Privacy Policy

1 INTRODUCTION

Welcome to the Privacy Policy of Gulf Air (GF).

Your privacy is important to us and we want to assure you that that the Personal Data we collect about you will be treated with care. This Privacy Policy will inform you about how we look after your Personal Data when you visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2 DEFINITIONS

This Privacy Policy uses a number of definitions which are set out below:

Data Controller: the entity which is responsible for determining when, why and how to Process Personal Data and for establishing practices and policies in line with applicable data protection law.

Personal Data:  any information which identifies an individual or information relating to an individual who can be identified (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. For example, Personal Data can include your name, date of birth and passport number. However, Personal Data does not include anonymous data or data that has had the identity of an individual permanently removed.

Processing or Process:  any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Special Categories of Personal Data: any data which reveals details about sensitive issues such as an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about physical or mental health, or genetic and biometric data.

Supervisory Authority: the independent public authority responsible for monitoring the application of relevant data protection law. Gulf Air has designated the UK Information Commissioner’s Office (ICO) as its Supervisory Authority.

3 IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of this website or the Gulf Air mobile application, including any data you may provide through this website when you make or amend a flight booking, join our Falconflyer Program or sign up to our newsletter.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements such other notices and is not intended to override them.

Identity of Data Controller

Gulf Air is the Data Controller of all Personal Data relating to our passengers, employees and third party individual contacts, as well as any other Personal Data used in our business for our own commercial purposes.

This Privacy Policy is issued on behalf of the Gulf Air so when we mention “Gulf Air”, "we", "us" or "our" in this Privacy Policy, we are referring to Gulf Air as being responsible for processing your data. Gulf Air is the Data Controller and responsible for this website.

Data Protection Officer

Gulf Air will appoint a Data Protection Officer (DPO) who will be responsible for overseeing questions in relation to this Privacy Policy. In the meantime, if you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Contact details

  • Email address: dpo@gulfair.com
  • Postal address: PO Box 138, Manama, Kingdom of Bahrain
  • Telephone number: +973 1733 8727

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK Supervisory Authority for data protection issues (www.ico.org.uk) which Gulf Air has designated as its Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details above.

Your duty to inform us of changes

It is important that the Personal Data we hold about you is accurate and up-to-date. It is your obligation to keep us informed if your Personal Data changes during your relationship with us. Please use the following links to update your Personal Data:

Falconflyer members
https://falconflyer.gulfair.com/ffp/user/login

Manage My Online Booking
https://flights.gulfair.com/falcon/cbh/mmb/login

Third-party links

This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by Gulf Air. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you look at other websites, we encourage you to read the Privacy Policy of every website you visit.

4 THE DATA WE COLLECT ABOUT YOU

Personal Data

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

  • Identity Data includes first name, middle name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport number and Falconflyer Program membership number.
  • Contact Data includes billing address, home address (if different), email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, data about your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, Falconflyer Program membership number, bookings made by you, your interests, service preferences, feedback and survey responses. 
  • Usage Data includes information about how you use this website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and third parties (i.e. any external partners) and your preferences when receiving communications.

Aggregated Data

When you visit this website or use any Gulf Air mobile applications, we may also collect, use, store and share aggregated, anonymised statistical or demographic data (Aggregated Data). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as it cannot directly or indirectly reveal your identity.

Aggregated Data may include the time and length of your visit to this website, the pages you have visited on this website, as well as details of the website you visited immediately prior to visiting this website. We may also record the name of your internet service provider. We use this information only to measure site activity and to develop ideas for improving our services.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

It is a necessary part of our business to collect certain types of Special Categories of Personal Data about you. For example, we need to collect data about your state of health if you inform us about that you are pregnant, have a medical condition which requires special equipment, or when you make a request for mobility assistance. Making certain meal choices will also involve the collection of data about your religious beliefs or state of health, for example if you inform us that you require a Hindu or diabetic meal.

We treat our obligations to protect Special Categories of Personal Data very seriously and we will always ask your express consent to collect, process or transfer such data for specified purposes each time you provide it to us.

Personal Data relating to minor passengers

In certain circumstances, we may need to collect, process or transfer Personal Data relating to minor passengers (i.e. children under the age of 16), for example where a flight booking is made in respect of a minor passenger. This is necessary for us to pursue our legitimate interests in running our business and to perform the contract of carriage.

We will only use Personal Data relating to minor passengers for the specified purposes set out in the “HOW WE USE YOUR PERSONAL DATA” section and with the express consent of the person who has parental responsibility. Minor passengers have the same rights as any other passenger regarding their Personal Data which are set out in the “YOUR LEGAL RIGHTS” section.

Providing Personal Data on behalf of other passengers

By providing us with Personal Data, including Special Categories of Personal Data, relating to other passengers on your booking, you are representing that you have their authority to provide their Personal Data to us and to consent to their Personal Data being collected and processed for the specified purposes. Gulf Air is entitled to rely upon such representations.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept your booking, but we will notify you if this is the case at the time.

5 HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide to us when you:
  • book a flight or arrange any other service with us;
  • create an account on this website;
  • join our Falconflyer programme;
  • apply for a career with us;
  • subscribe to our newsletter;
  • enter a competition, promotion or survey; or
  • submit an enquiry or give us some feedback.

This website. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the “HOW WE USE YOUR PERSONAL DATA” section and our Cookie Policy for further details.

  • Our mobile website and mobile applications. Our mobile website and mobile applications have the ability to access mobile device information to better serve passengers in the service that is used. We may use location data for our mobile website and mobile applications to enable us to provide the most helpful format and content (for example pre-populating your departure airport based on current location) providing that you have agreed to the use by Gulf Air of your location data. If you would like to restrict our collection of your location data, please adjust the settings on your device.
  • Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:

o Data from the following parties:

  1. analytics providers such as Google based outside the European Economic Area (EEA)[1]
  2. advertising networks based inside OR outside the EEA; and
  3. search information providers based inside OR outside the EEA.

o Contact, Financial and Transaction Data from providers of technical or payment services based inside OR outside the EEA].

o Identity and Contact Data from data brokers or aggregators based inside OR outside the EEA].

6 HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data as permitted by law. Most commonly, we will rely on the following types of lawful basis to process your Personal Data:

  • Legitimate Interests: the interests of Gulf Air in conducting and managing our business in order to give you the highest standard of service and the best and most secure travel experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests.

We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your express consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Performance of Contract: processing your Personal Data is necessary for the performance of the contract of carriage to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation: processing your Personal Data may be necessary for compliance with a legal or regulatory obligation to which we are subject.

For example, in accordance with Article L 232-6 of French Internal Security Code, we may transmit reservation, checking or boarding data collected from passengers (API/PNR) to the French national public services and competent authorities for the purposes and under conditions as defined in the Decret N° 2014-1095 dated 26 September 2014.

  • Consent: in certain circumstances, we may ask for your express consent to collect, process or transfer your Personal Data, for example in relation to opting into receiving our newsletter or other direct marketing. You have the right to withdraw your consent at any time simply by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we will use your Personal Data, and which types of legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying upon to process your Personal Data where more than one basis has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new online account holder or Falconflyer member

(a) Identity

(b) Contact

Necessary for our legitimate interests (for running our business)

 

To process your flight booking including:

(a) Contacting you regarding your travel arrangements

(b) Manage payments, fees and charges

(c) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To arrange any special assistance you require or make arrangements for special medical equipment, which may necessitate providing the data to our third party suppliers

(a) Identity

(b) Special Categories of Personal Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to enable us to assist you in boarding your flight and travelling safely)

(c) Express consent requested during the booking process

 

To arrange meal choices which may identify your food preferences, religious beliefs or state of health, which may necessitate providing the data to our third party suppliers

 

(a) Identity

(b) Profile

(c) Special Categories of Personal Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to enable us to provide you with a meal which fits your food preferences, religious beliefs or health restrictions)

(c) Express consent requested during the booking process

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our conditions of carriage,  Privacy Policy or any other terms and conditions

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to study how passengers use our services and to enable us to offer better services to you in the future)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how passengers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how passengers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve this website, services, marketing, passenger relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of passengers for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our services, grow our business and offer more suitable services to you in the future)

 
Cookies

This website makes use of cookies to measure site activity and to customise information to your personal tastes. A cookie is an element of data that a website can send to your browser which may then store the cookie on your hard drive, either temporarily or long term. This means that, when you visit this website in future, we can tailor information to suit your individual preferences which can save you time and provide you with a more personalised visit.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you to explain the legal basis which allows us to do so or, where required by law, to seek your consent.

7 MARKETING

We aim to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this “marketing”).

The “soft opt-in”

You will continue to receive marketing communications from us if you have previously booked flights or purchased other services from in the past, or if you have requested information from us in connection with a potential booking or purchase, unless you have opted out of receiving future marketing communications.

Third-party marketing

We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8 DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your Personal Data for the purposes set out in the table in the “HOW WE USE YOUR PERSONAL DATA” section with third party service providers.

Disclosure of your Personal Data within Gulf Air

All parts of Gulf Air, including outstations, branches and offices acting as joint controllers or processors and which are based in EEA and non-EEA countries, e.g. the Kingdom of Bahrain, and provide IT and system administration services.

Disclosure of your Personal Data to External Third Parties

  • Service providers acting as processors based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who provide IT and system administration services to Gulf Air.
  • Service providers and suppliers acting as processors based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who provide passenger services, such as ground-handling companies, catering providers, and companies providing assistance for passengers with reduced mobility.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, consultants, auditors and insurers based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities acting as processors or joint controllers based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

9 INTERNATIONAL TRANSFERS

Internal Transfers

We will share your Personal Data within the Group. As Gulf Air’s head office is based in Bahrain, it will be necessary to transfer Personal Data which was collected in the EEA outside of it.

We ensure your Personal Data is protected by requiring all of our Group companies, branches, offices and outstations to follow the same rules when processing your Personal Data. These rules are called "Binding Corporate Rules". Gulf Air’s Binding Corporate Rules are found under the Transparency section.

External Transfers

Many of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Data to third parties which are based outside the EEA, we ensure a similar degree of protection is afforded to the data by ensuring at least one of the following safeguards is implemented:

  • Certain non-EEA countries to which we will transfer your Personal Data have already been deemed by the European Commission to provide an adequate level of protection. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
  • Where we use third party service providers based in the US, we may transfer data to them if they are covered by the EU-US Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
  • Where we use certain third party service providers which are not based in the EEA or the US, we may use specific contracts approved by the European Commission which give your Personal Data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

10 DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11 DATA RETENTION

How long we retain your Personal Data

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure in the "YOUR LEGAL RIGHTS" section for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12 YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

  • Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes (and you will always be able to opt-out via the “unsubscribe” link on an email from us). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following situations: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to information which was originally collected electronically and which you either consented to us using or was used to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee (taking into account the administrative costs of providing the information) if we consider your request to be unfounded, repetitive or excessive.  Alternatively, in these circumstances, we may refuse to comply with your request but we will provide you with a full explanation of this at the time.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will respond to all legitimate requests within one calendar month. If your request is particularly complex, or you have made a number of requests, it may take us up to 3 calendar months to respond (instead of the 1 calendar month mentioned earlier), but we will notify you of this and keep you updated.

13 CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. This version of the Privacy Policy was last updated on 21 May 2018. Historic versions of this Privacy Policy can be obtained by contacting us.

 

[1] The EEA is composed of the 28 EU Member States plus Norway, Iceland and Lichtenstein.  

Version: 21-May-2018