CONTENTS
3. IMPORTANT INFORMATION AND WHO WE ARE.
4. THE DATA WE COLLECT ABOUT YOU.
5. HOW IS YOUR PERSONAL DATA COLLECTED?
6. HOW WE USE YOUR PERSONAL DATA.
8. DISCLOSURES OF YOUR PERSONAL DATA.
13. CHANGES TO THIS PRIVACY POLICY.
Welcome to the Privacy Policy of Alia – The Royal Jordanian Airlines Plc (Royal Jordanian) (Royal Jordanian) and its subsidiaries; Royal Wing Co., Ltd., Royal Tours and Tikram For Airport Services psc which, together with Royal Jordanian itself, are collectively referred to as the Group.
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.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.
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. Royal Jordanian has chosen the UK Information Commissioner’s Office (ICO) as its Supervisory Authority.
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 Royal Jordanian mobile application, including any data you may provide through this website when you make or amend a flight booking, join our Royal Plus 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
Royal Jordanian 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.
Royal Jordanian has two subsidiaries, Royal Wings Company and Royal Tours for Travel and Tourism Company which, together with Royal Jordanian itself, are collectively referred to as the Group
This Privacy Policy is issued on behalf of the Group so when we mention “Royal Jordanian”, "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Group responsible for processing your data. We will let you know which entity will be the Data Controller for your data when you purchase a service with us. Royal Jordanian is the Data Controller and responsible for this website.
Data Protection Officer
Royal Jordanian has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. 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
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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by Royal Jordanian. 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
Aggregated Data
When you visit this website or use any Royal Jordanian 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 Halal 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 section 6 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 section 12.
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. Royal Jordanian 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:
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:
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.
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.
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 account holder or Royal Plus member |
(a) Identity (b) Contact |
Necessary for our legitimate interests (for running our business)
|
|
To process your flight booking including: (a) Manage payments, fees and charges (b) 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 legitimatine terests (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 (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) |
This website makes use of cookies to measure site activity and to customize 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 Read More..
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.
We strive 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.
We may have to share your Personal Data for the purposes set out in the table in section 6 with the following parties:
Disclosure of your Personal Data within the Group
Companies in the Group, outstations, branches and offices acting as joint controllers or processors of your Personal Data.
Disclosure of your Personal Data to External Third Parties
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.
Internal Transfers
We will share your Personal Data within the Group. As Royal Jordanian’s head office is based in Amman, Jordan, it will be necessary to transfer Personal Data which was collected in the European Economic Area (EEA) outside of the EEA.
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". A copy of Royal Jordanian’s Binding Corporate Rules can be found here. Learn More
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:
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
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.
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. In order to comply with the laws of The Hashemite Kingdom of Jordan, we retain all documents and data for up to 15 years.
In some circumstances you can ask us to delete your data: see Request erasure in section 12 below 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.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
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 longer up to three calendar months to respond, but we will notify you of this and keep you updated.
13-CHANGES TO THIS PRIVACY POLICY
Aggregated Data
When you visit this website or use any Royal Jordanian 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 Halal 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 section 6 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 section 12.
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. Royal Jordanian 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.