Privacy and Security Policy
We are Jet Airways (India) Ltd (“Jet Airways”), of Siroya Centre, Sahar Airport Road, Andheri East, Mumbai 400 099, India. We are a Scheduled Airline in India and engaged in the business of providing services of air transport and cargo and services ancillary and related thereto (“Services”).
Our data protection officer is located in India and can be contacted at firstname.lastname@example.org
Our European Union representative is located at Jetair House, 188 Hammersmith Road, London, W6 7DJ, United Kingdom and can be contacted on email@example.com
Any personal information received by Jet Airways in the course of providing Services is controlled by us and so we are considered the data controller of your personal information. If you have made a flight booking with us but one or more flights are to be provided by other airline(s) then those other airlines will also separately be considered a “data controller” under European Union and UK data protection law. Any entities providing additional services such as entities providing insurance, hotel or car rental services will also separately be a “data controller” of your information if you sign up for such additional services. You can access the privacy policies of these entities from them directly.
Data Protection Laws
We have to comply with the data protection laws of India and other countries that we fly to including Data Protection Act no 2472/1999, Law no 3471/2006 and from 25 May 2018 the General Data Protection Regulation (EU) 2016/679 when keeping personal information about you and when we obtain, use, disclose or otherwise process such data.
We are committed to protecting your personal information and respecting your privacy.
This policy explains about the personal information that we collect from you, use, disclose or otherwise process in connection with your relationship with Jet Airways as a customer. In particular, we explain the kinds of personal information that we collect from you, how we collect it, what we use it for and who we may share your personal information with. By “personal information” we mean information about you where you are, or could be, identified.
Further we will also use and disclose your personal information to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry. In particular, each of the passengers who are grouped under the same Passenger Name Record (“PNR”) number shall be deemed to be authorised representatives of each of the other passengers under the same PNR number.
If you or any passenger travelling has special health, dietary or access requirements, which you or they would like us to be aware of, you need to inform the same to us in advance of your travel through the website, contact centre or any of our airport/city ticketing offices enabling us to process the said information and your request accordingly.
Where making a reservations through our airport, city offices or agents in countries where we function through agents, you may update your preferences for communication by filling out the form made available at our airport offices, city booking offices and such agents.
Categories of Personal Information We Collect
We collect personal information from you such as your name, address and contact details, your travel arrangements and purchase history, your credit/debit card number (including expiration date), passport number and nationality, health information e.g., medical records or requests such as dietary preferences and information about how you use our services and about how you use access to our websites, call centres and mobile applications. This 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 services.
Sensitive Personal Information
Certain categories of Personal Information, such as health or biometric information are considered to be special categories of data requiring additional protection under European Union and UK data protection law and is referred to here as “Sensitive Personal Information”. You may choose to share Sensitive Personal Information with us directly (or through authorised persons, travel agents, other airlines) in certain circumstances by providing your medical history or dietary preferences. We collect and process Sensitive Personal Information only when it is essential. Examples of where we may collect and process ’sensitive personal data’ includes the following:
- where you have requested specific medical assistance from us and/or an airport operator, such as the provision of a wheelchair, medical assistance or extra oxygen for the flight; or
- where such information has been passed onto us by a third party, where you have given that third party consent to do so, such as the travel agent through which you made your booking or from other airline for your onward journey, where the processing of such Sensitive Personal Information is required for the processing of your service request.
How We Collect Your Information
We collect Personal Information about you whenever you use our services (whether services provided directly by us or by other companies or agents acting on our behalf), when you travel with us, when you use or purchase tickets through our website, when you use our website through interactions with our staff and cabin crew, when you use our contact centres or mobile applications, or interact with us via email or social media platforms such as Facebook, LinkedIn, Instagram or Twitter, or when you book to use our services through third parties (such as travel agents and other airlines).
Jet Airways may occasionally collect personal information through its sponsoring of promotions and contests to give its guests the opportunity to win various prizes.
Jet Airways may occasionally collect personal information through its carrying out of, or sponsoring of, optional customer services.
Jet Airways may also receive Personal Information about you from third parties such as companies we have contracted with to provide services to you or other airlines involved in your journey, relevant airport operators and customs and immigration authorities.
Why We Collect Your Information
Jet Airways collects Personal Information directly from you or from your authorised representatives (i.e. persons whom you have authorised to do so, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., your travel agent or our service provider), through our website, mobile services, and other channels including our ticketing counters and airport operations.
We use your Personal Information to conduct our business and to provide you with the best possible services and travel experience including to:
- provide the travel, travel updates, upgrades, check-in and other services you have asked us to provide;
- facilitate payment card verification and screening;
- provide you with your e-ticket for travel;
- provide information to relevant regulators and authorities (such as tax, customs and immigration authorities);
- personalise your travel experience;
- communicate with you about administrative details;
- for the purposes of 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;
- request feedback on the travel, our services and products through customer surveys;
- communicate with you about the travel and travel related services and product offerings including information about delays, gate changes etc.;
- provide you with marketing, offers and promotions from us or our partners (where we have your permission to do so).
- to resolve an issue or problem, in which case you may be contacted by our guest relations team, sales staff or legal and professional advisors in order to resolve the same efficiently;
- improve our services; and
- comply with our safety and security requirements and meet our legal obligations.
Personal information collected from JetPrivilege members by JPPL is used to ensure the members receive applicable mileage credit for travel purchases, for participating flights and other JetPrivilege partners activities/benefits. This personal information is also used by JPPL to communicate with the members concerning their JetPrivilege account and to notify them of any special promotions they may be eligible for. Jet Airways may also use JetPrivilege members profile information to perform a number of functions including but not limited to:
- pre-filling certain data fields;
- performing certain booking functions;
- billing the member for its reservation;
- sending the member offers that may be of interest; and
- notifying the member of a flight change, reservation confirmation or a special fare offering.
Who Else May Have Access to Your Information
To best serve you, we may share your personal information with our associates, partners, wholly-owned subsidiaries, JPPL as well as service providers that provide support services to us or that help us market our products and services or process personal information on our behalf. Service providers are third parties who perform services on our behalf, including local agents who help manage customer needs at airports contractors who help us run our office operations and provide baggage delivery and repair services. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from Jet Airways.
In particular and in order to facilitate your service request, as part of our legal and contractual obligations, we will often need to share your personal information with third parties such as other airlines when there is a codeshare and airport operators, customs and immigration authorities and travel agents involved in making your travel arrangements. We also share your personal information with third parties who deliver services either to you or to us, such as companies that provide airport assistance, purchase of duty free products inflight or with banks and payment providers, to authorize and complete payments.
In particular and in order to facilitate your travel arrangements, we will often need to share your personal information with third parties such as other airlines when there is a codeshare and airport operators, customs and immigration authorities and travel agents involved in making your travel arrangements. We also share your personal information with third parties who deliver services either to you or to us, such as companies that provide airport assistance, purchase of duty free products inflight or with banks and payment providers, to authorize and complete payments.
Occasionally, Jet Airways may provide customer mailing lists and email addresses to reputable, carefully screened partners or other companies whose services and products may be of interest to you.
We may also disclose your personal information to a third party when you ask us to do so or when we believe it is required by law or under a contract.
Personal Information will be disclosed to our legal advisors for establishing, exercising or defending our legal rights and to our other professional advisors, or as otherwise authorised or required by law.
Jet Airways may disclose your personal information to law enforcement agencies and government for security, customs and immigration requirements. Mandatory personal information (known as Passenger Name Record (PNR) or Advance Passenger Information (API)) will be disclosed to the appropriate customs and immigration authorities as required by the immigration authorities of the countries where you are travelling. Do note that the initial recipients of such information may share your PNR and API data with other government agencies or enforcement authorities.
Countries Having Access to Your Information
We may need to transfer your Personal Information across our other offices to help provide the Services in the course of operating our business efficiently. We also allow third party service providers to process Personal Information where this is needed in connection with a service they provide to us. These arrangements may involve your Personal Information being located in various locations around the world. The countries to which we commonly disclose your personal information include India, where we have our corporate office, United Kingdom and the countries where you are flying to and from, in these circumstances Jet Airways will enter into agreements with those processors incorporating the Model Contract Clauses to ensure an adequate level of protection of your Personal Information.
Our servers, storing and keeping your information secure, are located in countries which either have an adequate level of protection or with which Jet Airways will have agreements incorporating the Model Contract Clauses.
Collecting Your Information Legally
We are able to legally collect and use your personal information either because:
- you have provided us with your consent to do so as explained above; and/or
- collecting and using your personal information is necessary for us being able to provide Service requested, including but not limited to:
- send product and operational communications relating to Service requested
- process any flight purchases made or provide you with any flight related services and products;
- carry out our legitimate business interests in order to carry out any requests or orders made by you or process any special service requests made by you via our website, call centres or our airport/city ticketing office;
- comply with a legal obligation;
- to send out any communication as may have been directed to us by government of any state or local authorities; or
- protect the vital interests of you or another person.
Retention of Your Information
We will only retain your personal information for as long as it is necessary to process your Service request, including flight purchases, keep you up to date with Jet Airways’ promotions where you have asked us to do so and/or to provide you with the best customer experience possible and pursuant to the requirements of law including laws of India. Retention is therefore necessary for the purposes of our legitimate interests (for example, to deal with any claims or queries which you have relating to your flight purchases), or where we are required to do so by law.
We will actively review the information we hold and delete it securely, or in some cases anonymise it/encrypt it, when there is no longer a legal, business or customer need for it to be retained.
You have the right to:
- obtain confirmation from us that your personal information is being collected and used by us and how to access the personal information held about you by us;
- have your personal information corrected if it is inaccurate or incomplete at any time;
- erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information we hold about you at any time;
- block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;
- obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from Jet Airways to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and
- a legitimate interest or the performance of a task in the public interest; or
- direct marketing.
In exceptional circumstances, Jet Airways reserves the right to deny you any of the above rights and may provide an explanation as required by applicable laws. Exceptional circumstances include where:
- acting on your request pursuant to the above rights would result in Jet Airways being in violation of any statutory or regulatory provisions
- an investigating authority or government institution objects to Jet Airways complying with a customer’s request,
- the information may, in our reasonable discretion and/or assessment, affect the life or security of an individual, or
- Personal Information is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
To make any requests as listed above, please contact us at firstname.lastname@example.org.
We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.
Contact Centre and Online Service
Contact centre and social media interactions are one of the many channels that can be used by guests to seek information on the various products and services of Jet Airways. Jet Airways in turn will use the contact centre and social media tools to deliver information relevant to you or respond to your queries.
Following are some examples of information or services Jet Airways provides to its guests via calls and/or emails & SMS : reservation creation and confirmation, fares and flight enquiries, special service requests, ancillary products (related to the particular travel that you have booked with us provided that you have consented to being contacted for the same) and information, important travel and flight related information and updates, customer satisfaction surveys and feedback.
When you send us an email or chat with us online or via social media, we register your communication with us. When you call us, our customer support will register your questions or complaints in our database. We may also record telephone calls for training purposes or to prevent or combat fraud and to respond to any legal requirements. We keep a record of any calls you make to our contact centre for a period of six months.
When you use our mobile application it may access your device information or data from your mobile device. If you would like to restrict such access, please adjust the settings on your mobile device. In particular, if you would like to restrict our access to your location, please turn off location data collection in your device’s settings. If you do decide to turn off location information, please note that services such as airport mapping, city code search and other location-based notifications on your day of travel will not work. Please note that our app will activate the camera on your device, if you choose to use the credit card or passport scanning functions. You can prevent this by not using those features.
When you subscribe to push notifications, you agree to receive Jet Airways promotions as push notifications on your mobile device or browser. You can unsubscribe from push notifications anytime, simply by unsubscribing from push notifications from Jet Airways on your device, browser or app settings as applicable. Jet Airways only stores unique subscription ID generated while subscribing to push notifications of Jet Airways. When unsubscribed on your device, the subscription ID shall not be used to deliver push notifications.
We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to potential risks, including:
- the pseudonymisation and encryption of your personal information where appropriate;
- ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and
- regular testing, assessment and evaluation of the effectiveness of our technical and organisational measures to ensure your personal information is secure.
We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using our website. Please note that email is not encrypted and is not considered to be a secure means of transmitting credit card information. We offer the use of secure communication transmission software (known as "secure sockets layer" or "SSL") that encrypts all information you input to our website before it is sent to us. SSL is an industry standard encryption protocol and this ensures that the information is reasonably protected against unauthorised interception;
Where you disclose information to us using our mobile app, please ensure that your device remains safe. We cannot be held responsible for any data misuse arising from unauthorised access to your device.
This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website. Your continued use of our website constitutes your acceptance of it.
Making a Complaint
We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal information, please contact us at email@example.com.
If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: https://ico.org.uk/concerns/ or telephoning the ICO helpline, which is 0303 123 1113.