AIR INDIA CUSTOMER DATA PRIVACY POLICY

Cookie policy

Air India uses what are known as browser cookies (hereinafter referred to as “Cookies”) in order to simplify the use of this Website and other websites and applications operated by SWISS (hereinafter referred to as the “Website”) and to obtain information that can help us to improve the information and services made available via the Website. This Cookie Policy provides you with information on the use of Cookies on the Website.

Cookies mean

Cookies are small text files that a User’s browser stores in a directory designed for this purpose on his/her computer. Cookies mean, for example, that text entries you have made in form fields on the Website are saved so that you do not have to enter the same information again the next time you visit the Website or when you want to use a different function on the Website.

Cookie settings

You can decide for yourself whether our Website’s web server is allowed to save Cookies on your computer or not. You can opt to change your browser settings so that they do not allow Cookies to be accepted or saved at any time. Alternatively, you can opt to be shown a warning message every time before you accept Cookies or you can set your browser up in such a way that it only accepts Cookies from certain websites. You can also delete Cookies that have already been saved at any time.

Web analysis

We use web analysis services to analyse the use of the Website in general and to gain insights into how to improve our offering. The web analysis services use Cookies to collect data. The information generated in this process (e.g. IP address and browser type) can be transmitted, after being rendered anonymous, to a server of the web analysis service in Germany or abroad to be saved and processed there. You can use corresponding browser settings, or set up an opt-out cookie of the web analysis service in question to prevent the service from placing Cookies on your computer and collecting data.

Online marketing

Air India uses internationally active online marketing networks such as DoubleClick to operate its online marketing measures (e.g. banners or affiliate programmes). These networks use Cookies to be able to focus marketing measures on the identifiable needs of customers. You can set opt-out Cookies to prevent these online marketing networks from placing Cookies on your computer and collecting data.

AIR INDIA CUSTOMER DATA PRIVACY POLICY

Table of Contents

• CHAPTER-I: Introduction
• CHAPTER-II: Scope and interpretation of this Policy
• CHAPTER-III: Information we collect about you
• CHAPTER-IV: How we use your information
• CHAPTER-V: Disclosure of your information to other parties
• CHAPTER-VI: Use of cookies, web beacons and other similar technologies
• CHAPTER-VII: Your control over your information
• CHAPTER-VIII: Minors
• CHAPTER-IX: Protecting information collected
• CHAPTER-X: Disclaimer
• CHAPTER-XI: Miscellaneous

CHAPTER – I

Introduction

Air India is a national carrier airline of India that operates its flights on domestic and
international sectors.

The customers of Air India include customers of different nationality and jurisdiction who avail/
book various services of Air India on different online and offline platforms, namely, Air India
website, mobile site, mobile applications, customer contact centre, authorised agents and
affiliates of Air India. In the course of availing such services, the customers of Air India provide
certain personal data and information to Air India and the said data and information is collected
and used by Air India to provide safe, smooth and efficient services to the customers; in which
event Air India is the controller of the personal information and data provided by the
customers.
Further, in certain cases, part of Air India services require the customers to voluntarily share
their preferences and options to avail additional services that involve third party participation
for provision of such additional services. In such cases, Air India collects and processes the
personal information and data of the customers with the third parties who are affiliates of Air
India.
In both the above cases, Air India acts as either the controller or the processor of the personal
information and data collected from the customers depending upon the purpose for which the
data is collected.
Air India is committed to respect the customer privacy and strives to take reasonable measures
to protect customer information which Air India collects, uses and discloses for regulatory and
business purposes and in order to provide the customer with a safe, smooth, efficient and
customised experience with Air India.
You should read this Policy carefully. By continuing to use our sites and/or our services or
otherwise providing us with any information, you signify that you have read, understood and
agree to be bound by this Policy as amended from time to time in respect of Air India’s
collection, use, handling and disclosure of your information as described in this Policy.
Please note that this Policy is not a contract and does not create any legal rights or obligations.
Instead, this Policy serves as guidelines for protecting your information.
For the purpose of this Policy, wherever the context so requires “you” or “your” shall mean
Customer and the term “we”, “us”, “our” shall mean Air India.

CHAPTER – II

Scope and Interpretation of this Policy

1. “Customer” means any person who purchase / intends to purchase / inquire about any
product(s) and / or service(s) made available by Air India through any of Air India’s
customer interface channels, namely, website, mobile site, mobile app, offline channels
including call centres, ticketing and reservations offices, authorised agents, affiliates and
code share airlines.

2. This Policy applies to the information that Air India collects about you, which include
the following situations:
• On Air India-managed websites and mobile websites, namely, airindia.in,
flyingreturns.co.in, flyai.mobi;
• Through Air India-managed mobile applications, namely, Air India Mobile App;
• Offline, namely, Air India ticketing offices, Customer Contact Centre, authorised
agents or other affiliates.

3. This Policy does not apply to any site not owned and managed by Air India. Please see
those respective sites for the privacy policies that may apply.

CHAPTER – III

Information we collect about you

1. Air India does not buy or acquire your personal information and data. Air India collects
and maintains your personal information and data when you provide the same while
booking or availing services on the online and offline platforms of Air India and its
affiliates. We collect information from you when you make travel arrangements, contact
us, complete a survey, register for the Flying Returns program, participate in a
promotion, or otherwise interact with us. The type of information we collect about you
depends on your particular interaction with us. The mandatory information we directly
collect about you to provide the services booked by you is as follows:

• Name;
• Contact information, namely, address, phone number and e-mail address;
• Flying Returns number and security information (if you are a registered member
of Air India Flying Returns program or Star Alliance program;
• Gender and date of birth;
• Payment information (namely, debt or credit card information, card number,
name of cardholder, billing address and expiry date);
• Passport information and photograph (in case of international travel);
• User and activity data from our sites and applications;

2. The other information we collect about you, when you voluntarily opt to provide the
same while booking services with Air India, includes:
• Government ID;
• Corporate ID or promo code;
• Images;
• Travel information, preferences and special requests (namely, flight information,
dietary, seating or other service preferences, upgrades, baggage requirements,
lost luggage);
• Purchase information (including both travel and non-travel purchases);
• Health information (namely, medical records or requests);
• Survey responses;
• Tax identification number of promotion or survey winner, depending on the
value of the prize.

3. Source of information
We collect your information from the following sources:
• Online purchases: When you book, purchase or enquire for services at Air
India-managed websites, mobile sites and mobile applications.
• Offline purchases: When you book, purchase or enquire for Air India services at
Air India ticketing offices, Customer Contact Centres or through authorised
agents or other affiliates of Air India. To make a purchase or transact other
business with Air India Customer Contact Centre, travel agents (including online
travel agents outside of Air India), or a customer service representative
(collectively, “Reservations Agents”), Reservations Agents collect data, namely,
payment information, birth date, name, addresses, email addresses, and
telephone numbers. We may monitor and/or record telephone calls to
Reservations Agents. By continuing with the call, you are deemed to consent to
such monitoring and/or recording. The Reservation Agents are not directly
under the control of Air India until you book Air India services with them.
• Frequent Flyer Program: When you book, purchase or enquire for Air India
services using Air India Frequent Flyer Program membership or any other
loyalty membership obtained from Air India or its affiliates. When you enroll in
Air India Flying Returns Program, or if you are already a Flying Returns member,
we collect specific information, namely, your name, address, phone number(s),
email address, Flying Returns account number password and other account
security authentication information. If you create a traveller profile, we also will
collect the information that you choose to provide to us, which may include but
not be limited to: payment information (namely, debit or credit card
information, billing name and address), telephone numbers, email addresses,
general requests or special needs, travel preferences and loyalty program
information.
• Medical or other emergency: If a medical or other emergency occurs while
travelling with Air India, we may collect information, including but not limited to
first and last name, contact information, date of birth, medical history or
information, and may share such information with third-party medical or other
safety personnel as necessary or advisable.
• Information we collect through our mobile application(s) (through
cookies, beacons or other tracking technologies designed for mobile
applications): These include
• Your pinpointed physical location information from technologies like
GPS, Wi-Fi, or cell tower proximity (geo-location tracking), if you agree
to grant us permission to do so;
• At select airports, your precise location may be tracked continuously to
provide you with location-based services, if you agree to grant us
permission to do so.
• Your domain name;
• Device ID or alternative ID where required by the platform provider;
• Electronic data concerning operating systems and computing
devices/browser, including types;
• Features you use and links you click;
• Amount of time spent in the application;
• Installs and uninstalls;
• Transaction details and history.
• Third-party analytics: We also use automated devices and applications, such as
Google Analytics, to evaluate the use of our websites and apps and the services
we provide. We use these tools to gather information about you to help us
improve our services, performance and user experiences. These analytics
providers may use cookies and other technologies to perform their services, and
may combine the information that they collect about you on our websites with
other information that they have collected. This Policy does not cover such third
parties’ use of the data.

CHAPTER – IV

How we use your information

1. We primarily use the information collected from you, to

• carry out our business operations and provide our services to you;
• fulfil necessary compliances under applicable law;
• facilitate your specific requests and preferences;
• gather feedback from you to improve our services; and
• build continued relationship with you and to provide you value added offers and
other allied options to avail our services.

CHAPTER-V

Disclosure of your information to other parties

1. Air India may disclose your information to the following persons/entities:

• Air India’s overseas offices and agents;
• Air India’s affiliates including airline partners, code share flights and ground
handling staff;
• Any governmental, regulatory and/or law enforcement authorities as directed
by or required under applicable law, court order, subpoena or other legal
process;

2. Your information may be disclosed by us for all or any of the following purposes:
• to conduct our operations and business and to provide you the services;
• to comply with any applicable law, order, rule, regulation, direction or request of
any governmental, regulatory or law enforcement authority in any jurisdiction;
• to enforce or protect our rights or properties or any or all of our affiliates,
associates, employees, directors or officers or when we have reason to believe
that disclosing your information) is necessary to identify, contact or bring legal
action against someone who may be causing interference with our rights or
properties, whether intentionally or otherwise, or when anyone else could be
harmed by such activities;

• for such other purposes for which you have given your specific request or
consent.

CHAPTER – VI

Use of cookies, web beacons and other similar technologies

1. Air India and our third party service providers collect information by using technologies
and methodologies, such as “cookies”, tags, web beacons or other similar technologies
that enable tracking as you browse our sites. We use these technologies to authenticate
you as a user, to remember your preferences for using the site, to present offers that
may be of interest and to facilitate transactions, such as flight searches and purchases.
We and our third party service providers also use these tools to analyze use of our sites
and our services. We may use this information in the aggregate or combine it with
information that we have already collected about you.
Cookie. “Cookies” are small bits of information that are stored on your computer by
your web browser. Web beacons or “pixel tags” are small strings of code placed on a
web page or in an email message for the purpose of transferring information. Cookies
and the other technologies discussed in this section allow us to recognize your
preference information, to track your transactions and to facilitate effective website
administration.

2. Cookies help establish a user session and allow our server to provide site users with the
appropriate information, advertisements and services. We also use cookies to ensure
you obtain the information you request, to authenticate your authority to access the site
and to track the usage of our websites in order to improve the site(s) according to our
customers’ needs. If you are a registered user on our website and you elect to have the
website store your Flying Returns number, the cookie stored on your computer will
contain your Flying Returns number.

3. If you do not want your information to be collected through cookies, you can change the
preferences in your particular Internet browser. Some website functionality may not
work properly if your browser does not accept cookies. Please consult your chosen
Internet browser for instructions on how to change your cookie settings.

4. Other technologies. These technologies allow us to recognize your preference
information, keep track of your transactions and facilitate effective website
administration. We and our third-party service providers may use other technologies
(also known as web beacons, web bugs or pixel tags), in connection with our sites and
services to, among other things, track the activities of visitors, help us manage content
and compile statistics about usage. We and our third party service providers may also
use emails sent to you to help us track email response rates, identify when our emails
are viewed and track whether our emails are forwarded.

CHAPTER – VII

Your control over your information

1. Air India may, upon your written request to us, allow you to view, change or update your
stored personal information. Where permitted by law, Air India reserves the right to
charge a reasonable administrative fee for this service. In exceptional circumstances, Air
India reserves the right to deny you access to your personal information and may
provide an explanation as required by applicable laws. Exceptional circumstances
include where:
• An investigating authority or government institution objects to Air India
complying with a customer’s request,
• The information may, in the exercise of Air India’s reasonable discretion and/or
assessment, affect the life or security of an individual, and
• Data is collected in connection with an investigation of a breach of contract,
suspicion of fraudulent activities or contravention of law.

2. If you are a Flying Returns member, you can view or update your personal information
by logging into your Flying Returns membership account on Air India Flying Returns
website. You may also update information relevant to your use of our mobile
application(s) through the app itself.

3. To protect your privacy and Air India’s proprietary databases and systems, you should
not share any of your information, such as Flying Returns number or password, with any
unauthorized individuals or third-party information aggregators that would allow them
access to your sensitive account information. You should also take all necessary steps to
secure your mobile devices and protect information you may have stored on them. We
do not have control over the security of your mobile device. Air India assumes no
responsibility for the loss of information associated with security disrupting
technologies, including but not limited to reverse engineering of mobile device
applications or malware, that compromise the Air India mobile application(s) as a result
of owner or third-party initiated changes to the mobile device. The security of that
mobile device is the responsibility of its owner, not Air India.

4. Opting out: Flying Returns members can opt out of receiving marketing or promotionrelated
emails or direct mail from Air India by accessing their account profile
information on the Air India website and changing their profile to indicate their desire
to be excluded. Emails sent to members will contain a message and link on how to opt
out of that type of communication in the future. Regardless of your opt-out preferences,
we reserve the right to send you emails or other communications for administrative
purposes.

CHAPTER – VIII

Minors

1. Due to the nature of our services, Air India will collect and maintain travel information,
about minor (according to applicable laws) when necessary to comply with security
regulations, for safety reasons, or as otherwise necessary for Air India to provide
transportation or other services requested.

2. Air India cannot distinguish the age of persons who access and use its websites. If a
minor (according to applicable laws) has provided Air India with Customer data without
parental or guardian consent, the parent or guardian should contact Air India to remove
the relevant Customer data and unsubscribe the minor.

CHAPTER – IX

Protecting information collected

1. Air India maintains necessary safeguards to protect the customer information and do
not engage in the business of buying or selling the customer data to any third party. Air
India treats the information of its customers as proprietary and confidential and
exercise same degree of care to protect the confidentiality of such information as it
would exercise to protect its own confidential information, but in no case less than a
reasonable degree of care.

2. Air India do not use the personal information of its customers for racial or ethnic
purpose, political opinions, religious or philosophical beliefs or trade union
memberships, processing of genetic or biometric data for the purpose of uniquely
identifying a natural person. However, this prohibition do not apply where any
particular customer has given his or her consent for one or more such purposes or
where the processing of the customer information is necessary for purposes of carrying
out legal obligations of Air India, or where the personal data of any customer is
manifestly public data.

CHAPTER – X

Disclaimer

1. In no event will Air India be liable for any direct, indirect, special, punitive, exemplary or
consequential losses or damages of whatsoever kind arising out of access to, or the use
of any information voluntarily provided by the customer for availing Air India services.

2. Air India also accepts no liability for violation of data protection rights of any customer
if the information provided by such customer is handled, used, stored or disclosed by Air
India in accordance with this Policy or as mandated by applicable law.

CHAPTER – XI

Miscellaneous

1. Location of your information / Data transfer

Air India will transfer, store, and process information that we collect about you, as
described in this Policy, in India, which may not provide the same level of protection for
your personal information as your home country. In addition, we may further transfer
your information outside India for the purposes described in this Policy. By submitting
any personal information or by using the website and without limitation to any other
rights or obligations we have, you consent to such transfer to, and processing in, India
and these other countries, and acknowledge that your information may be subject to
access by law enforcement and other government entities, including courts and
tribunals, in accordance with laws applicable in those jurisdictions.

2. Retention

Air India will retain your information for as long as it is necessary to fulfill the purpose
for which it was collected, the legal or business purposes of Air India, or as required by
relevant laws. When destroying your information, we will take commercially reasonable
and technically possible measures to make the personal information irrecoverable or
irreproducible in accordance with the applicable laws.

3. Other sites/digital channels

Our sites and our online services may contain links to third party sites. Any access to
and use of such linked sites is not governed by this Policy but instead is governed by the
privacy policies of those third party sites. We are not responsible for the information
practices of such third party sites.

4. Contact us

If you have comments or questions about this Policy, please submit your inquiry to Air
India Customer Care. Please reference this Policy in those communications.

5. Legal effect and changes to the policy

As previously stated, this Policy is not a contract nor does it otherwise create any legal
rights or obligations. Rather, this Policy merely reflects guidelines setting forth Air
India’s intended business practices. By using any Air India digital channel, and/or by
providing any information to Air India online or offline, you consent to the collection
and use of such information by Air India, its affiliates, partners, contractors and
permitted agents as herein described and consistent with applicable laws. Also, Air
India, in its discretion, may amend, interpret, modify or withdraw any portion of this
Policy and related business practices at any time by posting updated versions or texts on
this site, and your continued use of our digital channels or offline outlets constitutes
your consent to those changes.

A version of this Privacy Policy has been effective since
May 25, 2018 This Privacy Policy supersedes previous privacy policies posted on Air
India website. Subject to applicable laws, the English version of this Policy will prevail
over any version of this Policy in another language. In the event of any inconsistency in
interpretation between the English version and any translation of the Privacy Policy,
this Policy statement in English will prevail.

Thank you for taking out the time to read this Policy.