We are part of a corporate group of companies (“Air Arabia Group”), which includes Air Arabia PJSC (a company registered in United Arabi Emirates with registration No. 39511 and registered office at A1 Building, next to Freight Center Entrance, Sharjah International Airport, P.O. Box 132, Sharjah), Air Arabia Maroc (a company registered in Morocco with registration no 192327 and registered office at 4 Rue Carthage, Quartier les Iris, Casablanca, Morocco), Air Arabia Egypt (a company existing under the laws of the Arab Republic of Egypt and under registration No. 131595 having its principal place of business at Florida Tower, 1229 El Sheikh Ali Gad El Haq St., Sheraton Bldgs, Heliopolis, Cairo, Egypt) , Air Arabia Abu Dhabi (a company registered in United Arab Emirates with registration no CN-2899403 and registered office at Abu Dhabi airport, business park, Abu Dhabi), Fly Arna registered office at Ground floor, Old VIP building, Zvartnots International Airport, Yerevan, RA and Fly Jinnah Services, (a private company limited by shares under the laws of the Islamic Republic of Pakistan, under Corporate Universal Identification No. 0154580, whose registered office is 5th Floor, Aviation Dynamics Building, Terminal 1 Road, Jinnah International Airport, Karachi, Pakistan) and their associated brands and/or companies from time to time.
Our GDPR representatives are:
Rickert Rechtsanwaltsgesellschaft mbH
(Information Systems Associates FZE (ISA)
53115 Bonn, Germany
Rickert Services Ltd UK
Information Systems Associates FZE (ISA)
PO Box 1487
United Kingdom email@example.com
You do not have to provide your personal information to us, but if you do not provide certain information we will only be able to provide limited products and services to you. Where you refuse to provide mandatory travel information or allow us to disclose it to required governmental agencies and as otherwise required, we will not be able to transport you.
2. Personal data we collect about you
We may collect personal data directly from you when you use our Mediums, contact us by telephone, by email or in person when you travel.
We may also receive your personal data from our suppliers who provide services to you on our behalf (for example when you provide feedback on our services), our partners when you purchase their travel related products or third parties who act on your behalf, for example travel agents or other parties who book a flight for you. If you book a flight on behalf of someone else, you must have their consent to use their personal information.
We will combine the information that we collect automatically from you with any other information that we collect directly from you or about you.
For more information on the parties who we may share your personal data with, please see "Disclosing your personal information" below.
3. Categories of data we collect
We may collect and process the following categories of information about you:
Your name and surname and your contact details
(email address, telephone number and postal address)
When you create an account on our website
Information about your bookings and your travel itinerary, if you require special assistance or if you have specific dietary requirements. This information may include any changes to your bookings and travel products that relate to your booking (for example if you purchase allocated seats or additional luggage or if you purchase travel insurance, rent a car or book a hotel along with your flight booking).
When you, book or manage your flight
Information about your health, if you have a medical condition that may affect your flight (please see section “Sensitive personal data” below for more information)
When you provide us with this information before you fly or through special meal requests (e.g. diabetic meals)
Information about other passengers in your booking, including the age range of any children traveling with you.
When you make a booking on behalf of other passengers
Information about your transaction, including your payment card details
When you purchase Fly Jinnah products or services
Advance Passenger Information. This information includes your full name, your nationality, your date of birth, your gender (where required) - the number and type of your travel document (e.g. passport or ID), its expiry date and country of issue
When you check in for specific travel routes
Information related to your flights and our services in connection with your flights (e.g. baggage drop service, declaring lost luggage)
When you take a Fly Jinnah flight
Information about your purchases of our partners’ travel related products and services
When you purchase such products or services
Information about the purchase of products available on board
When you pre-order these products or purchase them on board
The communications you exchange with us (for example, your emails, letters, calls, or your messages on our online chat service)
When you contact Fly Jinnah, or you are contacted by Fly Jinnah
Your posts and messages on social media directed to Fly Jinnah
When you interact with us on social media
When you reply to our requests for feedback or participate in our customer surveys
Your preferred departure locations, seats, meals, payment methods as well as the details of your family members
When you choose to provide this information while creating an account or through managing your preferences
Information about how you use our website or our mobile app, such as your searches for flights
When you navigate on our website or when you use our mobile app
Information that relates to your Air Rewards membership
When you sign up or login to your Air Rewards account
4. Sensitive personal data
Sensitive personal data includes data about an individual's health and religion and other categories of personal data which are closely protected. We do not generally collect this information from you (or those you are booking for), but where we do, we seek to minimize the collection and use of it.
Where you have notified us of a health issue that you or someone in your booking:
- may require medical permission to fly, or special conditions or assistance whilst travelling (for example oxygen);
- is pregnant; or
- requires special assistance either on our planes, at destinations or activities or at airports,
You agree that you have voluntarily provided that information to us and that you consent (and those you are booking for consent) for us to use that information to provide you with these products or services and/or determine your fitness to avail yourself of our products or services.
Where your religion or health status could be inferred from meal preferences, we will not link this information or use it in any other way other than to fulfil your meal request.
In each case, you specifically consent (on your behalf and on behalf of those you are booking for) that we can use your sensitive personal data and transfer outside your local country to anywhere in the world where you are travelling or have travelled from or where we provide products or services from (or Fly Jinnah or our service providers do or your travel agent does) (see "Disclosing your personal information" below).
If you do not allow us to process any sensitive personal data, this may mean we are unable to provide all or parts of the services you have requested from us. Please be aware that in such circumstances you will not be entitled to cancel or obtain a refund of any price you have paid.
5. Using the Mediums
(a) when you register an account with us we collect - title, first name, surname, nationality, country of residence, date of birth (if required), phone number, email address, password;
(b) when you join Air Rewards– we collect the same information as when you register an account with us, plus in addition we collect preferred language, and the additional terms set out in the Air Rewards Program terms and conditions apply;
(c) when you book a flight or other products or services with us we collect - passport details, date of birth, emergency contact and details of next of kin. We may collect your email address and / or phone number for boarding pass delivery during online check-in and to provide relevant information for your booking. In some countries we also need to collect your nationality and other information for tax purposes. When you visit our Mediums, we may retain some of the above information to assess the reasons in case of incomplete booking, such as lost internet connection and to support you with completing the bookings.
(d) when you are making payment we will collect different information depending on the payment method. For example for credit card payments we will collect - credit cardholder name, card number, expiry date and CVC code. You may also choose to store your credit card details with us for future use. However, we do not store your CVC/CVV code (the security code on the back of a credit card); and
(e) for adding new information and preferences to your Air Rewards profile. For example recording your preferred seat or meal on our flights.
6. Information about others
You may provide us with information about others, for example:
(a) If you ask us to provide them with information or allow them to manage your booking on your behalf; or
(b) If you make or manage a booking for or on behalf of another person who has allowed you to do so. We need to know the names of all passengers travelling. If you are booking a flight on behalf of someone else (whether adult or a child), you must obtain their consent to use their personal information, including their sensitive personal data as described above. We proceed on the basis that you have obtained these consents. Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this policy. This is especially the case if you provide us with sensitive information about them (e.g. a reference to an illness or health condition).
You may also provide information about others for purposes such as referring a friend to use so we can offer them our products or services. You must contact only those individuals via our Mediums who you know would be happy to hear from you and you must not use our products or services to send unsolicited 'spam' messages.
7. How and why we use your personal data
We use the information provided in the following ways:
(a) To fulfil our contract with you and/or dealing with your booking or intended booking, including processing your booking, sending you your itinerary or other details relating to your booking, or contacting you if there is a problem with your booking (for example by sending you a service message or calling you to inform you when your booking has not been completed);
(b) Managing your wider travel and products or services requirements, for example liaising with and transferring your data to other airlines, service providers and/or travel agents so that they can facilitate your travel arrangements so any disruption can be minimized;
(c) Personalization of the service you receive, for example being aware of previous travel experiences or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile;
(d) Providing Advanced Passenger Information for passengers landing in certain countries. If you do not provide this information we may not be able to provide travel and may not be able to provide a refund or re-booking;
(e) Facial recognition and other biometric technologies for identification purposes may be used by ourselves, by our travel providers, immigration authorities at the airports we fly from or to, including on behalf of Governments and to comply with local regulatory requirements;
(f) Sharing data with loyalty schemes and operators, including Air Rewards (and in each case their affiliated schemes where you have those accounts);
(g) The provision of access to airport products or services;
(h) Interaction with you at different touch points throughout your journey (for example we may inform you that your flight departure has changed);
(i) We may use location data for our mobile website and mobile app to enable us to provide the most helpful format and content (for example pre-populating the language, departure airport, airport codes and payment country) providing that you have agreed to the use of your location data;
(j) To register you with our Mediums and administer our Mediums’ products or services where you have registered to receive these. You can unsubscribe from these Medium products or services at any time (see Choice/Opt-out below);
(k) To administer any contest, competition, prize draw or your acceptance of any other promotional offer you may enter, and notify winners, as more fully set out in the applicable terms and conditions;
(l) To personalize the look and feel of our Mediums and our communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Mediums, market research and, (where you have agreed to this) via social media and networks;
(m) To answer any queries which you may send to us by email or other forms of communication, and we may keep a record of these contacts including call recordings (to the extent permitted by applicable law);
(n) In order to conduct customer satisfaction surveys and improve the products and services we offer or create new products and services;
(o) To meet our legal compliance obligations or for accounting or audit purposes, including the prevention of fraud for online payments and use of loyalty schemes;
(p) To protect our property, rights, and interests as well as the property, rights, and interests of other persons;
(q) For legal purposes, such as to respond to a valid legal subpoena or regulatory order;
(r) For credit checking and credit scoring purposes;
(s) For crime prevention and detection;
(t) For direct marketing purposes, as set out in detail below in the section "How do we use your personal information for marketing purposes”; and
(u) As you may authorize or consent to additionally from time to time.
8. How do we use your personal information for marketing purposes?
Where you have indicated you would like to receive updates from us:
(a) we and /or Air Arabia Group may send marketing communication to you to tell you about developments in the products and services available through our Mediums and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
(b) where we are able to determine or you have indicated to us that you would like to receive it, other entities in the Air Arabia Group and/or other third parties may also send you marketing or updates relating to their products or services; and
(c) we will use your personal preferences which you have told us about, which we have derived from Cookies (see our Cookies Policy [http://www.flyJinnah.com /en/cookie-policy]) and/or which we have inferred from your service usage (see “Aggregate data, data analytics and social media functionality” below) or market research. We will use this information to tailor the advertising and communications that you receive to be those of the most relevance and interest to you.
You can also unsubscribe from receiving certain electronic messages (see "Withdrawing your consent" below).
9. Requesting access to your personal data
You have a right to request access to the personal data that we hold about you. This could include booking information relating to flights you have taken with us.
If you would like to request a copy of your personal data or if have any questions in relation to your personal data, please contact our customer relations department.
10. Security of your personal data
We will take appropriate steps to protect the personal information you share with us. We invest significant resources to protect your personal information, from loss, misuse, unauthorized access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorized or unintended access that is beyond our control.
11. Cookies or other tracking technologies
In order to improve our services, to provide you with more relevant content and to analyze how visitors use our website and app, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.
For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website. In addition, in order to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or html form.
12. Disclosing your personal information
We may disclose personal information about you as follows:
(a) To other entities within the Air Arabia Group for fulfilment of the purposes listed above;
(b) To governments, border control agencies, regulators and others as permitted or required by law, in relation to Advance Passenger Information or such other legal requirements as apply from time to time when travelling to or from a particular country;
(c) To third parties whose products or services you are purchasing such as airlines, tourism agencies, hotel and car hire companies, or to travel agents, including if there is a problem with your booking so that your travel agent can resolve it with you, and you acknowledge and consent that this may also be sensitive personal data;
(d) To our third party service providers and processors, as set out in “Working with other service providers and Air Arabia Group companies” section below;
(e) To third party advertising and social media platforms to provide advertising and the information requested by social media platforms to deliver the user's requested functionality;
(f) In operating our loyalty schemes and referrals to other loyalty schemes, as set out in their terms;
(g) We may also disclose your personal information as permitted or required by law. For example, we will disclose personal information to those governmental bodies who have authority to obtain it, in order to comply with a warrant or subpoena issued by a court of competent jurisdiction, and to comply with record production requirements;
(i) to anyone to whom we transfer or may transfer our rights and duties under our agreement with you;
(j) where you have authorized someone else to manage your booking;
(k) to customs and/or immigration departments or other regulatory authorities in your country of departure and/or destination (or countries you transit through or overfly during your journey) in order to comply with the law in those countries;
(l) if we have a duty to do so or if the law allows us to do so; and
(m) to our employees and agents to do any of the above on our behalf, now or in the future.
13. Minors accessing our Mediums
You confirm to Fly Jinnah that you are of the applicable legal age or over to access and use our Mediums in accordance with its terms. If a minor (according to applicable laws) has provided Fly Jinnah with information without consent of a parent or guardian, the parent or guardian can contact Fly Jinnah to remove it.
14. Working with other service providers and Air Arabia Group companies
These service providers and group companies may be located in your country, countries in the European Economic Area, in Armenia, the United Arab Emirates, or elsewhere in the world. Different privacy laws may apply in these countries See further detail in our "Transfer of Your Personal Information" section below.
17. Withdrawing your consent
You do not have to provide us with your personal information. However, if you choose not to provide certain personal information we request and/or require or consent to its use and disclosure, you will still be able to visit our Mediums but you may be unable to access certain options, products or services, and in some cases we may not be able to fulfil your booking.
All marketing communications we email to you will provide you with a way to withdraw your consent to future marketing.
To opt out of mobile device messages or notifications from Fly Jinnah applications go into “settings” on your device and turn off notifications for the Fly Jinnah application.
Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs.
Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding your booking and responses to your enquiries made to us, and that we may hold your details on a suppression list so we don't send you marketing communications in the future.
You also have the ability to change your cookie settings to block certain types of cookie - this is explained in more detail in our Cookies Policy [http://www.flyjinnah.com /en/cookie-policy].
18. Aggregate data, data analytics and social media functionality
We may aggregate personal information and remove any identifying elements in order to analyze patterns and improve our marketing and promotional efforts, to analyze Medium use, to improve our content and product offerings, and to customize our Mediums’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
We gather certain usage information like the number and frequency of visitors to our Mediums. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. This collective data helps us to determine how much our customers use parts of our Mediums, and do research on our users’ demographics, interests, and behavior to better understand and serve you.
If you use buttons on our Mediums linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Mediums may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).
19. Do Not Track
Currently, our systems do not honor browser do-not-track requests; you may delete cookies and other tracking technologies using the processes specified in our Cookies Policy [http://www.flyjinnah.com /en/cookie-policy].
20. Transfer of your personal information
In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.
21. When you apply for a job listed on the Career section of our website
When you use services provided on our Career section, you will be asked to provide certain personal information in order to apply for jobs, or to join the company. We will store this information and hold it on computers or otherwise.
(a) We will collect the following personal data from you at various stages of the recruitment process.
- Personal Details: this includes your first name, maiden name and surname, date of birth, home address, home telephone number, marital status, gender;
- Family Details: this includes your emergency contact information, spouse name, spouse contact information, children, parents and other relatives name;
- Documentation Required Under Immigration Laws: this includes your nationality, passport data, national identification number, employee identification number, passport photo, information or documents sufficient to establish citizenship, identity and employment eligibility;
- Resume and CV Information: this includes information contained in application letters, your resume or CV (e.g. employment and education history, professional qualifications, language and other skills, certifications, etc.), information necessary to complete a background check, details on performance management ratings, development programs planned and attended, e-learning programs, performance and development reviews, copies of work experience certificates and any other information provided by you to Fly Jinnah during the first phases of your application, your on boarding and (if applicable) your employment;
- Interview records: this includes your responses to questions during the interview process and the results of any psychometric or other structured evaluation method we may use to decide whether you might be suitable for the role you have applied for.
(b) Legal basis for using your data
We will only collect, use and share your personal information where we have an appropriate legal basis to do so. Appropriate legal bases include:
- our legitimate interests as a company to screen and evaluate candidates for possible employment at the Fly Jinnah;
- where processing your data is a necessary step before entering into a contract (of employment) for a job that you have applied for;
23. Contact information