Privacy Policy

1 INTRODUCTION

Welcome to the Privacy Policy of Gulf Air (GF).

Your privacy is important to us and we want to assure you that the Personal Data we collect about you will be treated with care. This Privacy Policy will inform you about how we look after your Personal Data when you visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2 DEFINITIONS

This Privacy Policy uses a number of definitions which are set out below:

• Data Controller: the entity which is responsible for determining when, why and how to Process Personal Data and for establishing practices and policies in line with applicable data protection law.
• Personal Data: any information which identifies an individual or information relating to an individual who can be identified (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. For example, Personal Data can include your name, date of birth and passport number. However, Personal Data does not include anonymous data or data that has had the identity of an individual permanently removed.
• Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
• Sensitive Personal Data: any personal information that directly or indirectly discloses the ethnic origin of the individual, their ethnic group, political or philosophical views, religious beliefs, trade union affiliation, criminal record, or any data relating to their health or sexual status. any data which reveals details about sensitive issues such as an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about physical or mental health, or genetic and biometric data.

3 IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of this website or the Gulf Air mobile application, including any data you may provide through this website when you make or amend a flight booking, join our Falconflyer Program or sign up to our newsletter.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements such other notices and is not intended to override them.

Identity of Data Controller
Gulf Air is the Data Controller of all Personal Data relating to our passengers, employees and third party individual contacts, as well as any other Personal Data used in our business for our own commercial purposes.
This Privacy Policy is issued on behalf of the Gulf Air so when we mention “Gulf Air”, "we", "us" or "our" in this Privacy Policy, we are referring to Gulf Air as being responsible for processing your data. Gulf Air is the Data Controller and responsible for this website.

Data Protection Officer
Gulf Air will appoint a Data Protection Officer (DPO) who will be responsible for overseeing questions in relation to this Privacy Policy. In the meantime, if you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

• Email address: dpo@gulfair.com
• Postal address: PO Box 138, Manama, Kingdom of Bahrain

You have the right to make a complaint at any time to the Personal Data Protection Authority, Kingdom of Bahrain (www.pdp.gov.bh), which is the Supervisory Authority for data protection issues in the Kingdom of Bahrain. If you are located in the United Kingdom, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (www.ico.org.uk), the UK Supervisory Authority for data protection issues. If you are located in the EEA, you have the right to make a complaint at any time to the Supervisory Authority in your country.

We would, however, appreciate the chance to deal with your concerns before you approach the Supervisory Authority so please contact us in the first instance using the contact details above.

Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and up-to-date. It is your obligation to keep us informed if your Personal Data changes during your relationship with us. Please use the following links to update your Personal Data:

Falconflyer members
https://falconflyer.gulfair.com/ffp/user/login
Manage My Online Booking
https://flights.gulfair.com/falcon/cbh/mmb/login

This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by Gulf Air. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you look at other websites, we encourage you to read the Privacy Policy of every website you visit.

4 THE DATA WE COLLECT ABOUT YOU

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

• Identity Data: includes first name, middle name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport number and Falconflyer Program membership number.
• Contact Data: includes billing address, home address (if different), email address and telephone numbers.
• Financial Data: includes bank account and payment card details.
• Transaction Data: includes details about payments from you and other details of services you have purchased from us.
• Technical Data: includes internet protocol (IP) address, your login data, data about your 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 this website.
• Usage Data: includes your username and password, Falconflyer Program membership number, bookings made by you, your interests, service preferences, feedback and survey responses.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and third parties (i.e. any external partners) and your preferences when receiving communications.

Aggregated Data
When you visit this website or use any Gulf Air mobile applications, we may also collect, use, store and share aggregated, anonymised statistical or demographic data (Aggregated Data). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as it cannot directly or indirectly reveal your identity.
Aggregated Data may include the time and length of your visit to this website, the pages you have visited on this website, as well as details of the website you visited immediately prior to visiting this website. We may also record the name of your internet service provider. We use this information only to measure site activity and to develop ideas for improving our services.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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.

Sensitive Personal Data
It is a necessary part of our business to collect certain types of Sensitive Personal Data about you. For example, we need to collect data about your state of health if you inform us that you are pregnant, have a medical condition which requires special equipment, or when you make a request for mobility assistance. Making certain meal choices will also involve the collection of data about your religious beliefs or state of health, for example if you inform us that you require a Hindu or diabetic meal.
We treat our obligations to protect Sensitive Personal Data very seriously and we will always ask your express consent to collect, process or transfer such data for specified purposes each time you provide it to us.

Personal Data relating to minor passengers
In certain circumstances, we may need to collect, process or transfer Personal Data relating to minor passengers (i.e. children under the age of 16), for example where a flight booking is made in respect of a minor passenger. This is necessary for us to pursue our legitimate interests in running our business and to perform the contract of carriage.
We will only use Personal Data relating to minor passengers for the specified purposes set out in the “HOW WE USE YOUR PERSONAL DATA” section and with the express consent of the person who has parental responsibility. Minor passengers have the same rights as any other passenger regarding their Personal Data which are set out in the “YOUR LEGAL RIGHTS” section.

Providing Personal Data on behalf of other passengers
By providing us with Personal Data, including Special Categories of Personal Data, relating to other passengers on your booking, you are representing that you have their authority to provide their Personal Data to us and to consent to their Personal Data being collected and processed for the specified purposes. Gulf Air is entitled to rely upon such representations.

If you fail to provide Personal Data
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, we may not be able to perform the contract we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept your booking, but we will notify you if this is the case at the time.

5 HOW IS YOUR PERSONAL DATA COLLECTED?

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

• Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide to us when you:
• book a flight or arrange any other service with us;
• create an account on this website;
• join our Falconflyer programme;
• apply for a career with us;
• subscribe to our newsletter;
• enter a competition, promotion or survey; or
• submit an enquiry or give us some feedback.
• This website. As you interact with this website, we may 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 the “HOW WE USE YOUR PERSONAL DATA” section and our Cookie Policy for further details.
• Our mobile website and mobile applications. Our mobile website and mobile applications have the ability to access mobile device information to better serve passengers in the service that is used. We may use location data for our mobile website and mobile applications to enable us to provide the most helpful format and content (for example pre-populating your departure airport based on current location) providing that you have agreed to the use by Gulf Air of your location data. If you would like to restrict our collection of your location data, please adjust the settings on your device.
• Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
• Data from the following parties:
1. analytics providers such as Google;
2. advertising networks; and
3. search information providers.
• Contact, Financial and Transaction Data from providers of technical or payment services.
• Identity and Contact Data from data brokers or aggregators.

6 HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data as permitted by law. Most commonly, we will rely on the following types of lawful basis to process your Personal Data:

• Legitimate Interests: the interests of Gulf Air in conducting and managing our business in order to give you the highest standard of service and the best and most secure travel experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. For example we may collect data on the confirmation of your passage through various checkpoints at the airport, in order to optimize punctuality. Airport management entities may record the time of the pre-screening of boarding passes before passengers’ entry to the security area and provide us with this data at the departure gate shortly before departure to enable us to check for missing or possibly delayed passengers and initiate an early unloading of baggage where appropriate. We do not use your Personal Data for activities where our interests are overridden by your fundamental rights and freedoms (unless we have your express consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
• Performance of Contract: processing your Personal Data is necessary for the performance of the contract of carriage to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation: processing your Personal Data may be necessary for compliance with a legal or regulatory obligation to which we are subject. For example, in accordance with Article L 232-6 of French Internal Security Code, we may transmit reservation, checking or boarding data collected from passengers (API/PNR) to the French national public services and competent authorities for the purposes and under conditions as defined in the Decret N° 2014-1095 dated 26 September 2014.
• Protecting your vital interests: processing your Personal Data is necessary for protecting your vital interests.
• Consent: in certain circumstances, we may ask for your express consent to collect, process or transfer your Personal Data, for example in relation to opting into receiving our newsletter or other direct marketing. You have the right to withdraw your consent at any time simply by contacting us.

Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of all the ways we will use your Personal Data, and which types of legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying upon to process your Personal Data where more than one basis has been set out in the table below.

Cookies
This website makes use of cookies to measure site activity and to customise information to your personal tastes. A cookie is an element of data that a website can send to your browser which may then store the cookie on your hard drive, either temporarily or long term. This means that, when you visit this website in future, we can tailor information to suit your individual preferences which can save you time and provide you with a more personalised visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you to explain the legal basis which allows us to do so or, where required by law, to seek your consent.

7 MARKETING

We aim to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this “marketing”).
The “soft opt-in”
You will continue to receive marketing communications from us if you have previously booked flights or purchased other services from in the past, or if you have requested information from us in connection with a potential booking or purchase, unless you have opted out of receiving future marketing communications.
Third-party marketing
We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8 DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your Personal Data for the purposes set out in the table in the “HOW WE USE YOUR PERSONAL DATA” section with third party service providers.
Disclosure of your Personal Data within Gulf Air
All parts of Gulf Air, including outstations, branches and offices acting as joint controllers or processors and which are based in EEA and non-EEA countries, e.g. the Kingdom of Bahrain, and provide IT and system administration services.

Disclosure of your Personal Data to External Third Parties

• Service providers acting as processors based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who provide IT and system administration services to Gulf Air.
• Service providers and suppliers acting as processors based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who provide passenger services, such as ground-handling companies, catering providers, and companies providing assistance for passengers with reduced mobility.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, consultants, auditors and insurers based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers based in the Kingdom of Bahrain and all countries to which Gulf Air provides airline services who require reporting of processing activities in certain circumstances.
• 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.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

9 INTERNATIONAL TRANSFERS

Internal Transfers
We will share your Personal Data within the Group. As Gulf Air’s head office is based in Bahrain, it may be necessary to transfer Personal Data which was collected in Bahrain outside of it to other parts of the Gulf Air Group. If you are accessing this site from outside Bahrain, you consent to the transfer, storage, and processing of your data in Bahrain or other countries.
We ensure your Personal Data is protected by requiring all of our Group companies, branches, offices and outstations to follow the same rules when processing your Personal Data. These rules are called "Binding Corporate Rules". Gulf Air’s Binding Corporate Rules are found under the Transparency section. 

External Transfers
Many of our external third parties are based outside Bahrain so their processing of your Personal Data will involve a transfer of data outside Bahrain. 
Whenever we transfer your Personal Data to third parties which are based outside Bahrain, we ensure a similar degree of protection is afforded to the data by ensuring at least one of the following safeguards is implemented: 

• Certain non-EEA countries to which we will transfer your Personal Data have already been deemed by the European Commission to provide an adequate level of protection. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
• Where we use third party service providers based in the US, we may transfer data to them if they are covered by the EU-US Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US. For further details, see: European Commission: EU-US Privacy Shield.
• Where we use certain third party service providers which are not based in the EEA or the US, we may use specific contracts approved by the European Commission which give your Personal Data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

10 DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures 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.

11 DATA RETENTION

How long we retain your Personal Data
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure in the "YOUR LEGAL RIGHTS" section for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12 YOUR LEGAL RIGHTS 

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

• Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete, inaccurate or outdated data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
• Request blocking or erasure of your Personal Data. This enables you to ask us to block or delete or remove Personal Data where the Personal Data is incorrect, incomplete, outdated, there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, if the processing for a particular purpose or in such a manner is to your or a third party data subject’s material or moral damage, and is not justified, unless you have provided your consent to such processing. You also have the right to object where we are processing your Personal Data for direct marketing purposes (and you will always be able to opt-out via the “unsubscribe” link on an email from us) and to decisions based solely on automated processing of personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to information which was originally collected electronically and which you either consented to us using or was used to perform a contract with you. 
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required 
You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee (taking into account the administrative costs of providing the information) if we consider your request to be unfounded, repetitive or excessive. Alternatively, in these circumstances, we may refuse to comply with your request but we will provide you with a full explanation of this at the time. 

What we may need from you 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 
We will respond to all legitimate access requests within fifteen business days and to all other legitimate requests for correction, blocking, and wiping, within ten business days. If your request is particularly complex, or you have made a number of requests, or there are justifiable reasons, it may take us up to 3 calendar months to respond, but we will notify you of this and keep you updated. 

Users in the European Economic Area (“EEA”) and United Kingdom (“UK”)
If you are located in the EEA or UK, you have the right to request access to your data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of your personal data in accordance with the General Data Protection Regulation (GDPR) or the UK GDPR. You also have the right to obtain a free copy of the specific contracts referenced in Section 9. You may use the information in Section 3 to submit your request. Additionally, you also have the right to lodge a complaint with your Supervisory Authority if you are located in the EEA, and with the ICO if you are located in the UK.
We will respond to all legitimate requests within one calendar month. If your request is particularly complex, or you have made a number of requests, or there are justifiable reasons, it may take us up to 3 calendar months to respond (instead of the 1 calendar month mentioned earlier), but we will notify you of this and keep you updated.
Personal data is also processed outside of the UK, Switzerland, and the EEA by Gulf Air’s group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 8. We use specific standard clauses to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and Gulf Air Group companies to restrict and regulate their processing of your data. By submitting your data, accessing our site or using our services, you consent to this transfer, storage, and processing by Gulf Air and its processors. 

13 CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. This version of the Privacy Policy was last updated on 03 November 2022. Historic versions of this Privacy Policy can be obtained by contacting us

[1] The EEA is composed of the 28 EU Member States plus Norway, Iceland and Lichtenstein.