Privacy Policy

Controller: [Company Name] Ltd, a company registered in England and Wales with company number [Number] whose registered office is at [Registered Address] (“we“, “us“, “our“).

1. Introduction and Controller Responsibility

We are committed to protecting and respecting your privacy. This policy (together with our Terms & Conditions and Cookie Policy) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

For the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018), we are the ‘data controller’ of your personal data.

2. The Data We Collect About You

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

Identity Data: Includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender, passport number, visa information, and photograph.
Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
Financial Data: Includes payment card details (which are processed directly by our PCI-DSS compliant payment processors), bank account details, and history of transactions.
Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us, including full itinerary, baggage details, and seat selection.
Technical Data: Includes internet protocol (IP) address, your login data, 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 our website.
Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data: Includes information about how you use our website, products, and services.
Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Category Data: In limited circumstances, we may collect data concerning health (e.g., to provide wheelchair assistance or accommodate specific medical needs) or religious beliefs (e.g., to provide specific dietary requirements like halal or kosher meals). This data is only processed with your explicit consent.

3. How We Collect Your Data

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

Direct interactions: You may give us your Identity, Contact, Financial, and Special Category Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- make a booking or enquiry;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion, or survey; or
- give us feedback or contact us.
Automated technologies or interactions: As you interact with our website, we will 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. Please see our Cookie Policy for further details.
Third parties or publicly available sources: We may receive personal data about you from various third parties, including:
- Analytics providers (such as Google based outside the UK);
- Travel agents and other booking platforms;
- Airline partners and interline carriers; and
- Fraud prevention agencies.

4. How We Use Your Data (Lawful Bases)

We will only use your personal data when the law allows us to. Our primary lawful bases for processing are:

Performance of a Contract: Processing necessary to fulfil a booking or other contract with you.
Legitimate Interests: Processing necessary for our legitimate interests (or those of a third party), where your interests and fundamental rights do not override those interests. This includes fraud prevention, network security, marketing, and business administration.
Legal Obligation: Processing necessary to comply with a legal or regulatory obligation (e.g., providing passenger data to UK Border Force).
Consent: Where we have obtained your clear, specific, and informed consent for a particular purpose (e.g., for marketing communications or processing Special Category Data). You can withdraw consent at any time.

The table below describes our processing purposes and the lawful basis we rely on.

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a new customer	Identity, Contact	Performance of a contract
To process and deliver your booking	Identity, Contact, Financial, Transaction, Special Category	Performance of a contract, Consent (for special categories)
To manage our relationship with you	Identity, Contact, Profile, Marketing	Performance of a contract, Necessary for legal compliance
To administer and protect our business and website	Identity, Contact, Technical	Necessary for our legitimate interests (IT security, admin), Necessary to comply with a legal obligation
To deliver relevant website content and advertisements	Identity, Contact, Profile, Usage, Marketing, Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical, Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity, Contact, Technical, Usage, Profile	Necessary for our legitimate interests (to develop our products/services and grow our business) or Consent

5. Data Sharing and International Transfers

We may share your personal data with the following parties for the purposes set out in the table above:

Service Providers: Who provide IT, system administration, payment processing, booking engines, baggage handling, and customer communication services.
Travel Partners: Including airlines, hotels, car rental agencies, and airport authorities to fulfil your travel arrangements.
Professional Advisers: Including lawyers, bankers, auditors, and insurers.
HM Revenue & Customs, regulators, and other authorities: Who require reporting of processing activities in certain circumstances.
Third parties: In the context of a merger, acquisition, or sale of our business assets.

Many of our external third parties are based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by using specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

6. Data Security

We have implemented robust technical and organisational security measures designed to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Access to your personal data is limited to employees, agents, contractors, and other third parties on a strict need-to-know basis. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have procedures in place 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.

7. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations.

8. Your Legal Rights

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Withdraw consent where we are relying on consent to process your personal data.

If you wish to exercise any of these rights, please contact our Data Protection Officer at the details below.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

9. Contact Details

Our full details are:
Full name of legal entity: [Company Name] Ltd
Email address: [data.protection@flysaudi.co.uk]
Postal address: [Registered Address], marked for the attention of the Data Protection Officer.

10. Changes to This Policy

We may update this policy from time to time. The historic version can be obtained by contacting us. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.