PRIVACY POLICY

Luxwing Ltd Privacy Policy
  1. Controller of Personal Information

Luxwing (collectively, the “Company”, “we” or “us”), is committed to safeguarding the privacy and personal information of our customers and business partners, (collectively; “you” or “your” means you, the person who provides us with personal data; and “personal data” shall have the meaning assigned to it in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council).

This Privacy Policy (this “Policy”) explains how we may collect, use, process, share, and store personal information about you, including through designated third-party service providers, and the choices that are available to you regarding this information.

Luxwing Ltd (a company with registration number C-53330, with principal offices at 15, Mannarino Road, Birkirkara, BKR9080 – Malta) is the data controllers.

If you have made a flight booking with us but one or more flights are to be provided by other airline(s)/operator(s) then that other airline/operator will also separately be considered a “data controller” under European Union data protection law. You can access the privacy policies of the other airlines via their own websites.

Any provider of services such as a caterer, a hotel or car rental company will also separately be a “data controller”. You can access the privacy policies of those providers from them directly.

The main establishment of Luxwing for purposes of the GDPR shall be Malta (Europe).

Please read this Policy carefully to understand our views and practices regarding your personal information and how we will treat it.

In addition to information kept in hardcopy, this Policy also applies to our company websites, and other online services that we offer which link to this Policy. Also note that our websites may contain links to other websites; if you follow a link to any of these websites, you should read their own privacy policy/notices.

 

  1. What information do we collect about you?

We collect information about you when you open an account with us, purchase our products and services and/or remit payment for services. We also collect information about you using cookies, and if you interact with us via phone and/or websites.

The types of information that you may give us vary depending on the specific entity with which you are doing business, and/or the particular services requested.

For example, you may be purchasing a flight, catering products, shuttle bus, taxi, cars and/or related services, engaging with us to provide a service. The information you may give us could include categories such as, but not limited to, your name, work or personal address, e-mail address, phone number, date of birth, gender, financial and/or credit card information, passport or driving license information, national ID number, personal description and/or photograph, as well as customer data, payment data, employee data and/or website user data.

This personal data may include information that you provide to us directly or through companies or agents we work with, as well as information which we collect when you use our products or services.

Any products and/or services acquired by you from us will be subject to their own terms and conditions which you must also read and accept. In the event of any conflict between this Policy and the terms and conditions of any such products or services (such as, without limitation, those terms and conditions in any Luxwing Ltd Agreement, or, in the Luxwing General Terms and Conditions of Carriage), then the terms and conditions of those products or services shall prevail.

 

  1. When and why do we collect personal ‘sensitive data’?

Personal data which are, by their nature, particularly sensitive in relation to fundamental rights and freedoms merit specific protection as the context of their processing could create significant risks to the fundamental rights and freedoms. Those categories of personal data, such as that about race, ethnicity, religion or health, are considered “sensitive data” in terms of applicable law.

Sensitive personal data will only be processed where:

  • you have requested specific medical assistance from us and/or an airport operator, such as the provision of wheelchair assistance or oxygen, or,
  • you have sought clearance from us to fly with a medical condition or because you are pregnant, or,
  • you have otherwise chosen to provide such information to us (or a third party such as the agent or broker through which you made your booking).

By providing any personal data that is, or could be considered to be “sensitive data”, you explicitly agree that we may collect, use, share with third parties and transfer such data, within and outside of the European Economic Area, in accordance with this Policy.

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  1. How do we use the information about you?

The main purposes for which we use your personal information are:

  • To fulfil your request and deliver the services you have asked for, and provide information to relevant authorities.
          • Example: For the purposes of accounting and billing, immigration and customs control, health and safety, security and legal compliance;
  • To manage the boarding process and to facilitate flight connections at the airport.
          • Example:
            • To send status updates and service communications to you.
            • We may send a communication informing you that aircraft is ready and waiting for you or if your flight has been delayed.
  • To keep track of you in advance of your flight and at the airport.
          • Example:
            • If you have presented at departure airport to gain access to one of the lounges (where available) we use.
  • To help keep you safe when you fly with us and to meet certain legal and regulatory requirements which apply to Luxwing as a Commercial Air Transport (CAT) operator.
          • Example:
            • As a CAT operator there are regulatory obligations on Luxwing to maintain a record of passenger information on our aircraft.
            • The laws of certain countries, such as but not limited to the UK and USA, require airlines to provide certain passenger information to the border and immigration authorities.
  • To provide services tailored to your requirements and to treat you in a more personal way.
          • Example:
            • We may personalise the experience you have while flying with us. For example, a member of our cockpit or cabin crew may welcome you back on board a Luxwing flight.
            • We may update and share information with our media agency, in order to serve tailored and relevant advertising from our partners and third parties on our websites,
  • To carry out analysis and market research.
          • Example:
            • We will analyse the way in which our sales channels, products and services are being used by customers so that we can understand how to improve the service we offer and encourage customers to use the full range of our products and services.
  • To carry out marketing including online advertising and keep you informed of Luxwing’ products and services.
          • Example:
            • We may send you information about our products and services by email or text message.
            • We may tailor the content of our websites, emails and other communications to ensure they are as relevant to you as possible – including previous destinations including offers and/or services relating to that or a similar destination.
            • Understand your flying preferences and provide information about offers, such as upgrades.
            • If you’ve searched for flights but not booked, we may remind you about our services via email or through online advertising e.g. Twitter, based on the flights you searched for previously.
            • We may combine/match customer relationship marketing data with a third party (e.g. Google) so both companies can understand behavioural activities such as knowing other sites visited.
  • To undertake targeted online advertising.
  • To send you status updates and service communications.
          • Example:
            • Even if you have opted-out of receiving marketing information from us, we may still send you communications about the services you have booked to use, such as your travel itinerary. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using (e.g. additional baggage and pre-booked meals).
            • We may also send you communications about the services you have previously used, for example, where you experienced some form of issue or problem and we wish to contact you about it proactively in order to resolve it successfully.
  • To improve our websites, products and services.
          • Example:
            • We may monitor the way that you and other customers use our website so that we can identify ways to improve the website experience.
  • For management and administrative purposes.
          • Example:
            • We may use and retain your personal information, including your purchase history, for administrative purposes, which may include for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud screening (including the use of credit reference agency searches and payment card validation checks) and systems testing, maintenance and development.

 

  1. Who do we share your personal data with?

Your personal information may be shared with other third parties:

    • air operators, and other third parties in order to give effect to our obligations under any contact entered into between you and us for the provision of flight services;
    • Customs and immigration authorities of any country in your itinerary or to which your flight may fly over. Luxwing is required by laws in the UK, USA and other countries to give border control agencies and customs authorities access to booking and travel information when you fly to and from countries including stop-overs and where you may overfly countries to your destination.
        • Further information about www.gov.uk.
        • Further information about Passports, visas and API (Advanced Passenger Information).
    • Airlines/operators and other service providers needed to deliver the services you have asked for where, for instance, part of your travel itinerary involves a flight operated by a different airline or includes car hire or a hotel booking. Those airlines/operators and other service providers will be identified when you make a booking.
    • 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.
    • In response to a valid, legal request from Government and law enforcement agencies such as customs and immigration authorities.
    • Third party service providers we are using to provide services that involve data processing, for example, to carry out marketing initiatives or run customer surveys on our behalf.
    • Third parties, such as law firms and law courts, to enforce or apply any contract with you.
    • Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.
    • We may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites (see how we use ‘Cookies’ and other methods for the collection of website usage data’ above).
    • We may provide usage information including your personal details to marketing agencies to deliver online advertising on websites or social networks.
    • If necessary to comply 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).

 

  1. When do we collect personal information about you?

We collect personal information about you whenever you use our services or products (whether these services are provided by us or by other companies or agents acting on our behalf), including when you book a flight or series of lights, when you travel with us and use airports where we operate or if you use lounge facilities provided by us or our agents, when you use our website, or interact with us via email or use our contact/call centres.

For additional details see ’What information do we collect about you?” above.

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, including airlines involved in your prior or onward journey, relevant airport operators and customs and immigration authorities.
  • if you complete a client survey or provide us with feedback.
  • if you choose to interact with us via social media, such as Facebook.

 

  1. Providing information about someone else

If you are providing personal data to us about someone else you confirm that they have appointed you to act for them, to consent to the processing of their personal data, and that you have informed them of our identity, of this Policy, and of the purposes (as set out in this Policy) for which their personal data will be processed.

 

  1. Your rights

You may contact our Privacy Office (please see below) to exercise any of the rights you are granted under applicable data protection laws, which includes  the right to access your data, to rectify them, to erase them, to restrict the processing of your data, the right to data portability and the right to object to processing. You may withdraw your consent at any time.

When you would like to exercise your rights, all you have to do is send your request to the Privacy Office of Luxwing:

Luxwing Ltd

15, Mannarino Road,

Birkirkara, BKR9080

Malta

Email: security@luxwing.com

 

  1. Consent of minors in relation to digital services

To be able to use the services provided through the website it is necessary to be older than 16; the processing of personal data of those under 16 is allowed, provided that it is exercised by the persons exercising parental responsibility.

 

  1. Security and Retention

Luxwing will take appropriate technical and organisational measures to protect your personal data against loss or unlawful use. Your personal data will be retained for as long as required for the purposes described in this privacy policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

 

  1. Internet

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

 

  1. Cookies

What are cookies?

Cookies are small data files which are downloaded onto your device by the website which you are visiting. The next time you visit the same website, cookies ensure that your device is recognised. By using cookies and similar technologies such as pixel tags/beacons and scripts (‘cookies’), this website can save information about visits and visitors. We place some of the cookies on the websites ourselves, while other cookies are placed by third parties. Third-party cookies may collect data outside our websites as well.

Cookies can be utilised to make visiting a website more personal, by, for instance:

    • displaying relevant navigation settings;
    • remembering visitors’ preferences;
    • improving the overall user experience and
    • limiting the number of advertisements shown.

Luxwing’s use of cookies

By clicking ‘agree’ when the cookie notice is shown or by continuing to use the website, you thereby give consent for cookies to be placed and read out on luxwing.com and the associated sub-domains if any. Luxwing uses the information which it has collected through cookies for the purposes stated in Luxwing’s Privacy Policy.

 

Luxwing.com uses three types of cookies

Functional cookies

These are cookies which enable users to view luxwing.com, use the functions on the websites and gain access to secured portions of them. The information collected through these cookies is not used for marketing purposes. If use of this type of cookie is not allowed, this will have the following consequences:

using various parts of Luxwing.com will become impossible;

Luxwing can provide less support to users;

Luxwing will be unable to remember your preferences for not using or displaying a specific function.

Analytic cookies

These cookies help Luxwing to improve its websites. The cookies collect information about the way in which visitors use Luxwing.com, including information about the pages most visited or the number of error messages displayed. WebAnalytics cookies are one example of this type of cookie.

Marketing and other cookies

Marketing cookies are typically placed on Luxwing.com by advertising networks. These networks are companies which act as intermediaries between Luxwing and advertisers. These cookies are used to:

  • show relevant, personalised advertisements or offers through every type of medium (such as e-mail, social media and banner ads) based on your visit to and click behaviour on Luxwing.com;
  • limit the number of times each advertisement is displayed;
  • measure the effectiveness of an advertising campaign;
  • make a link with social media, so you will be recognised when you wish to use social media through luxwing.com.

 

Adjusting cookie settings and deleting cookies

If you do not want Luxwing to place cookies on your device, you can refuse the use of cookies through your browser’s settings or options. You can also refuse just our partners’ cookies. You need to separately adjust the settings for each browser and each computer. The links below will take you directly to your browser’s user guide.

Please note that, if you adjust the cookie settings for Luxwing, you may not be able to correctly use some parts of Luxwing.com afterwards.

 

More about cookies

‘Your Online Choices’ (www.youronlinechoices.com) is a website offered by the internet advertising industry which contains information about ‘behavioural advertising’, ‘online privacy’ and opt-out options.

 

  1. Updates to our Privacy Policy

As appropriate, we may make changes to this Privacy Policy that will be posted online. Please check back frequently to remain aware of any updates or changes to this Privacy Policy.

This Policy is effective as of the “Effective Date” reported at the top of this Policy.

It is in your own interest to access this page regularly to view the latest version of this Policy. If we make a change or modification to this Policy, we may, where appropriate and where possible in our sole discretion, alert you with a notice on our website or with any other means of notification we deem fit. Your continued access to or use of any of our services or products or your purchase of any of our products or services (that is entirely voluntary) or your continued provision of personal data to us following any change or modification to this Policy shall be deemed your acceptance to be bound by any such changes or modifications.

 

  1. How to contact us

If you have additional questions, or believe you are eligible to submit a subject access request, you can reach us by email at security@luxwing.com or by post at:

Luxwing Ltd

Attn: Privacy Administrator

15. Mannarino Road

BKR 9080 – Birkirkara

Malta

Please be aware that when we receive a formal written complaint regarding the processing of personal data, we try to resolve it directly with the person who has made the complaint, or with the data controller when we are acting as a data processor. However, as necessary, we will work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding our processing of personal data that we cannot resolve with a complainant directly.