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Privacy Policy (EEA and UK)

1. Privacy Policy

1. Akasa Air, A brand of SNV Aviation Private (Akasa Air, we/us/our) is committed to ensuring the privacy of our customers (you/your). This privacy policy (the Privacy Policy) applies to our customers, potential customers and passengers on our flights who are located in the European Economic Area (EEA) and the United Kingdom (UK). It sets out our practices in relation to collection, use and storage of your personal data. This Privacy Policy also informs you of the circumstances in which your personal data may be shared. This Privacy Policy is to enable you to make an informed decision in relation to your personal data. Please read this Privacy Policy carefully to be aware of the collection, use and storage of your personal data that is entrusted with us.

2. If you are an existing customer details about how we use your personal data is contained in your customer contract with us. Further we will notify you at the time of collection of your personal data of the uses we propose to make of your personal data and the situations in which you may opt out of certain uses of your personal data.

3. Our websites and mobile applications may contain links to other third party websites. These third party websites have their own privacy policies and terms of use. We do not accept any responsibility or liability for their policies or processing of your personal data. You should make yourself aware of these policies before you submit any personal data to such third party websites.

4. This Privacy Policy is intended to explain our privacy practices and covers the following areas:

1. Personal Data we collect from you;

2. The use of your personal data;

3. Who we may share your personal data with?;

4. Security and Protection of your Personal Data;

5. Contacting us & your rights to prevent unsolicited marketing and to access and update your personal data;

6. How changes to this Privacy Policy and the Cookies Policy will be made

2. Personal Data we may collect about you

1. We will collect and process all or some of the following personal data about you:

1. Information you provide to us Personal data that you may provide to us while using this website, our mobile site, and mobile application including your name, email address, other contact details, student/defence ID number, the company you work for (in relation to corporate bookings), booking information and flight itinerary;

2. Information you provide us about your children When a child is travelling with us we may collect data such as the child’s name, date of birth, gender and other relevant information similar to the information you provide to us about yourself.

3. Advanced Passenger Information (API) including your passport, Visa and travel information, date of birth, gender and nationality;

4. Health data that you may provide us in order to meet your health related needs in flight (eg. to respond to particular health risks or to understand allergies, etc) and also to provide special assistance, for example wheelchair access assistance;

5. Payment informationrelating to the method of payment, GST/tax related information card information (for your security, we do not retain your CVV number, the CVV number is used only for authentication) and the name of your bank);

6. Our correspondence we will retain a copy of any correspondence that you sent to us;

7. Survey information we may ask you to respond to some survey questions to help us serve you better. We will be retaining the data you may provide as a part of your responses.

8. Your transactions the details of any ticket purchased from us and data related to payment and fulfilment of services shall be retained by us. and

9. Website and communication usage details of your visits to the websites and information collected our website including cookies and other tracking technologies including, but not limited to, your IP address and domain name, profile image, geographical location, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

10. Other information you may voluntarily share with us such as your social media handles.

2. We require certain personal data and information in order to enable us to render services or provide products to you which may include details of your travel documentation, payment details and contact information. If you do not provide such information to us we may be unable to deliver you the products and services in full.

3. In a situation where you have provided us personal data relating to another person (for example, where you have booked a flight on his or her behalf) please ensure that you have that person’s knowledge and permission to use their data. Please provide that person with a copy of (or a link to) this privacy policy so they understand how we process personal data.

4. We may receive personal data from:

1. Global Distribution Systems for example, where you have made a booking using a flight comparison website;

2. Online travel agents, meta search sites, aggregator siteswhere you have made a booking using a third party agency; or

3. Travel management companies

5. The data received from these organisations will be limited to that described at section 2.1 above and we will not use it for any other purpose other than those described.

3. Uses made of your personal data

1. This section informs you of the purposes for which we collect and use your personal data. The basis for data processing is stated here are in compliance with applicable European Law and the laws of the United Kingdom.

2. We have identified the purposes for which we may have to disclose your personal data which are stated below. In addition, we may disclose personal data for the identified purposes to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of Akasa Air that perform activities on our behalf, as well as other members of the Akasa Air group.

1. To communicate effectively with you and conduct our business to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us; Legal basis: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you)

2. To provide you with marketing materials to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by post, email, SMS, WhatsApp, chat, chatbot, phone and fax and private messages through other digital platforms. And, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” section below. Legal basis: consent, legitimate interest (to keep you updated with news in relation to our products and services)

3. For research and development purposes to analyse your personal data in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services; Legal basis: legitimate interests (to allow us to improve our services)

4. To monitor certain activities to monitor queries and transactions to ensure service quality, compliance with procedures and to combat criminal activity; Legal basis: legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services)

5. To inform you of changes to notify you about changes to our services and products; Legal basis: legitimate interests (to notify you about changes to our service)

6. To ensure website content is relevant to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers; Legal basis: legitimate interests (to allow us to provide you with the content and services on the websites)

7. To reorganise or make changes to our business in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal data to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy Legal basis: legitimate interests (in order to allow us to change our business)

8. In connection with legal or regulatory obligations We may process your personal data to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. Legal basis: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)

9. Understanding your health requirements To ensure that you are safe on flights and to manage any particular requirements for example, allergies. Legal basis: explicit consent, contract performance, safety.

4. Who we share your personal information with

1. For the purposes stated in this Privacy Policy we may disclose your personal data to our agents, suppliers, governmental authorities or subcontractors as may be reasonably necessary for the fulfilment of the said purposes. This will include customs and immigrations authorities, airports at which we operate, credit card fraud companies (to detect and prevent fraud), payment operating services, notification channels to notify customers regarding their bookings, flight schedule changes by sending SMS and emails, the departure control system (DCS), the baggage reconciliation system (BRS), advance passenger processing (APP) and customer and border protection (CBP), travel processing system.

2. In addition, we may disclose information about you to counterparties, customs and immigration authorities, other government bodies, regulators and law enforcement agencies where required by law, in connection with any legal proceedings or prospective legal proceedings, or in order to establish, exercise or defend our legal rights including providing information to others for the purposes of crime detection and prevention.

3. Except as provided in this Privacy Policy, we will not otherwise provide your information to third parties.

5. Storage and security of your personal data

1. Please note that no data transmission over the internet using websites, mobile applications or other platforms can be guaranteed to be completely secure. We, however, maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with applicable laws.

2. All information you provide to us is stored on and processed through our or our subcontractors’ secure cloud servers and/or CRM systems (which are compliant with applicable data privacy regulations) in various jurisdictions outside of the EEA or the UK (including India and any other country/ies in which Akasa Air or its affiliates, subsidiaries or agents maintain facilities) and accessed and used subject to our security policies and standards.

3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

6. Processing outside the EEA and the UK

1. We will sometimes transfer personal data to other jurisdictions, including destinations outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal data as set out in this Privacy Policy.

2. Where your personal data is transferred from an entity inside the European Economic Area (the EEA) or the UK (as the case may be) to outside the EEA or the UK (as the case may be), we may be required to take specific additional measures to safeguard the relevant personal data. Where we transfer your personal data, we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other equivalent measures applicable in the UK or otherwise to ensure the appropriate security of your personal data.

3. Please contact us as set out in the “Contacting Us” section below if you would like to see a copy of the specific safeguards applied to the export of your personal data.

4. Storage limits: Storage limits: Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

7. Your rights & contacting us

Marketing

You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. Where you do not wish to receive marketing from us, you can decline or withdraw your consent at any time, either by choosing not to select the relevant check boxes on our subscription form, by clicking the unsubscribe link in any marketing message received from us, or by contacting us here.

Updating information

We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by contacting us as set out in the “Contacting Us” section below. Please note that it is your responsibility to ensure that your booking information or flight itinerary is accurate.

Your rights

If you have any questions in relation to our use of your personal data, you should first contact us as per the “Contacting Us” section below. Under certain conditions, you may have the right to require us to:

1. provide you with further details on the use we make of your information;

2. provide you with a copy of information that you have provided to us;

3. update any inaccuracies in the personal data we hold (please see paragraph 5.2);

4. delete any personal data the we no longer have a lawful ground to use;

5. where processing is based on consent, to withdraw your consent so that we stop that particular processing. Please note that in relation to health information, this will prevent us from reacting to any health condition you may have;

6. to ask us to transmit the personal data you have provided to us and we still hold about you to a third party electronically;

7. object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and

8. restrict how we use your information whilst a complaint is being investigated. Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month. If you are not satisfied with our use of your personal data or our response to any exercise of these rights you have the right to complain to the relevant data protection authority.

Contacting us

If you have any questions in relation to this policy, please contact us at info@akasaair.com

1. Changes to our Privacy Policy and/or Cookies Policy

1. We may change the content of our websites and how we use cookies and consequently our Privacy Policy and our Cookie Policy may change from time to time in the future. If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our Website.

2. This Privacy Policy was last updated on July 12, 2022.