Privacy Policy

AIR INDIA PRIVACY POLICY

Air India values your privacy. Our privacy policy (“Privacy Policy") applies to all the Personal Data we gather, and you share with us when you visit our websites, use our apps, and utilize any services provided by Air India including our loyalty program and live chat options. Once you choose to provide us with Personal Data, Air India will only use your information in accordance with this Privacy Policy.

This Privacy Policy is issued on behalf of the Air India Limited and is hereinafter referred to as “Air India”, “we”, “us”, or “our” in this Privacy Policy. Air India Limited is the controller or data fiduciary and responsible for this website.

To provide you with our services and the services available through our website and application, Air India, as controller (or data fiduciary) may process (including collect, store, and transfer) your Personal Data. Please note that other airlines have their own privacy policies. Air India recommends you read those other policies if your travel plans include travel on other airlines, as those policies may differ from Air India.

If you have any questions or comments, please contact our Data Protection Team / Data Protection Officer as per the details available in Section XIV of this Privacy Policy.

I. The Types of Personal Data We Collect

As per Air India’s business practices, we may collect Personal Data from you. “Personal Information” or “Personal Data” means any information about an individual from which that person can be identified.

We currently collect and process Personal Data, which include:

  • Contact Information: We collect your personal data during the course of account creation on our website/application as well as while booking our services. This information includes your name, phone number, gender, email Id, frequent flyer details, Address, and Nationality.
  • Security Information: Information related to website password, application passwords etc.
  • Financial Information: This information includes payment data, transactional data, credit/debit card information, bank account number etc.
  • Identification document/ information: We may collect advance passenger information like your visa details, passport, or identity card details, including your passport number, the country in which your passport was issued and the expiry date.
  • Health Information: In order to offer better services to you, we may collect certain health information of yours such as allergies, medical information, disabilities etc.
  • Information related to children: We only process the personal data of Minors with the prior consent of their parents or their legal guardians.  (Please refer to Section III for more details.)
  • Location and device information: Your device location (where you have permitted access to location), operating system, IP address, browser information etc.
  • Loyalty Account: This data includes points and miles data, your preferences and hobbies, language preferences etc.
  • Details pertaining to the services booked with us: During our course of interaction and for facilitating the services you have booked with us we may gain insight into some personal data, such as onward travel details, meal preference, travel preferences check in date and time, seat upgrades, Wi-Fi usage etc.
  • Other Information: This includes the data you choose to share with us by means of interacting with our social media pages or completing a flight satisfaction survey.
  • Recruitment Data: In case you apply to any of our openings we shall process your data for assessing if you are suitable for the position. In such scenarios we shall collect your educational qualifications, professional history, contact details etc.
  • In case, you share personal data with us which relates to another person to provision a service from us, you are responsible for ensuring the person knows and has consented to us collecting and processing their personal information in accordance with the provision of this privacy policy.

Subject to applicable laws, we may monitor or record your phone conversations for training and customer service purposes, to comply with relevant legal obligations and to make and defend claims. If you visit one of our Reservations and Ticketing Offices or an Air India Lounge, you may be monitored by closed circuit television for security purposes.

We also collect, use, and share aggregated data such as statistical or demographic data for different purposes. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website, mobile application, or service 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.

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, where permitted by applicable law, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access or use to our website, mobile application, and other services).

II. How we Collect / Receive the Personal Data and the Use of such Personal Data

We use different methods to collect Personal Data about you, including through:

Direct Interactions: You may give us your Personal Data by filling in forms or by corresponding with us by phone, email, on our website, through live chat, or otherwise. This includes Personal Data you provide when you:

  • apply or avail our products or services;
  • apply for job openings available at Air India;
  • create an account on our website or app;
  • use our live chat option “Ask AI.g”;
  • subscribe to our service or publications;
  • request marketing communications to be sent to you;
  • enter a competition, promotion, or survey; or
  • give us feedback or contact us.

Indirect Interactions: We may receive your personal data from third parties such as:

  • When you book our services using travel agents or third-party websites
  • Airport Kiosks
  • Payment service providers
  • Partner Airlines and cooperation partners (such as star alliance network)
  • Our affiliates to provide you with services in case of our merger or amalgamation.
  • Referees and recruitment agencies in case you have applied with us for any job openings.

Automated technologies or interactions: As you interact with our website or our services, 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. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

III. Purpose of Processing and Lawful Basis:

Your personal data can only be processed in accordance with one of the lawful bases provided under applicable data privacy laws. We may rely on different legal basis to comply with the regulatory requirements.

Fulfillment of our services:

We may process your personal data in order to fulfill the services you have booked with us. A contract exists between you and Air India when you utilize our services by booking a flight or cargo on our website, application or through any third party. In order to fulfill our services, we shall process your personal data for the purposes of identity verification, reservations, check-in, and cargo management.

In this respect, information may also be processed for providing ancillary services including but not limited to additional baggage reservation, seat preference, meal preference, cargo management, provision of wheelchair assistance and facilitate duty free purchases.

Additionally, personal data may also be processed for the purpose of preventing fraudulent transactions while receiving payments from foreign nationals.

Legal Basis of processing for EEA (European Economic Area)/UK: We process your personal data for the fulfillment of contractual obligations, for the above listed purposes.

To send communications related to the services availed with us:

We may also process your personal data for sending communications to you relevant to the services opted through us such as flight tickets, gate change communication, changes to the flight plan etc. Please note that the communications transmitted for these purposes do not require your explicit consent to be obtained by us.        

Legal Basis of processing for EEA/UK: We process your personal data for the fulfillment of contractual obligations, for the above purpose.

To carry out marketing activities:

We may process your personal data to carry out our marketing campaigns by sending you personalized offers, and newsletters through various channels such as email/WhatsApp/SMS/RCS/push notification or any other channel. We shall send such marketing communication only when you have opted-in or subscribed to receive the same.  If you have a Maharaja Club Account, you may update your marketing preference at Preference Centre in your account area at any time. Additionally, you (including guest users) may opt out or unsubscribe through the option available in such marketing communication.

We may also process your personal data to carry out targeted or personalized advertisement on our websites, third party websites, social media platforms or any other digital marketing channels to show personalized offers and products to you. To opt out from such processing refer to our Cookies Policy.

Please note: Opting out of receiving the marketing emails shall not stop our communications sent for services availed with us.

 Legal Basis of processing for EEA/UK: We process your personal data on the basis of consent received, for the above purpose.

To improve our products and service:

We may analyze your personal data in order to understand you better, develop and improve our products and services. We may also send survey links, make calls, invites for usability testing and interviews to receive feedbacks from you on the services availed from us. If you are a data subject from the EU/UK region and does not wish to receive the survey links from our side, you can raise a data subject request for right to object.

Legal Basis of processing for EEA/UK: We process your personal data on the basis of legitimate interest, for the above purpose.

To manage our loyalty programme:

We process your personal data to manage your Loyalty account with us. The processing shall be in accordance with the Loyalty terms and conditions which can be accessed “https://www.airindia.com/in/en/maharaja-club/about/terms-conditions.html”. We shall also process your data to determine offers and provide personalised services based on your tier. Your accounts may also be profiled and automated decisions maybe made from such profiling activities.

At times, the personal data may be processed to manage your Maharaja Points upon conducting transactions with our loyalty partners and affiliate members.

Legal Basis of processing for EEA/UK: We process your personal data on the basis of legitimate interest and consent provided, for the above purpose.

To manage your requests and complaints:

We may process your personal data under circumstances where you have initiated contact with us for queries, requests, or to address any grievances or feedback you may have pertaining to the services you have availed from us.

Legal Basis of processing for EEA/UK: We process your personal data on the basis of consent received, for the above purpose.

Health Data:

We may process your health data only in scenarios where in you have explicitly consented for receiving special assistance before, during or after the flight. We may share this information with our employees or third parties who shall be involved in providing the assistance requested.

In case of an emergency scenario wherein medical assistance is required, we shall process your data on the basis of vital interest.

To manage any dispute, defend our legal claims and prevent fraud:

We may process your personal data in order to defend our claims in the court and fighting fraud. Additionally, we shall process your personal data in accordance with any tax obligation and legal obligations.

We may be required to disclose your personal data in case of legal disputes or if queries are raised by authorities in order to prevent, investigate or prosecute crimes including identity fraud, terrorism etc.

Legal Basis of processing for EEA/UK: We process your personal data on the basis of Legitimate Interest, for the above purpose.

Flight Planning and management:

We may process your personal data in order to plan and manage our fleet efficiently, which includes scheduling, route optimization and crew allocation. This helps us to ensure better operations along with minimal disruption to passengers while consuming our services.

We may as well process personal data to audit, monitor and improve our internal processes for smooth functioning of our website, application, and internal procedure.

Legal Basis of processing for EEA/UK: We process your personal data on the basis of Legitimate Interest, for the above purpose.

Processing job application:

We shall process your personal data in order to process the job applications submitted by you either through our website or through third party agents or recruitment agencies.

Legal Basis of processing for EEA/UK: We process your personal data on the basis of Legitimate Interest, for the above purpose.

IV. Personal Information of Children

  Due to the nature of our services as an airline, we may collect travel information, which may include Personal Data of persons below the age of majority (“children”) when it is required to comply with the law, or as otherwise required to provide transportation needs and services (e.g. Air India may offer special discounts to children and needs to assess fare eligibility, verification at check in, and sharing of data to another airline if a transfer is involved or for transport of unaccompanied children).

If you are a minor, you may use our services only with the involvement of a parent or guardian. If personal data related to minors has been collected without consent of their parents or their legal guardians, they have the right to object to processing and/or request deletion of such personal data (Please refer to Section VII for more details on how to exercise these rights).

V. Who We Share your Personal Data With

We may share this information with:

  • to other companies in the Air India Group; to customs, border control, security, anti-terrorism and immigration authorities, which require by law access to booking and travel itinerary information including Passenger Name Records for all passengers;
  • to our marketing or advertisement partners for sending marketing emails;
  • to third parties including but not limited to other airline partners, GDS partners, partners connected with our Loyalty Programme, other service providers including those who are acting as our agent or sub-contractor, including, hoteliers, insurance companies, ground handling service providers, medical assistance providers, caterers, credit card and credit reference agencies, IT and system administration services providers, data analytics & data processing service providers, vendors, and our legal and other professional advisors, including lawyers, bankers, auditors, and insurers;
  • to third parties in connection with financing, securitization, insuring, restructuring, assignment or other disposal of all or part of our business or assets or in relation to defence of claims;
  • to official authorities, including law enforcement, governmental and regulatory authorities, including health authorities: (a) if we believe disclosure is required by any applicable law or regulation; (b) to protect and defend our rights, or the rights or safety of third parties; or (c) where it is in our legitimate interest to co-operate and share information with such authorities;
  • where you have made a travel booking, to passengers travelling under the same booking as you; or
  • to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
  • For recruitment purposes, we may also transfer your personal data to third party service providers such as recruitment agencies, background verification agencies, IT system providers etc.

VI. How we Store, Retain, and Erase your Personal Data

We will use technical and organizational measures to safeguard your Personal Data in accordance with applicable laws.

We will retain Personal Data for as long as it is necessary to fulfil the specified purpose for which it was collected, the legal or business purposes of Air India, as described in this Privacy Policy and in line with our data retention policies, or as required by relevant laws. When erasing Personal Data, we will take commercially reasonable and technically possible measures as prescribed under applicable laws to make the Personal Data irrecoverable or irreproducible in accordance with the applicable laws.

VII. Your Data Protection Rights

You have certain rights in relation to your personal data and how we process it, depending upon the jurisdiction you are in.

You have the following rights irrespective of the jurisdiction you belong form:

  • Right to access: the right to request copies of the Personal Data we hold about you at any time, or that we modify, update or delete such data. This access includes access to information about the processing, such as purpose, categories of data and recipients, duration of the processing, data subjects’ rights and appropriate safeguards in case of third country transfers.
  • Right to rectification: the right to have your Personal Data rectified if it is inaccurate or incomplete. Depending upon the nature of the request, you may be able to update certain sets of personal data on your own.
  • Right to erase: the right to request that we delete or remove your Personal Data from our systems.
  • Right to withdraw consent: the right to withdraw previously given consent to process your Personal Data
  • Right to complain to supervisory authorities: If you wish to make a complaint or are unhappy with the way we process your personal data, you have the right to complain to the appropriate supervisory authority of your jurisdiction. However, we would suggest to first utilize our grievance redressal mechanism or write to the Data Protection Officer before reaching out to the supervisory authorities.

If you belong from India, you have certain additional rights. The same has been listed below:

  • Right to nominate another person: You have the right to nominate any individual to act on your behalf in case of your death or incapacity to exercise applicable rights.

If you belong from UK/EEA region you have certain additional rights. The same have been listed below:

  • Right to restrict our use of your Personal Data: the right to limit the way in which we can use or process your Personal Data.
  • Right to data portability: the right to request that we move, copy or transfer your Personal Data to another data controller in a machine-readable format.
  • Right to object: the right to object to our use or processing of your Personal Data including where we use it for our legitimate interests.

Please contact us at data.privacy@airindia.com if you wish to make a request for exercising the above rights or if you have a grievance related to the processing of your Personal Data. To help us confirm your identity and to ensure that the personal data is only disclosed to authorized individuals, please provide your full name, frequent flyer number (if loyalty member), email ID and phone number registered with us while sending the data subject request. Please note, where required we may also request for additional information before taking any actions on the requests raised by you. If you are raising a data subject request on behalf of another individual, such requests shall be accompanied by appropriate proof of identity of the requester, details of relationship with the person on whose behalf the request is being made and proof of authority for making such a request.

We will not charge you for exercising any rights provided above, unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why within 7 business days.

VIII. Existence of Automated Decision-Making such as Profiling

We may engage in automatic decision making using your Personal Data for marketing purposes in accordance with applicable laws. You have a right to object to such automatic decision making in certain instances, depending on applicable laws. Kindly refer to Section VII to understand how to exercise your rights.

IX. Links

Our website, mobile application, or other services may contain links to other web sites or platforms. Please be aware that we are not responsible for the privacy practices of web sites not operated by us. We encourage you to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by our website, mobile application, or other services.

X. Transfer of your Personal Data

(a) The Personal Data that we process may be transferred to countries other than where you are based. For example, we transfer your Personal Data, where some of our processors are located. If you are based in the EU, we rely on standard data protection clauses that are approved by the European Commission for the transfer of Personal Data outside the European Economic Area.

(b) You can find out more information about these transfer mechanisms by contacting us.

XI. Security

We strive to do our best to protect your personal data and undertake all appropriate technical and organizational measures to ensure the same. We constantly review our security practices to mitigate any risk arising out of unauthorized access, accidental data loss, or damage to your personal data.

Our security practices are in alignment with the industry best practices, including storing your account details and personal information on secure servers and conducting regular security and privacy trainings for our employees to make them understand their responsibilities in looking after your information.

XII.  Notification of Breach

If you suspect any misuse or loss or unauthorized access to your Personal Data please let us know immediately by contacting us via the contact details given in this Privacy Policy as provided in Section XIV.

XIII. Changes to this Privacy Statement

We will post changes to this Privacy Policy and update the effective date when this Privacy Policy is updated. We may modify this policy and all modifications will be notified to you in accordance with applicable laws. You are free to decide whether to accept a modified version of this Privacy Policy or not.

XIV. Privacy Contact Information

If you have any questions regarding our Privacy Policy or if you want to exercise any of your rights, you can do so by contacting our Data Protection Officer Mr. Davinder Kumar  through  data.privacy@airindia.com.

XV. Cookie Usage

Air India uses cookies to improve your experience of using our website. Please refer to our Cookie Policy for additional details.

13 July 2024