Privacy Policy

1. GENERAL

1.1 We are committed to respecting Your privacy and protecting Your personal information.

1.2 For the purposes of this privacy policy and notice ("Privacy Policy") "We", "Our" and "Us" refers to IAG Connect and the Airline while references to "You" and "Your" refers to the persons using the Services and / or purchasing any Goods (including persons who access the Services or purchase the Goods on behalf of other persons).

1.3 This Privacy Policy applies in addition to (a) the privacy policy between You and the Airline available at their website; and (b) if You are a member of a loyalty scheme operated by the Airline and/or Avios Group (AGL) Limited (“AGL”) issuing Avios points such as the Executive Club.

1.4 For the purposes of this Privacy Policy:

1.4.1 “British Airways”/ “Airline” means British Airways Plc a company registered in England under company number 1777777 and with a registered office at Waterside (HAA2), PO Box 365, Harmondsworth, Middlesex, UB7 0GB, UK.

1.4.2 "Goods" are any items that may be made available to purchase through this website and/or app; and

1.4.3 "Services" are the Wi-Fi Services and any other services that may be accessed through this website and/or app.

1.4.4 Other terms that are capitalised in this Privacy Policy have the meaning given to them in the Terms and Conditions in the Glossary (Section BE).

2. CONTROLLER OF PERSONAL INFORMATION

Any personal information processed by Us in connection with this Privacy Policy is controlled by IAG Connect and by the Airline, which are each and separately considered the "data controller" under applicable data protection laws.

IAG Connect address is Dublin Airport, County Dublin, Ireland. They can be contacted via the Data Protection Manager at the following address: Waterside (HAA2), PO Box 365, Harmondsworth, Middlesex, UB7 0GB, UK.

British Airways address is Waterside (HBD2), PO Box 365, Harmondsworth, Middlesex, UB7 0GB, UK. They can be contacted via the Data Protection Manager at the same address.

3. HOW AND WHEN DOES THIS POLICY APPLY?

This Privacy Policy applies to personal information about You that We collect, use and otherwise process in connection with Your relationship with Us as a customer or potential customer, when You access and use this website and/or app. This website and/or app provides You with direct access to Our catalogue to make online purchases of the Goods and/or Services offered. By visiting this website and/or app, purchasing these Goods and/or accessing or using these Services You agree and consent to Your personal information being used and disclosed in the manner set out in this Privacy Policy. You do not have to provide Your personal information to Us but if You do not provide certain information We will be limited in the products and Services We can make available to You. However, We are not responsible for third parties’ use of Your information where such use is permitted for their own purposes and You should consult their privacy policies for further information.

4. HOW WILL WE INFORM YOU OF CHANGES TO THIS PRIVACY POLICY?

If We change this Privacy Policy, We will let You know about the changes by publishing the updated version on Our website which will take effect as soon as it is posted. We are committed to protecting and respecting Your privacy and will continue to do so in any future changes We make to this Privacy Policy.

5. WHEN DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?

5.1 We collect personal information about You when You access this website and/or app and/or when purchasing Goods and/or accessing Services including, for example:

5.1.1 what You provide to Us and in any communication between You and Us;

5.1.2 automatically in connection with Your use of Your electronic device and the Services;

5.1.3 from Our service providers including Our internet connectivity and payment service partners;

5.1.4 if You complete a customer survey or provide Us with feedback;

5.1.5 if You enter a competition or register for a promotion; and

5.1.6 if You choose to interact with Us via social media, such as Facebook or Twitter.

5.2 In addition, We may receive personal information about You from third parties, such as:

5.2.1 companies contracted by Us to provide any Goods and/or Services to You;

5.2.2 companies involved in Your travel plans, including airlines involved in Your prior or onward journey, relevant airport operators and providers of ground transport and accommodation services; and

5.2.3 Our partner companies (e.g. car hire providers and hotels) that participate in Our affiliate schemes, loyalty schemes and other customer programmes.

6. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT AND PROCESS?

6.1 We may process the following categories of information:

6.1.1 Personal Information. Personal Information is information that You provide to Us that identifies You, for example, Your name, address, date of birth, email, telephone number, etc., or that can be used to identify You. Personal Information does not include information that is about You but from which You could not reasonably be identified.

6.1.2 Sensitive Personal Information (for EU residents). Sensitive Personal Information is Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, biometric data or data that concerns health or sexual activity.

6.1.3 Contact Information. Contact Information is Your name, email address, telephone number and any other contact information that You provide Us with in connection with creating, accessing or updating Your Account with Us for the Goods and/or Services.

6.1.4 Security Information. Security information includes answers to any security question used for the purposes of verifying Your identity and any password used by You as part of any log-on process in accessing Your Account for this website and/or app.

6.1.5 Payment Information. Payment Information is the credit card, debit card or related banking information You provide Us with to pay for the Services.

6.1.6 Network and Device Information. We may collect information about Your electronic device and information that is necessary to provide You with the Services, such as device type, a session ID token, source and destination addressing information, IP address, MAC address, the software You are using and related device and network information.

6.1.7 Location Data. We may collect data regarding Your location while You are using the Services (more specifically, the location of the mobile device that is accessing the Services).

6.1.8 Order History. Your order history will contain details of all purchases made by You in accessing these Goods and/or Services through this website and/or app.

7. HOW DO WE COLLECT AND USE WEB/APP USAGE DATA?

7.1 When You visit this website and/or app, We may collect and process information about Your website/app usage (e.g. Your browsing history and information about Your navigation through Our website) using "cookies" and other similar technologies. We may also combine Your web usage data with other information We have about You.

8. HOW DO WE COLLECT AND USE GEO LOCATION INFORMATION?

8.1 When You use this website, and/or app We collect information about Your location based on Your IP address. An IP address (i.e. an Internet Protocol address) is a numeric code that can act as a unique identifier for Your computer or other access device and can be used to indicate the country from which You are accessing the relevant website or app. Knowing the country You are likely to be in enables Us to provide more relevant content and do so in an appropriate language. We also use this information to analyse how Our website users interact with Our websites.

8.2 If We have Your permission to do so, We may also use the functionality on Your electronic device (such as Bluetooth and GPS) and/or information based on Wi Fi and/or mobile phone mast locations to determine Your approximate location so that We may provide You with more relevant content and Services. We only do this where You have provided Your consent to the use of location data, which may typically be provided (or withdrawn) by adjusting the settings of Your electronic device.

9. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

9.1 The main purposes for which We use Your personal information are to deliver the Goods and/or Services You have asked for or purchased, including:

9.1.1 verifying Your identity and processing payments;

9.1.2 to provide Goods and/or Services tailored to Your requirements and to treat You more personally;

9.1.3 to send You service communications;

9.1.4 to conduct customer surveys;

9.1.5 to support other administrative purposes which may include for example, accounting and billing, auditing, credit or other payment card verification, anti fraud screening (including the use of credit reference agency searches and payment card validation checks), safety, security, health, administrative and legal purposes and systems testing, maintenance and development.

9.2 We may also use and retain Your personal information for the following marketing related purposes:

9.2.1 direct marketing communications (e.g. sending You marketing emails) to include offers and content relevant to You where You have agreed to such communications. These communications may be tailored to You based on the information that We hold, from the use of this site including Your order history.

9.2.2 for the promotion and the operation of affiliate, loyalty and other customer programmes;

9.2.3 statistical and marketing analysis;

9.2.4 sales and marketing research; and

9.2.5 tailoring the site content.

10. WHEN WILL WE SEND YOU MARKETING COMMUNICATIONS?

10.1 You may receive marketing communications from Us and third party providers who are providing Goods and/or Services to You if You have You requested information, Goods or Services from Us, or if You provided Us with Your details when You entered a competition or registered for a promotion (and have expressed a preference not to receive such communications).

10.2 When accessing this website and/or app there is an option not to receive marketing, offers and promotion from Uss. If You do not want to receive direct marketing communications from Us then please select that option.

10.3 In addition, each marketing communication We send by email will also have an "unsubscribe" option which will allow You to stop You receiving further marketing emails.

10.4 Please note that if You tell Us that You do not wish to receive further marketing communications, You will still receive "service" communications (as described above) confirming and servicing any purchases You may have with Us. If You are a loyalty scheme member or customer programme member of the Airline or any airline within Our group, We will continue to keep You informed about Your membership benefits and other important information relating to the loyalty scheme or customer programmes.

10.5 In addition to using the ‘unsubscribe’ link in emails, if You receive marketing communications from Us because We obtained Your details when You registered with this Site, or purchased Goods and/or Services from Us, You can tell Us at any time that You do not wish to receive these marketing communications by writing, with Your full name, address and other contact details to the address given above in paragraph 2.

10.6 You will not receive direct marketing communications from companies outside of Our group as a result of giving Your details to Us, but We do use third parties to send marketing communications on Our behalf. If We do ever want to allow a third party to send You direct marketing not related to Us, We will seek Your permission before sharing Your details with them. However, please be aware that We do sometimes send marketing communications that promote a third party’s products and Services (for example, those of Our business partners) as well as Our own.

11. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

11.1 Your personal information may be shared within the IAG Group including the companies that operate the following airlines, Aer Lingus, British Airways, Iberia, Iberia Express, Level and Vueling. We may also share the information with other companies owned by IAG including Avios Group (AGL) Limited and British Airways Holidays Limited. We share information with these parties so they can assist Us in providing any Goods and/or Services to You.

11.2 We may also disclose Your personal information to the following third parties for the purposes described in this Privacy Policy:

11.2.1 other companies needed to deliver the Services You have asked for including internet connectivity service providers and content providers (including GoGo Inc., Panasonic and Inmarsat);

11.2.2 credit and charge card companies, credit reference agencies and anti fraud screening service providers (including Cybersource Corporation a subsidiary of Visa Inc.);

11.2.3 any partners in Our loyalty schemes and customer programmes that You have joined;

11.2.4 third parties running customer surveys on Our behalf (further details above);

11.2.5 third party service providers We are using to provide Goods and/or Services that involve data processing;

11.2.6 third parties, such as law firms and law courts, in order to enforce or apply any contract with You;

11.2.7 third parties, such as the police and regulatory authorities, to protect Our rights, property, or the safety of Our customers, staff and assets; and

11.2.8 if necessary to comply with a legal or regulatory obligation in any jurisdiction, including where that obligation arises as a result of a voluntary act or decision by Us (eg Our decision to operate to a country or a related decision).

12. WHAT COUNTRIES WILL YOUR PERSONAL INFORMATION BE SENT TO?

12.1 Your personal information may be sent to and stored by Us and third parties in countries outside the country in which You are located and in particular outside the European Economic Area. This occurs in the course of providing Your travel arrangements and because Our business and the third parties identified in “Who do we share your personal information with?” have operations in countries across the world. This may involve sending Your data to countries where under their local laws You may have fewer legal rights. However, wherever We store Your information We will treat it in accordance with this Privacy Policy.

12.2 By continuing to use Our Services, the Portal and by providing any personal information, You consent to such transfers, storing and processing of Your personal information outside the country in which You are located and outside the European Economic Area, including to countries where under their local laws You may have fewer legal rights.

13. HOW CAN YOU AMEND PERSONAL INFORMATION YOU’VE PROVIDED?

13.1 You can change Your personal details by amending Your profile at this website and/or app or contacting IAG Connect at the address given above in paragraph 2.

13.2 You can also change Your personal details by amending Your profile at the Airline's website or contacting the Airline at the address given above in paragraph 2.

14. ACCESSING YOUR PERSONAL INFORMATION

14.1 You have the right to request and access a copy of any personal data about You held by Us. You also have the right to correct, amend, or delete personal data that is inaccurate, that has been processed in breach of any applicable privacy laws other than where We have a legal obligation to retain that personal data.

14.2 The request must be in writing and must contain the following:

14.2.1 Your name and postal address;

14.2.2 any details which may help Us locate the information You are requesting, for example:

14.2.2.1 booking reference or flight numbers and dates; and/or

14.2.2.2 IAG Connect account details.

14.3 You must also provide:

14.3.1 a photocopy of Your passport or driving licence, so that We can verify Your identity;

14.3.2 Your signature and the date of the request; and

14.3.3 signed authority from the individual whose data is required if You are applying on their behalf.

Please send Your request for information held by IAG Connect or British Airways to the address given above in paragraph 2.