Stobart Air is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following.
- What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
- All personal data is collected and processed in accordance with Irish and EU data protection laws.
“Stobart Air” (referred to as “we”, “us”, “our” or “Stobart Air” in this policy) in this policy primarily refers to Stobart Air UC, the main operating company of the Stobart Air group, and, where appropriate, to other companies in the Stobart Air group or other entities over which Stobart Air exercises management control. Stobart Air UC, is the “data controller” of all personal information that is collected and used about Stobart Air customers for the purposes of General Data Protection Regulation. Stobart Air is registered in Ireland with registration number 28858 and registered offices at Stobart Air 1 Northwood Avenue, Santry, Dublin 9, Co. Dublin, D09 V2F7.
What Personal Data we collect
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, booking reference number, payment details and information about your access to our website.We may collect personal data from you when you book a flight with us (indirectly through our partners Aer Lingus & FlyBe), use our website or when you contact us. Specially we may collect the following categories of information:
- Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, credit/debit card or other payment details;
- Advance Passenger Information, which includes your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;
- Medical conditions for passengers who have special medical requirements and/or dietary requirements;
- Travel history, including information related to your flights and services booked in connection with your flights;
- Information you provide about your and your companions’ travel preferences;
- Information about your purchases of our trusted partners’ products and services;
- Information about your use of our website;
- The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media;
- Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitive” personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary (for instance if you request special assistance), or you have deliberately made it public.
What do we use your personal data for, why and for how long
Your data may be used for the following purposes:
- Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your flight, including requested flight changes;
- Contacting you in the event of a flight time change or cancellation: we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
- Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
- Immigration/customs control safety: we may be obliged to provide your information to border control agencies;
- Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
- Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
- Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your travel with us and to personalise the services we offer to you, such as special offers to your favourite destinations or Family Plus deals;
- Processing your job application or request for information in relation to vacancies;
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for. In most cases we will need to process your personal data so we can enter into our contract of carriage with you.We may also process your personal data for one or more of the following reasons:
- To comply with a legal obligation (e.g. Immigration or customs requirements);
- You have consented to us using your personal data (e.g. for marketing related uses);
- To protect your vital interests or those of another person (e.g. in case of a medical emergency);
- It is in our legitimate interests in operating as an airline (e.g. for administrative purposes).
Only children aged 16 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required. We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means. We must also consider periods for which we might need to retain personal data in order to meet our legal obligations (e.g. in relation to claims for cancelled flights under EU Regulation 261/2004) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made. When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
Stobart Air operates businesses in multiple jurisdictions, all of which are located in the European Economic Area (EEA)1. While countries outside the EEA do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with Irish and EU law on data protection. For any new processing activities that will require processing outside of the EEA we will complete a DPIA and utilise standard means under EU law to legitimise data transfers outside the EEA. 1Policy to be revised once The United Kingdom exits the EU.
Sharing your personal data
- Government authorities, law enforcement bodies, regulators and airports in your itinerary or to which your flight may fly over for compliance with legal requirements;
- Trusted GDS (Global Distribution System) agents through which you book your Stobart Air flight;
- Trusted service providers we are using to run our business such as ground handling agents assisting our passengers at airports in all countries we operate in, call centres providing assistance to our customers, cloud service and e-mail marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns;
- Commercial banking partner which facilitate our requirement to occasionally process refund payments directly to customers.
- Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
Cookies and site tracking
Data Protection Management
We have appointed data protection manager responsibility to oversee compliance with this policy. If you have any questions about this policy or how we handle your personal information, please contact us firstname.lastname@example.org. You have the right to make a complaint at any time to a supervisory authority. The Irish Data Protection Commissioner is the lead data protection supervisory authority for Stobart Air as an Irish data controller.
Your Data protection rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please email us at email@example.com the following link or contact us by post at Data Protection Manager, Stobart Air, 1 Northwood Avenue, Santry, Dublin 9, D09 V2F7. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.