This document clarifies what personal data LLC “Pobeda Airlines” (hereinafter referred to as "the Airline") collects about passengers and, in some cases, about other persons (hereinafter referred to as "You", "personal data subjects"), how this data are used and to whom are transferred.
This document is of an informational nature and is not part of the contract of air transportation or any other contract of a consumer nature concluded between You and the Airline. At the same time, the Airline proceeds from the premise that any person who enters into an air transportation contract or another consumer contract with the Airline prior to the conclusion of the contract has carefully read this document and expressed its acceptance about document’s content without any reservations.
The Airline is the operator of personal data in the sense of the norms of international law and applicable norms of Russian legislation. Full name of the Airline: Limited Liability Company "Pobeda" Airline. Address: Kievskoye highway, 22nd km, household 4, bld. 1, village Moscovskiy, Moscow suburb, 108811. The airline was established in accordance with the laws of the Russian Federation, INN 9705001313, OGRN 5147746103380. Phone: +7 (809) 505-4777, e-mail address for applications regarding the processing of personal data: email@example.com.
THE CONCEPT OF PERSONAL DATA
Personal data means any information related to an identified individual or identifying on the basis of this information. Personal data may include (but not limited to) the last name, first name, patronymic, date of birth, sex, citizenship, type and number of the identity document, phone number, e-mail address, other online identifiers (including nicknames in social networks and other web resources), payment information (date and amount of payment, method of payment, name of the holder of the bank card, etc.), information about the contract of carriage (including the booking code, time and flight route, additional services, place on an aircraft ).
SOURCES OF PERSONAL DATA
The airline can receive your personal data:
- via the Airline website and mobile applications of the Airlines for iOS and Android, for example, when you book a flight, arrange additional services or subscribe to the newsletter;
- by personal contact with the Airline (in writing form, by e-mail or through a call center);
- from other sources: for example, if you decide to bind your account in a social network to our website, certain information from your profile in the social network.
In all these cases personal data can be received by the Airline not only from you personally, but also from third parties, in particular from agents authorized by the Airline, as well as from third parties acting on your behalf or in your interests (for example, from travel agents, not being our partners, or from other persons who book a flight for you).
PERSONAL DATA PROCESSING IN CONNECTION WITH THE IMPLEMENTATION OF THE CONTRACT OR THE AVAILABILITY OF THE LEGITIMATE PURPOSE
In case of conclusion and execution of a passenger’s air carriage contract or other contract of a consumer nature, the Airline will process the personal data of the passenger (other consumer), including information on the actual performance of the contract of air carriage or another contract of a consumer nature with respect to the person concerned.
Airline use this information, for example, to identify passengers and baggage, when passengers register for a flight and boarding to an aircraft, when send electronic route receipts and other documents, when inform passengers about possible changes and delays in the flight schedule provided for in the air transport agreement, etc.
In addition, the Airline may store the personal data if there is a legitimate interest in their preservation. In particular, the Airline can keep information about the conclusion and execution of the air transportation contract and after its full execution, since this information is necessary to resolve possible future disputes with the passenger or with the airline's contractors, as well as to control the quality of passenger service. The period of storage of personal data in these cases, as a rule, can not be less than the maximum possible limitation period for the passenger's requirements for the Airline arising from the contract of air transportation.
For the conclusion and execution of the contract of air transportation or other contract of consumer nature, the Airline may transfer personal data to third parties participating in the performance of the contract. In particular, the Airline can transmit information about passengers of future flights to the departure airport operator for the purposes of passenger registration and baggage registration, or information about non-arrival of luggage to the arrival airport operator and to specialized baggage search systems.
PROCESSING SPECIAL CATEGORIES OF PERSONAL DATA
The Airline processes data about the passenger's health condition to the extent necessary to conclude and execute an air transportation contract or other consumer contract, and to consider applications from passengers associated with such contracts, in particular:
- when ordering additional services related to the air transportation of passengers with disabilities or other restrictions that may affect the normal performance of the contract by the Airline;
- for the carriage of certain categories of passengers, when, in accordance with the current regulation, a certificate or other medical document is required to show that there are no contraindications to the flight for health reasons or in connection with pregnancy;
- in cases of injuries and other medical conditions that occurred during air transportation, especially when staying on board an aircraft, including for further payment of insurance compensation;
- when considering applications and claims of passengers, including property, when the passenger justifies his claim by having one or another medical condition;
In these cases, getting and processing of relevant information about your health is necessary to prevent harm to life and health and the proper execution of the contract of air transportation or other contract of a consumer nature. And therefore your refusal to provide this information may be one of the reasons for the subsequent refusal to you provision of an appropriate service due to the inability to provide minimum safety requirements or a comprehensive review.
The Airline can save these data even after completion of air transportation to the extent that it is necessary to resolve possible future disputes.
The Airline does not process data on the health of the passenger, except as noted above.
If the passenger refuses to enter into an air transportation contract or in the case of the cancellation of an air transportation contract due to the presence of an appropriate decision taken by the government of the Russian Federation or another state (in particular, by virtue of clause 4 of Article 786 of the Civil Code of the Russian Federation), the Airline reserves right to keep relevant information.
In any case, the airline does not collect or process information on racial and ethnic origin, political and religious views, membership in professional and other associations, sexual life and sexual orientation, and biometric information.
PERSONAL DATA PROCESSING FOR THE LAW
The personal data of any personal data subject may be stored, processed and transferred if such an obligation is assigned to the Airline by virtue of a law, other regulatory legal act or the requirement of the authority. For example, in order to comply with formalities, the Airline can transmit information about booking a ticket to the passenger's name and about the flight (indicating the name, date of birth, requisites of the identity document and other information) to the competent transport safety authorities and the border control authorities of the Russian Federation, as well as the states of departure, arrival or transit of a passenger.
Personal data can also be disclosed by the request of the court and enforcement authorities of judicial decisions, law enforcement agencies, on advocacy request, during the implementation of control and supervisory measures to monitor the observance of passengers' rights and in other cases provided for by law.
In each such case, the specific personal data that have to be stored, processed or transferred are determined by the applicable law of the Russian Federation as the state in which the activities of the Airline, the states of departure, arrival or transit of the passenger and other states are licensed.
HANDLING OF PERSONAL DATA WITH YOUR AGREEMENT
By concluding an air transportation contract with the Airline, or by using the services management tools of Pobeda Airlines on the website www.pobeda.aero or in the mobile application of Pobeda on iOS and Android platforms (for example, by entering the appropriate entries in the registration forms, but not limited to this), in accordance with Article 9 of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," it is assumed that you provided the Limited Liability Company "Pobeda" Airline (OGRN 5147746103380, the license of the Federal Air Transport Agency No. PP 0377 dated 01.10.2015) and its authorized representatives expressly acceptance to the processing of personal data, as well as any other data relating to the client's identity, to any action (operation) or set of actions (transactions) performed with personal data, including (without limitation): collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), cross-border transfer (USA, UK, as well as the states of the passenger), depersonalization, blocking, removal, destruction, as well as any other actions stipulated by the current legislation of the Russian Federation, using automation tools, including information and telecommunications networks, or without use of those, as well as the acceptance to send e-mails and information messages to the customer's e-mail address and / or mobile phone number, including adding information on current Pobeda Airlines and its partners, promotions and other informational messages, as well as the use of said passenger e-mail to display targeted advertising and information messages.
The Airline may use your personal data for the purpose of providing or promoting the products and services of the Airline. For this purpose, the Airline may transfer part of the information containing your personal data to its strategic partners. This allows you to keep up to date with news about sales, to report on the opening of new flight directions and upcoming events.
For example, when you subscribe to Airline newsletters, this assumes that you have authorized the Airline to provide you with information about the services of the Airline. This information can be combined with other information in order to provide and improve our services and for advertising purposes, including targeted advertising. If you want to refuse newsletters, you can do this at any time by changing the corresponding settings in the "Personal Account" by clicking on the "Unsubscribe" link in the email or by sending us a notification to firstname.lastname@example.org. Acceptance or refusal of newsletters does not affect the sending of service messages carried out in connection with the conclusion and execution of the contract of air carriage (for example, messages with route receipts or information on the status of the voyage).
Also the Airline can use your personal data to conduct marketing, sociological and other similar studies, in particular when conducting surveys of the Airline's customers and when studying the structure of consumer demand.
Use of personal data in all the purposes indicated in this section is allowed if you did not specify the reverse when providing personal data and did not disclose your disagreement with the use of your personal data for the specified purposes afterwards.
CONSIDERATION OF APPEALS
You can apply to the Airline to:
- to receive information about your personal data stored in the Airline, for example, to obtain information about which personal data is stored in the Airline, or to obtain a copy of personal data;
- make corrections to your personal data in case they are not true. However, the correction of personal data does not entail an automatic change in the terms of the current air transport contract;
- withdraw your consent to the storage and / or processing of your personal data in cases where such consent was given, and the storage and / or processing of personal data are subject to the availability of such consent.
The Airline draws attention to the fact that the removal of your personal data is impossible if their availability is necessary for the performance of the contract of air transportation or other contract of a consumer nature, if the Airline has a legitimate objective in preserving personal data, and if the Airline keeps personal data by law.
Appeal, as a rule, should be sent by letter in hard copy to the postal address of the Airline (in some cases, in particular for the refusal of newsletters, other methods that are specifically mentioned in this document may be used). The Airline reviews applications if the form of the appeal and the information contained in it allow you to uniquely identify you and exclude "identity theft". The period for consideration of the appeal is one month from the date of receipt of the application to the Airline. The appeal must be signed either by the person whose personal data this refers to, or by his legal representative (parent, guardian - in case of a minor or incapacitated), or by a person acting on behalf of the said persons. In the last two cases, it is mandatory to attach to the application a document confirming the authority of the person sending the appeal (for example, birth certificates or notarized attorneys, or their copies certified by a notary). The Airline pays attention to the fact that the originals of the application and any documents received with the application are not returned.
As a general rule, appeals are considered free of charge. At the same time, in the case of manifestly unreasonable appeals, as well as requests for which the answer was previously given, the Airline has the right to charge a fee for processing such an application or refuse to consider such an appeal, in essence.
In certain cases, specifically provided for by legal acts of the Russian Federation or foreign countries, fees for making changes to personal data may be charged directly by virtue of these norms.
COLLECTION OF INFORMATION ON INFORMATION RESOURCES OF AIRLINE
When you visit the Airline's website or use a mobile application, the Airline can collect information about how you use the said information resources, using cookies and server logs. The collection of this information is due to the technological peculiarities of the work of these information resources, is transitory (temporary) and is not aimed at collecting personal information exclusively about you.
PROTECTION OF PERSONAL INFORMATION
As part of the protection of personal data, the Airline takes measures to prevent their accidental or unauthorized destruction or accidental loss, as well as to prevent unauthorized access, alteration or dissemination of personal data.
By accessing the Airline's website, HTTPS is used by default to protect data. We do not recommend the use of the HTTP protocol when using the Airline website. The airline is liable only for the operation of the website www.pobeda.aero and is not responsible for the processing of personal data by the owners of third-party websites, even if such website is linked from the Airline's website.
In order to protect unauthorized access to your personal data, it is strictly not recommended to inform unauthorized persons with accounting information for accessing the information resources of the Airline (for example, login and password from the account on the website), as well as the identifiers of a particular trip, including the booking code (combination of six Latin letters and numbers), air ticket number, etc. This information should be provided only when interacting with the Airline.
DATA PROTECTION DEPARTMENT
If you have any questions regarding the processing of your personal data, you can contact our data protection officer who will be available if you request information, suggestions, questions or complaints: email@example.com.
PROVISION OF PERSONAL DATA BY THIRD PARTIES
In all cases of obtaining personal data, the Airline assumes that this data is entered either by the person himself or by his legal representative (parent, guardian) or by a third person on behalf of and with the consent of the said persons. For example, when booking a person's ticket on the Airline's website or through a mobile application, it is assumed that the person making this booking and correspondingly entering the passenger's personal data on the ticket is:
- the passenger himself, who is of legal age and capable; or
- legal representative (parent, guardian) of a minor or incompetent passenger; or
- a person who has legally obtained the explicit consent of such persons to transfer their personal data to the Airline during the booking process.
If you find that your personal data has been transferred to the Airline without your consent or against your will, you should immediately contact the Airline in the ways described in the "Consideration of appeals" section to prevent unauthorized use of your data.