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Gold Medal Travel Group Plc (trading as Netflights.com) takes your privacy seriously and we are committed to protecting your personal information. Our Privacy Notice explains how we collect, use and share personal information in the course of our business activities. In order to help you find what you are looking for, we have divided the information into the following sections.
The personal information we collect and when and why we use it Legal basis for using your personal information Sharing your personal information with others How we use your personal information for marketing purposes, profiling and analytics Transferring personal information globally How we protect and store your personal information Cookies Legal rights available to help manage your privacy California Shine the Light Disclosure How you can contact us
Gold Medal Travel Group Plc (trading as Netflights.com) is a member of the Emirates Group. The Emirates Group includes a number of related businesses, including:
You can find out more about the Emirates Group here. This Privacy Notice covers the Emirates Group, its websites, mobile applications and mobile websites (collectively referred to as the “Platforms”) except where you are notified of another privacy notice or policy by the specific Emirates Group entity who collects your personal information.
The Emirates Group entity responsible for your personal information will be the member of Emirates Group that originally collects information from or about you. There may be separate or additional applicable privacy notices made available when your personal information is first collected by that Emirates Group entity, for example, where you purchase an Emirates product or service from us.
You do not have to provide your personal information to us, but if you do not provide certain information we will only be able to provide limited products and services to you. For example, where you refuse to provide mandatory travel information, we will not be able to transport you.
This Privacy Notice applies even if you have purchased your travel or other products or services via a third party (such as a travel agent or holiday company). These third parties may also have their own privacy policies that apply when they collect information from or about you.
We may amend this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. If we decide to change our Privacy Notice we will place any updates on this webpage and the privacy sections of any relevant Platforms. Please regularly check this webpage and the privacy sections of any relevant Platforms for the latest version of our Privacy Notice. If at any point we decide to make fundamental changes to our Privacy Notice, we will seek to inform you by notice on our website or on the relevant section of any other Platform or email.
You might find external links to third party websites on our Platforms. Our Privacy Notice does not apply to your use of a third party site. We are not responsible for the privacy practices of websites that are not operated by an entity in the Emirates Group and encourage you to read the privacy statements of any such third party site.
When you book a flight, holiday, cruise or make other travel related bookings with us, we will collect, process and use personal information so that we can deal with all aspects of your booking. Types of personal information we collect The types of personal information we collect when you make a booking with us includes your:
How we use this personal information
We use your personal information to:
Special categories of personal information we collect and use We also collect special categories of personal information. The types of special categories of personal information we collect when you make a booking or fly with us include:
We use special categories of personal information to:
Where your religion or health status could be inferred from meal preferences, we will not link this information or use it in any other way other than to fulfil your meal request. We do not generally collect special categories of personal information from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it and handle it with extra care. We also share this information with third parties (who help manage our business and deliver services such as those parties who provide wheelchairs at airports) and other companies within the Emirates Group (who help manage your booking or journey), and we transfer it globally. Click on the following relevant sections for further details about Sharing your personal information with others and Transferring personal information globally. Where you (or any passenger travelling) provides us with special categories of personal information you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which it was collected.
Advanced Passenger Information (API)
For passengers landing in certain countries, we are required to provide details of the itinerary and booking details in our Passenger Name Record (PNR) system to border control, customs and law enforcement officers at ports of entry and exit on your itinerary. This information is referred to as Advanced Passenger Information (API). We will share API with relevant authorities as required and permitted by local and applicable laws. If you do not provide this information we may not be able to provide travel and may not be able to provide a refund or re-booking. Making a booking on behalf of another person If you are making a booking on behalf of another person(s), it is your responsibility to obtain their consent to make the booking and share their details with us (as anticipated by this Privacy Notice), which we will assume that you have done prior to making the booking. It is also your responsibility to represent that person during the booking process, which means that you will need to provide us with the information required to make a booking, such as the full name and passport details of the person concerned, and explain to that person how we will use their personal information as set out in this Privacy Notice. Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Notice. Each person in a booking will be able to view the phone number and/or email of the other person(s) in a booking and update such information. Any operational messages sent to one member of a booking will also be sent to the person who made the booking.
When you register to use one of our Platforms, we collect, process and use personal information to manage your registration. Once you register, this will enable you to manage your account and preferences. Types of personal information we collect The types of personal information we collect from you when you register for an online account includes your:
Once you register an online account member the types of personal information we collect from you includes:
We use the personal information we collect if you register an online account, together with the Personal information we collect and use if you make a booking with us, to:
Any information we collect will also be used in accordance with the terms and conditions of the online account.
If you have any queries about any of our products or services, compliments or complaints, or requests such as flight certificates, we will need to collect information from you, including your contact details, in order for us to respond to your query or provide you with assistance. We will collect this information when you submit a form on our Platforms, send us an email, call our customer service centre, visit a local office or retail centre, or contact us via another form of communication such as through social media or an online chat tool. Types of personal information we collect The types of personal information we collect includes your:
Depending on the nature of your query, we may need to collect special categories of personal information from you so that we can properly understand the nature of your query or request. More details on Special categories of personal information we collect and use are above. We also keep a record of the communications we have with you including call recordings so that we can monitor and improve the quality of our customer support services, comply with relevant legal obligations and to make and defend claims. If you visit one of our local offices or retail centres you will be monitored by closed circuit television for security purposes. In each case, we do so in compliance with applicable laws.
How we use this personal information We use your personal information to:
We may from time to time hold contests, competitions or prize draws or make available promotional offers. If you want to take place in any of these, we ask you to provide us with certain personal information and we also use this information to keep in touch with you about our products, services and any special offers which we think may be of interest. Types of personal information we collect The types of personal information we collect includes your:
Any information we collect will also be used in accordance with the terms and conditions of the contest, competition, prize draw or promotional offer.
Types of personal information we collect The types of personal information we collect include your:
In the event of an emergency affecting your medical condition during your flight or travel journey, we will need to collect special categories of personal information. More details on Special categories of personal information we collect and use are above. How we use this personal information We use your personal information to:
Our Platforms use cookies. A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet, and helps us provide better Platform services to you and tailor certain content. Cookies may collect personal information about you. For more information on how we use personal information when you use our Platforms and how to manage cookie settings see When and how we undertake analytics and profiling and Cookies below.
We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order, and to protect our property, rights and interests as well as the property, rights and interest of other persons. We also process your personal information for crime prevention and detection purposes, including the prevention of fraud for online payments, for identity verification, for credit checking and credit scoring purposes and accounting or audit purposes. If you visit one of our local offices, retail centres or other properties, you may be monitored by closed circuit television for security purposes. In each case, we do so in compliance with applicable laws.
We collect personal information from third parties who you have authorised to provide your personal information to us (for example, this may be your travel agent or another person making a booking on your behalf, your travel companion, your travel coordinator, our promotion partners, social media and other digital platforms). We combine this information with the information we collect directly from you or about you for the purposes set forth in this Privacy Notice. More details on Sharing your personal information with others is below. We also collect personal information from individuals who may refer you as a friend to our products or services. We ask these individuals to confirm that you are happy to hear from us.
We collect different personal information depending on your payment method (such as credit card, bank transfer, cash). For example, for credit card payments we may collect the credit card holder name, address, card number, expiry date and CVC code. You may also choose to store your credit card details with us for future use. We do not store your CVC/CVV code (which is the security code on the back of a credit card).
We will only collect, process use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
We set out more information about the legal bases for which we process personal information in the table which you can access here. There may be one or more legal bases relevant to an activity listed in this table. The table may be amended and updated from time to time.
We share your personal information in the manner and for the purposes described below:
We use personal information to let you know about Emirates Group products and services that we think may be of interest to you. This may be based on your preferences, derived from Cookies, inferred from your interactions with us including on our social media accounts or market research. We may also let you know about our corporate services which we believe may be relevant to you in a professional capacity. We also work with social media and other digital platforms to provide you with advertisements within those platforms. We provide them with your name and contact details (such as your email address or phone numbers). If these social media and digital platforms match profile information provided by us with your profile information held by them then they will serve you our advertisements. The social media platforms will not identify you or share other personal information in your social media account to us. We will only send you direct marketing, whether about us, carefully selected third parties or partners, products or services, in accordance with your marketing preferences. We may contact you by email, SMS/text, social media, or through other communication channels that we think you may find helpful. If at any time you would like us to stop sending you marketing material, contact us or choose the relevant "unsubscribe" option set out below.
To protect your privacy and to ensure you have control over how we manage marketing with you (and provided that you have indicated that you would like to receive it):
Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs. If you do unsubscribe from marketing communications you will still receive operational and service messages from us regarding your booking including where you may not have completed a booking (such as abandoned cart emails or pop-up notices), and responses to your enquiries made to us.
Analytics We aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and products and services, to customize our Platforms’ content, layout, products and services, and to support our business operations and we may appoint third parties to do this on our behalf, as set out above in Sharing your personal information with others . We gather certain usage information like the number and frequency of visitors to our Platforms. This information includes which webpage you just came from, which webpage you next go to, what browser you are using, your device ID and your IP address. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you. One of the ways we do this is by installing and using Cookies on your browser or device. You can find out more about cookies and our Cookie Policy in the section entitled Cookies below. If you use buttons on our Platforms linked to social media or similar sites (for example, "Like" and/or "Share" buttons), content from our Platforms may be sent back to those sites and, depending on your privacy settings, may be privately or publicly visible (for example, to friends, followers or generally to anyone who has access to your profile page). Profiling We use personal information such as your date of birth, gender, country of residence, transactions (for example, payments made with us and flights taken), information derived from Cookies and your preferences and behaviours for profiling. Some of the legitimate purposes we profile personal information include:
Where required under applicable privacy laws:
The Emirates Group is a global business, which means your personal information may be transferred and stored in the United Arab Emirates and other countries which may be outside your country of residence. Some of these countries are subject to different standards of data protection than your country of residence. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, and we only transfer personal information to another country where:
To this end:
You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above. For residents of Australia, your personal information may be transferred to the United Arab Emirates, the United Kingdom and where our servers are located from time to time, along with where you are travelling to or from or as required by law.
Protection of your personal information
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and safeguard the privacy of such information. For example, the measures we take include:
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
Here are some simple steps you can take to ensure your personal information is kept securely:
Storage of your personal information
We keep your personal information for as long as is reasonably necessary for the purposes for which it was collected. For example, to manage bookings and provide you with any relevant Emirates products or services, as explained in this Privacy Notice. We will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings. If you require further information about how we retain particular information please contact us.
A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet, and helps us provide better Platform services to you and tailor certain content. Cookies may collect personal information about you. Cookies help us remember information about your visit to our Platforms, like your country, language and other settings and searches. Cookies enable us to understand who has seen which webpages and how frequently, and to determine which are the most popular areas of our Platforms. They can also help us to operate our website more efficiently, and make your next visit easier and customise your view of the Platforms to reflect your preferences and activities. They also help us tailor our marketing and advertisements to you on our Platforms, other websites you visit, social media platforms and your other devices. For more information on how we use cookies please read our Cookie Policy, where you can also find information so you can delete cookies or block certain types of cookie. You should note that this may have an impact on our ability to provide the Platform services to you. See also our section on When and how we undertake profiling and analytics.
If you are subject to laws that provide you with such rights, depending on certain exceptions, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information:
If you wish to access any of the rights set out above, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive. You can exercise your rights by emailing us at [email protected] or by sending us a communication at Legal Department, dnata Travel UK, Glendale House, Glendale Avenue, Sandycroft, Deeside, CH5 2DL, United Kingdom. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: the source of your personal information; the purposes, legal basis and methods of processing; the data controller’s identity; and the entities or categories of entities to whom your personal information may be transferred.
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. You can request that we stop contacting you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes. If you have joined our mailing list, you can manage your marketing preferences automatically by clicking the "unsubscribe" link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us or changing your account settings which will remove you from the relevant marketing list.
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.
You can ask us to restrict your personal information, but only where:
We can continue to use your personal information following a request for restriction, where:
You have a right to lodge a complaint with your local supervisory authority (i.e. your place of habitual residence, place of work or place of alleged infringement) if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If we share your personal information with carefully selected third parties for the third party’s own marketing purposes and you are a California resident, you may contact us once per year to request the name of that third party(ies) and the categories of information shared about you. To do so, please send a request to us as set out below with valid proof of California residency. Please note that it may take up to 30 days to process your request.
The primary point of contact for all issues arising from this Privacy Notice is our Data Privacy Officer, who can be contacted here or by sending us a communication to Legal Department, dnata Travel UK, Glendale House, Glendale Avenue, Sandycroft, Deeside, CH5 2DL, United Kingdom. If you have any questions, concerns or complaints regarding our compliance with this Privacy Notice, we encourage you to first contact our Data Privacy Officer. We will investigate and attempt to resolve complaints and disputes as quickly as possible and in any event, within the timescales provided by applicable data protection laws. Issue date of Privacy Notice: May 2018