6.1 For what purposes do we use your information?
We will use your information for a variety of different purposes some of which will be dependent on the services that you engage us for. This includes:
● To facilitate your travel with us. We will use your information to provide you with any services that you request or purchase from us. This includes providing your flight, checking you in to your airport, administering your Flying Club and/or Flying Co membership, (including earning and redeeming points and other benefits),providing your lounge access, managing the transit of your luggage, providing you with any special assistance, providing you with airport transportation, issuing you with your tickets (on the basis of performing our contract with you or where you have provided your consent);
● To send you service communications and support services. We will use your information to send you any communications relevant to the services or products you’ve requested or purchased from us. This includes sending you an e-ticket for your flight, and sending you an email to notify you of changes to your flight time or itinerary. We will also provide you with customer service and support, deal with your enquiries, scheduling changes, complaints, comments or observations shared with us and monitor your progress through airport check in to ensure that you make your flight (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with customer service);
● To manage our relationship with you. This includes notifying you of changes to our terms of use or privacy policy, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
● To send you marketing communications. We will use your information to keep you up to date with our latest news, offers and competitions (including, where applicable, relating to Flying Club) unless you have told us that you’d prefer not to hear from us. We (or our partners or service providers on our behalf) may do this using analysis compiled from information we have collected from you or which we have generated about you or which we have lawfully received about you from our partners (on the basis of our legitimate interests to provide you with marketing communications where we may lawfully do so or where you have provided your consent). Please see the “MARKETING” section below for more information;
● To provide you with suggestions and recommendations. To share your information with selected third parties such as suppliers and partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
● To enable you to join Flying Club and/or Flying Co or update your details. We will use the details provided on your account registration form and any amendments to your online profile (on the basis of performing our contract with you);
● To process and facilitate transactions with us. We will use your information to process transactions and payments, e.g. for flight bookings or purchases on our Retail Therapy store, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
● To personalise and improve your customer experience. We will use your information to provide you with a more personalised service. For example, tailoring the communications we send to you with your preferred routes, serving you only with advertising that we think you might like, acknowledging your tier status with us and/or any inflight preferences (on the basis of our legitimate interests to present you with the right kinds of products and services);
● To improve our customer service. We will record calls to our call centre and/or monitor calls for the purposes of improving our customer service, ensure quality assurance, training, security and for general business purposes (on the basis of our legitimate interest in improving our customer service);
● To enable us to interact with you on social media platforms. These include Facebook, LinkedIn, Twitter, Instagram and YouTube, for example, posting status updates, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
● To process your job applications. We will use your information to process any job applications you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);
● To optimise our site and app. We will use your information to provide you with access to our site and application in a convenient and optimal matter, and with personalised content relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users);
● To ensure security and protect our business interests. We will use your information to ensure the security of our services, buildings, and people, including to protect against and investigate and deter against fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business, where we have a legal obligation to do so, for establishing exercising or defending legal claims or for reasons of substantial public interest);
● To determine your fitness to fly. In certain circumstances, we will use your information to determine whether it is safe for you and/or other passengers to fly with us (on the basis of your consent);
● To conduct research. We will use your information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you chose to participate in customer surveys, consumer focus groups and research (on the basis of our legitimate interests to improve our products, services and customer service);
● To detect fraud, terrorism and unlawful activities. To protect against, investigate, and deter fraudulent, unauthorised, or illegal activity, including identity fraud, terrorism and other types of unlawful conduct (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
● To comply with our legal obligations, policies and procedures. We will use your information to enable us to:
- Comply with our policies and procedures, and our legal obligations (for example adhering to court orders and subpoenas);
- To enforce our legal rights;
- To protect the rights, property and safety of staff, passengers and others;
This includes sharing your information with our lawyers, technical advisors, law enforcement and other regulatory bodies where necessary.
Occasionally we will use your information to make decisions about what communications you would like to receive from us in order to improve your customer experience.
6.2 On what grounds will we process your information?
We will use your information for the purposes listed above, either:
● For the performance of your contract with us and the provision of our contract with you;
● To comply with a legal obligation;
● For our legitimate interests (we explain what we mean by this below);
● To protect your or another person’s life;
● With your consent;
● For establishing, exercising or defending legal claims; or
● For reasons of substantial public interest.
6.3 What do we mean by “legitimate interests"?
As outlined above, in certain circumstances we (or partners on our behalf) may use your personal information to pursue legitimate interests of our own or that of third parties, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you, our customers. This involves:
● Providing you with and improving our customer service (including sharing data with our service providers and partners for the purposes of providing you with our goods and services, including to help us provide and administer your Flying Club membership and benefits);
● Determining the effectiveness of our site/tools/services and improving the security and optimisation of our network, sites and services;
● Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;
● Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing in certain circumstances, and serving you with advertising that is relevant and likely to be of interest to you;
● Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business;
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. We won’t use your information if we believe your interests should override ours, unless we have other lawful grounds to do so (such as your consent or if we have a legal obligation. If you have any concerns about our processing please refer to details of “YOUR RIGHTS” section below.
As we outline in “YOUR RIGHTS” section below, you will have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.