The types of personal data we process
1.1 General. We may collect and process the following categories of personal information:
- Name, passport number and other identifying information
For example, we may record your name, title, gender and date of birth, your nationality, country of residence and passport number.
- Your contact details and personal account or registration details
Your contact details may include your address, telephone number and email address. When you create a personal account, or register for a service, we may also record your sign in details and other information you fill out on your personal account or registration form. For business travelers, we also collect information relating to your company such as company name and business location.
- Information about your reservations, bookings and purchases
When you make a reservation, or book a flight with us, we process your reservation and booking information. This information may include details about your flight, prices and the date of your reservation or booking. In addition, we process information in relation to ancillary services (such as upgrades and extra luggage) and products you purchase.
- Information about your travel arrangements
When you travel with us, we process information in relation to your journey. Such as your travel itinerary, (online) check-in, your (mobile) boarding pass and your travel companions. We may also record any specified medical needs or dietary requests you have and any additional assistance you require.
- Our communication with you
When you send us an email or chat with us online or via social media, we register your communication with us. We also register your communication preferences. For example when you unsubscribe from one of our newsletters or when you choose to receive your booking related communication (such as confirmation, check-in notification, boarding pass, and flight status updates) via other channels than email (such as WhatsApp, Facebook Messenger or WeChat). When you call us, our customer support will register your questions or complaints in our database. We may also record telephone calls for training purposes or to prevent or combat fraud.
- Information in relation to social media
- Information you choose to share with us
You may choose to share information with us, for example when you share your interests and preferences with us, leave a comment for us on Facebook, fill out a customer survey or submit an entry for a contest.
How we collect your data
2.1 We collect the aforementioned categories of personal data in the following ways:
- We receive your personal data from your travel agent, our airline partners and other companies involved in facilitating your travel arrangements
We receive your data from these parties to handle your reservations and bookings and to fulfil your travel arrangements and purchases. For example, when you book a flight through a travel agent, we receive your identifying information and booking details from your travel agent. And if you use a third party platform to search and book a flight, we may receive those details from that provider.
- We receive personal data from other airlines in your country that participate in our loyalty programs and our loyalty partners (such as hotels and car rental companies)
- Depending on your social network settings, we may receive information from your social network provider
Please see ‘The types of personal data we process’ above.
We also share your personal information with these third parties (please see ‘Disclosing or sharing data with third parties’ below).
For which purposes we use your data
3.1 The main purposes for which we use your personal information are:
- To provide our services to you
To handle your reservations and bookings and to fulfill your travel arrangements and purchases, we need to process most of the information described above. For example, we need your name, passport number and other identifying information to issue your ticket. To confirm your booking and to inform you about changes in your flight status, we need your contact details. And, to ensure that you receive the required care, we require your specified medical needs.
- To provide our online services and mobile apps to you
For example, we use your name and flight details when you check-in for your flight with our app.
For example, to understand which digital channel (email, social media) or device (desktop, tablet or mobile) you prefer, so we can restrict our communication to that channel or device.
Legal basis. We process your personal data for our legitimate interests to develop better services and offers for our customers, to improve our loyalty programs, to provide more responsive customer support and to improve the design and content of our websites and mobile apps.
Right to object. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data for statistical research (please see below ‘Your rights’).
- To send you updates and special offers tailored to your interests
Communication. When you book a flight with us, we send you personalized ads and special offers for airline related products and services in our booking related emails (unless you opt-out during the booking procedure). For example, before your flight we will send you an email to help you prepare for your flight. In this email we may include special offers for your stay or transport at your destination. You may also subscribe to receive emails or mobile push notifications from us with updates and special offers tailored to your interest. For example, you can subscribe to the Mymay AirLines newsletter which keeps you informed on attractive fares, inspiring destinations, package deals and the latest news. With your consent, we may also send you emails on specific occasions, such as a special offer on your birthday or personalized offers for your next trip within a few months after you return. We may also use other communication channels to send you personalized ads and special offers, such as postal mail or, with your consent, social channels (such as Facebook Messenger, WhatsApp or WeChat).
Legal basis. We process your personal data as described in this paragraph for our legitimate interest and the interests of third parties to provide you with relevant updates
- For record keeping and to comply with statutory obligations
We collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations.
We may be required by law to collect and share your identifying information and your booking and travel information with public authorities or governmental organizations for the purpose of border control, immigration, entering the territory of a State, security or combatting terrorism.
3.2 Legal basis. We collect, use and store your personal data to provide services and our loyalty program to you, to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party or on the basis of your consent.
You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent. For example, by clicking the unsubscribe link in the email, adjusting your communication preferences in your account (if available) or by changing your smart phone settings (for mobile push notifications and location data). You may also contact us to withdraw your consent (please see ‘Your Rights’ below).
If you refuse to provide personal data that we require for the performance of the contract or compliance with a legal obligation, we may not be able to provide all or parts of the services you have requested from us. For example, we may have to cancel your flight or we may not be able to provide you with the ancillary services requested by you (such as special meals). If you provide incomplete or inaccurate information, we may be forced to deny you boarding or entry into a foreign territory under applicable Georgia or international laws.
When we process your personal data for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. Our legitimate interests may for example include security and safety purposes or to provide better services and offers to you. For more information on these interests, please see the ‘For which purposes we use your data’ above. Where we process your personal data for our legitimate interests or the interests of a third party, you have the right to object at any time on grounds relating to your particular situation (please see ‘Your Rights’ below).
Disclosing or sharing data with third parties
4.1 General. We may disclose or share your personal data with our group companies, airline partners, your travel agents, airlines that participate in our loyalty program and loyalty program partners, service providers or subcontractors for the following purposes.
- For support services
We use third parties to provide our services, such as IT suppliers, social network providers, marketing agencies, credit and charge card companies and anti-fraud screening service providers. All such third parties will be required to adequately safeguard your personal data and only process it in accordance with our instructions.
4.2 Public authorities. We may also be required by law to collect and share your identifying information and your booking and travel information with public authorities or governmental organizations for the purpose of border control, immigration, entering the territory of a State, security or combatting terrorism.
Security and retention
5.1 Myway Airlines will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use.
International transfer of your data
6.1 may transfer your personal data to countries other than your country of residence. This occurs in the course of providing your travel arrangements or because our group companies, partners or service providers have operations in countries across the world. The laws of these countries may not afford the same level of protection to your personal data.
6.2 The transfer of personal data to countries other than your country of residence is often necessary to provide our services to you. In other cases, Myway AirLines will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws.
6.3 We may also be required to disclose your personal data to foreign public or government authorities Laws in some other countries may require us to give border control agencies access to booking and travel information. Therefore, any information we hold about you and your travel arrangements may be disclosed to the customs and immigration authorities of any country in your itinerary. In addition, laws in several countries require Myway AirLine to collect your passport and associated information prior to travel to or from those countries. When required, we will provide this information to the relevant customs and immigration authorities. We may also disclose your personal data to government authorities if applicable law requires disclosure.
7.1 You may contact our Privacy Office to exercise any of the rights you are granted under applicable data protection laws, which includes (1) the right to access your data, (2) to rectify them, (3) to erase them, (4) to restrict the processing of your data, (5) the right to data portability and (6) the right to object to processing.
- Right to access
You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right.
- Right to rectification
You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.
- Right to erasure
You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, any other controller to whom your data has previously been made public by us. This includes situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.
- Right to restriction of processing
You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted.
- Right to object.
You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing (see ‘Legal basis’ above).
At any time and free of charge you can object to direct marketing purposes in case your personal data are processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. In case you exercise this right, we will no longer process your personal data for such purposes.
7.2 You may withdraw your consent at any time
You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent.
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