic origin, political opinions, religious or philosophical beliefs, genetic and biometric information, health, etc.) for example in order to determine your fitness to fly, provide you with any special assistance that you may require (including special dietary requirements) or determine whether you are eligible to travel on a special religious flight.
We may also use this personal information to respond to a medical or security incident involving you or another passenger included on your booking or otherwise to comply with our legal obligations.
We will only process this category of personal information, if it is necessary, or you have provided us with your express consent to do so.
3. Why we need your personal information
We will only process your personal information where we have a legal basis under applicable data protection legislation to do so. We set out more information on our legal basis for processing your personal information below.
In most cases, we require your personal information to provide our services to you.
We also need your personal information for our legitimate interest as a commercial airline, or otherwise to comply with our legal and regulatory requirements. Where we process your personal information to meet our legitimate interests, we always balance these against your fundamental rights and freedoms and put in place robust safeguards to ensure that your privacy is protected.
On occasion, we may need to use your personal information to protect your vital interests, for example in a medical emergency.
We may also use your personal information where we have your consent for a specific purpose, for example to let you know about offers or promotions you may be interested in.
You do not have to provide your personal information to us. However, in some circumstances, where you do not provide personal information for the purposes of your travel with us, where it is mandatory, we will not be able to carry you.
We set out below in further detail how we use your personal information to:
Purpose Description Legal Basis for Processing
Provide services to you and manage your booking
When you have booked to travel with us, we use your personal information to fulfil our agreement with you, including:
· sending you your itinerary and booking confirmation;
· arranging to meet any special requirements you might have that have been communicated to us in advance;
· providing other services to you, performed either by us or our partners, including checking you and your baggage in for your flight (including tracing your baggage), issuing your boarding pass, managing the boarding process and facilitating flight connections, catering arrangements;
· pre-flight and on-board services, including providing you with access to our lounges or any extras you may have purchased from us or any of our partners; and
· assisting you with any changes you need to make to your booking.
When you send cargo with us, we will use your personal information to manage your shipment and comply with all our legal and regulatory obligations.
Necessary to fulfil our legal obligations to you.
Manage your rewards programme account
If you have signed up to become a member of our rewards programme, we will use the personal information provided to:
· manage your rewards programme account, including log-on, account verification and your accrual and redemption activity;
· ascertain your tier level; and
· understand more about your preferences in order to provide you with a personalized experience when flying with us or to obtain your feedback in order to improve your experience when next flying with us.