Effective as of January 1, 2020
What Is Personal Information?
Personal information (often called personal data) means details which identify you or could be used to identify you, such as your name and contact details, your travel arrangements and purchase history. It may also include information about how you use our websites and mobile applications. Personal information includes sensitive personal information.
What Is Sensitive Personal Information?
Some laws require additional protections for categories of personal information that are considered sensitive. Sensitive categories include information about an individual's race, ethnicity, religion, health, sexuality or biometric information.
When Does Air General Collect Personal Information About You?
We collect personal information about you whenever you fill our online forms to request services, when you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you travel using our Greeter Services, when you use our online forms to request various services or interact with us via email. For example, when you request Air General Traveler Services using our online Meet & Greet Booking Request form, you choose to provide us with personal information.
In addition, we may receive personal information about you from third parties, such as:
- Companies contracted by us to provide services to you.
- Companies involved in your travel plans, such as travel agencies or airlines involved in your prior or onward journey, driving services companies, airlines or hotels, and/or customs and immigration authorities.
- Companies who provide details to us under contractual restrictions to facilitate our provision of services to you such as your personal booking agents or personal representatives or administrative assistants.
Does Air General Collect Personal Information On Young People?
At times Air General receives requests, either directly or indirectly, through partners such as travel agencies or personal booking agents, to provide services to assist young travelers. At that time, Air General requires that a parent or guardian fill out the Young Traveler's Information Form. By filling out this form, the parent or guardian authorizes us to collect and process certain personal information on individuals under age 16, only for the purpose of providing the requested services.
What Types of Information Does Air General Collect?
When you use our services, you will need to provide us with your personal details or the details of those individual(s) who will be using our services during their travel.
We collect the following categories of personal information:
- Information you provide to Air General to complete and manage a booking for our Meet & Greet (Traveler Services (i.e. your name, address, email, contact details, date of birth, gender, passport number, your account details and payment information.
- If you buy tickets for someone else, we may collect your billing information but may communicate with the passenger directly about their travel arrangements and trip plans.
- Information collected during your use of our services and on-site interactions with our staff and representatives (i.e. destinations, participation in certain events).
- Information about your travel arrangements (i.e. Your travel itinerary, airline reservations, details of any dietary restrictions, medical conditions, or and additional assistance or specific accommodations that you require.
- Information about the services we have provided to you in the past.
- Information about online registration when you request services through our online system.
- Information about your use of our websites, and mobile applications.
- Photos we use to help identify young persons or other special passengers.
How Do We Use Your Personal Information?
- To fulfill your trip requests and requirements, travel arrangements and deliver the services you have asked for.
- To communicate with you via text messages, email or voice calls; we may also send status updates as we are rendering the Services to you.
- To help keep you safe when you travel with us, use our services and to meet certain legal and regulatory requirements which apply to Air General as a travel company such as the appropriate use of our Greeter airport ID badges to assist passengers through security procedures.
- To provide services tailored to your requirements and to treat you in a more personalized manner such as adhering to dietary restrictions and preferences, specific requests to manage events or participation in local goings on during your trip.
- To carry out analysis and market research.
- To carry out marketing including online advertising and keep you informed of any changes to Air General's service offerings or new products and services.
- To improve our websites, products and services.
- For management and administrative purposes including to protect our legal rights if needed.
Is It Necessary To Collect Sensitive Personal Information?
Air General as a matter of practice attempts to limit the circumstances where we collect and process sensitive personal information. Examples of our collection and processing of sensitive personal information follow:
- If you request services from us to accommodate a specific medical condition, such as the provision of wheelchair assistance or oxygen.
- If you request services from us to accommodate special needs or desires such as specific requests because you are pregnant, traveling with young children or babies, or traveling with an ill companion.
- If you choose to provide such information to us to facilitate our provision of services or it has been passed onto us by a third party such as a travel agent or airline through which you made certain travel booking.
In addition, you may have requested services (such as a meal or delivery to a specified destination) which is not 'sensitive personal information' but may imply or suggest your religion, health or other information.
Does Air General Send You Marketing Communications?
When we have your permission, we may from time to time send you marketing communications from Air General or Air General Passenger Services. Marketing communications may include a business partners' products and services related to the travel you are undertaking, as well as our own.
We will only allow third parties or other members of our group to send marketing communications to you when you have agreed to receive marketing from third parties. We will respect your choice as to what communications you wish to receive and how these are sent.
You will only be sent marketing emails from other companies within our group where you have provided your consent to those companies.
How Can You Change Which Marketing Communications You Receive Or Unsubscribe?
If you decide you would no longer like to be sent marketing communications, you can change your mind at any time.
Each marketing communication we send by email will also have instructions whereby you can opt out from an unsubscribe option which will allow you to stop receiving further marketing emails. You may also stop any further text messages by replying with the word ’STOP.’
Alternatively, you can unsubscribe an email address by sending an email to firstname.lastname@example.org, which will stop us from sending all marketing communications to the address provided. You will need to do this for each email address you have used with us in the past.
We aim to action requests to stop being sent marketing communications within 10 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made.
Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications (as described above) which are necessary, for example, to confirm your booking or to provide you with an update on the status of your request for Services. If you ask us to stop sending marketing communications, please note we may still retain your personal information for the purposes of indicating that you do not want to receive marketing communications. If you have provided us with consent for marketing purposes, you may withdraw your consent to such processing at any time by contacting us at email@example.com.However, if you withdraw your full consent, in some circumstances, it may mean we will not be able to provide all or parts of the services you have requested from us and you will not be able to cancel your booking or obtain a refund of any charges you have paid.
What Is Our Legal Basis For Processing Your Information?
Air General will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason(s) Air General collected and needs to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be:
- Because we need to use your information so that we can process your request for our services and render you the requested services and perform the contract we have with you.
- Because it is in Air General's legitimate interests as a provider of various travel and hospitality services to assist individuals in their travel experiences to use your personal information to improve our services and to operate our business (e.g. to personalize your travel experience with us; if needed for purposes of legal claims).
- Because Air General needs to use your personal information to comply with a legal obligation (e.g. if you are trying to connect with one of our greeters, we may use your personal information to communicate with you or to assist you with your travel experience; if needed for purposes of complying with legal requirements in some countries).
- To protect the vital interests of you or another person (e.g. to assist you if you have a medical emergency and you are unable to consent, to ensure your safety).
- Because you have consented to Air General using your information for a particular purpose.
If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may, in those circumstances, be based on your consent in all cases.
How Long Does Air General Maintain Personal Information?
We will keep your information for as long as we need it for the purpose for which is being processed. For example, where you request our services, we will keep the information related to your trip and events that you have scheduled, so we can fulfill the specific driving arrangements you have made or provide the accommodations you requested. After that, we may keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the service. However, Air General generally deletes your information within 90 days from the last date of services provided to you.
When Does Air General Disclose My Personal Information?
We do not share personal information for any commercial or marketing purpose unrelated to the delivery of Air General products and services without asking you first. We do not rent or sell our customer lists. The following are limited situations where we may share information with third parties, including personal information, for the purposes described below.
We may also disclose your personal information to the following third parties for the purpose described here:
- Air General and other service providers need to deliver the passenger services you have requested from us. For instance, part of your travel itinerary may include a hotel stay, a car driver, or involves flights booked by Air General Traveler Services. These third party service providers will be identified when you make a booking.
- Accounting firms or law firms that we hire to provide professional services to our business.
- Third parties, such as law enforcement agencies and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.
- If necessary, with third parties to comply with or to facilitate Law enforcement agencies our compliance with a legal or regulatory obligation in any jurisdiction, including where that obligation arises because of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision).
- Credit and charge card companies, credit reference agencies and anti-fraud screening service providers to process payments and (where necessary) to carry out fraud-screening or enforcement.
How Do We Handle Personal Information in The European Economic Area and the UK?
The nature of our business means it is sometimes necessary for us to send your personal information outside the European Economic Area or the UK to fulfil your travel arrangements. Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and outside the European Economic Area and the UK.
In addition, we may transfer your personal information to parties in countries outside the country in which you are located in order to provide the cargo or passenger services or other requested services to you. This may involve sending your personal information to countries that have data protection and privacy laws that are less protective than those in the country where you are located.
What Are Your Options Regarding Your Personal Information?
Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated, we may extend the deadline for responding to three months, but we will let you know if this is the case.
We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons that prohibit us from granting your request.
What Are Your Rights?
Based on the law applicable to the use of your personal information, you may have rights that you can exercise in relation to your personal information particularly if you are located in the European Economic Area or other countries with similar data protection laws and regulations. These rights may be conditional or we may have to balance your rights against our rights and obligations to process your personal information or to protect the rights and freedoms of others. A number of the rights you have in relation to your personal information, as applicable in the European Economic Area, are explained below:
- Right to Withdraw Consent. As described above, we ask for your consent to process your personal information in various instances such as when you request our services. When we do this, you have the right to withdraw your consent at any time. We will stop the further processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.
- Right to Object. You may request us to stop using your personal information where we are doing so under legitimate interests. This right will be balanced with other considerations, such as whether there is a need for the information to comply with a legal request.
- Right to Restriction of Processing. You may request us to stop processing of your personal information, such as for marketing purposes or if the personal information is inaccurate.
- Right of Access. You may access the personal information we hold on you. There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally protected or privileged.
- Right of Rectification. You may ask us to correct the personal information that you have shared with us if that information is inaccurate. Note that we are not able to change or correct any data that has been created as a result of a transaction with us e.g. previous hotel stays or flight history.
- Right to Erasure. You may ask for personal information which identifies you to be removed. This right will be balanced with other considerations, such as whether there is a need for the information to comply with a legal request.
- Right Related to Automated Decision Making. If you have been subject to an automated decision and do not agree with the outcome, you can contact us and ask us to review the decision.
Information that identifies you will be removed our active systems. However, a separate and restricted copy of the identifying information will be kept for up to two years to meet the obligations we have to law enforcement, national authorities and legal proceedings.
What Do We Consider When Erasing Your Personal Information?
We may need to retain certain elements that relate to a contract between you and Air General, for our own legal and auditing purposes.
A record of your request including the personal information you supplied will be retained in the application used to carry this out for 2 years.
In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us in relation to previous travel or retain any preferences you have previously shared with us.
We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past two years. We are required to retain this information in case there is a need to re-open the complaint.
How Can You Exercise Your Legal Rights and Change How We Use Your Data?
If you wish to change how we use your personal information, please contact us at firstname.lastname@example.org. If you wish to receive a copy of any other information we hold on you, we will ask for some information to identify you, which will only be used to process your request. We will verify your identity via email before continuing with your request.
To facilitate this request, we recommend that you contact us in writing at the address above and include the following information with your request:
- Your name and postal address.
- Details of your request.
- We need corroborating information to establish your identity (e.g. a photocopy of your passport or driving license).
- Your signature and the date of the request.
- If you are applying on behalf of another person, the signed authority from the individual is required.
- Any details which may help us locate the information which is the subject of your request, for example, reservation confirmation numbers, flight numbers and dates.
Do Not Track (California residents only)
Do not Track (’DNT’) is a setting provided by your browser (depending on the browser used) that you can activate in your browser's settings to let websites know that you do not want them collecting certain information about you. Unfortunately, we do not currently have the technology to respond to DNT signals. As a result, we do not afford different treatment to California residents whose browsers send a DNT signal as opposed to those without this setting.