Air Serbia privacy statement
Air Serbia takes its responsibility concerning personal data protection very seriously.
Air SERBIA is a Joint Stock Company established and seated in Belgrade, Republic of Serbia. At Air SERBIA, and our affiliates and branch offices (collectively referred to as "Air SERBIA", "we", "us"), we take our data protection and privacy responsibilities seriously. This statement describes how we collect, process, use, disclose and transfer your personal information as a data controller. It covers instances when you contact us, use our services or interact with our website www.airserbia.com or our mobile app.
Terms of Use
Use of the Air SERBIA Website or/and mobile app is subject to our terms of acceptable use, found in our Terms and Conditions. Any products and services supplied are subject to our Terms and Conditions, Customer Care Policy and General Conditions of Carriage.
Updates
We may amend this statement from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this statement. If we make material changes to this privacy statement, we will seek to inform you by notice on our website or email ("Notice of Change").
Third Party Websites
Air SERBIA may link you to other websites. We are not responsible for the way in which third party websites operate or the way in which they may process any personal information, which you provide to them. It is important that you understand this and check their respective privacy policies and terms of use.
What personal information we collect and when and why we use it
In this section you can find out more about:
- the types of personal information we collect
- when we collect personal information
- how we use personal information
Flight and Booking Information
If you use the Air SERBIA Website to make a flight booking or manage a reservation, we will collect and use information about you as necessary to manage the booking. This may include personal information such as your name, date of birth, address, next of kin details, Passenger Name Record number ("PNR number"), gender, passport details, any meal preferences or frequent flyer program membership references such as your username and password (if applicable) together with payment details (such as your credit card number) and contact information (such as phone number and e-mail address) for the lead passenger.
Additionally, if you have made your contact information (phone number and/or email address) availabe to us in the moment of purchasing a ticket, such information may be used for the purpose of notifiying you on changes of your travel itinerary.
We may also seek to collect from you for the purposes of providing you with enhanced services, such as medical services, special categories of personal data, which are treated with extra care by us. These special categories of data include details relating to your health such as whether you use a wheelchair or require an oxygen tank, certain health behaviors such as whether you are a smoker and your religion. In limited circumstances, such as where we are providing you with chauffeur services, we may additionally collect information about your whereabouts using systems such as GPS.
If you or any passenger traveling has special health, dietary or access requirements, which you or they would like us to be aware of, we may collect information about these matters where this is provided.
In case you are natural person using our services within the territory of the People’s Republic of China, we will only collect and use sensitive personal information, either with your consent, or when you voluntarily provide us with this information, or where such information is required or permitted to be collected by law or professional standards. Processing of sensitive information is necessary for our services to be provided. Also, in case of processing of personal information of minors under the age of 14, such personal information will be only processed based on the consent of the parents of other guardians of the minors. Where processing is based on your consent, you will have the right to withdraw your consent. The withdrawal of consent shall not affect the validity of the processing activities conducted based on consent before it is withdrawn. This article is applicable in all cases in which sensitive data of natural person within the territory of the People’s Republic of China is being processed for provision of our services.
Where you are making a booking on behalf of other traveling passengers, it is your responsibility to represent that passenger in the booking process and explain how we will use their personal information as set out in this Privacy Statement. You must obtain their consent to make the booking and share their details with us as anticipated by this Privacy Statement. We will assume that you have done this. We may be under separate legal obligations to explain to them that we are controlling their personal information, even if it comes to us from you.
Advance Passenger Information
On some routes we are required to pass details of the itinerary and booking details in our Passenger Name Record system to border control, customs and law enforcement officers at ports of entry / exit on your itinerary. We will share this information with relevant authorities as required and permitted by local and applicable laws. If you are in, or flying to/from France, please note that in accordance with Article L 237 -7 of French Internal Security Code, air carriers may transmit reservation data collected from their passengers (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 26/09/2014.
Etihad Guest Frequent Flyer Program
Our Frequent Flyer program is managed within our Partner Etihad Airways PJSC from Abu Dhabi in United Arab Emirates with its subsidiaries. If you join our frequent flyer program, Etihad Guest, you will be asked to register your personal details with Etihad Guest. This will allow Etihad Guest to manage your account and provide you with rewards and benefits. This may include information such as your name, date of birth, address, email, telephone number, next of kin, your photograph, passport details, your credit card details including its expiry date, your Etihad Guest Number, PNR number, flight ticket number, professional details such as your profession, title, role, including professional licensing numbers. In exceptional circumstances Etihad Guest, may have access to certain personal data, including Special Categories of personal data (as defined in the General Data Protection Regulation) obtained during the course of your flight, as set out in this policy.
When you join Etihad Guest, you will be asked to confirm that you agree to share data between Air SERBIA and Etihad Guest to receive these benefits. Any information shared with Etihad Guest is held subject to Etihad Guest's separate privacy policy and terms and conditions, which you can find here.
Customer Support and online services
If you contact us with a query or comment about any of our services, or would like us to keep you informed about latest news and developments at Air SERBIA, we will need to collect information about you (including your contact details) to help us respond to your query or request. We may do this when you call our customer support centre, or interact with us through our online support tools. This information may include your name, date of birth, address, email, telephone number, next of kin, your photograph, passport details, your credit card details including its expiry date, your Etihad Guest Number, PNR number, flight ticket number, professional details such as your profession, title, role, including professional licensing numbers. We may also need seek to collect from you Special Categories of Data, for the purposes of properly understanding your query or request, which are treated with extra care by us. These Special Categories of Data may include details relating to your health such as whether you use a wheelchair or require an oxygen tank, certain health behaviours such as whether you are a smoker, your race and ethnicity, your religion
We may also keep a record of any communications we have with you (including a recording of any calls you make). We do this in compliance with applicable laws to help monitor and improve the quality of our customer support services, to make and defend legal claims, and to comply with legal obligations to which we are subject. Where you have asked to receive an information update from us, you are free to change your preferences (for more information, refer to 'Updating your personal profile and preferences' section below).
Events and Promotions
From time to time, we may hold events and special promotions to introduce Air SERBIA to new customers. If you come to one of these events, or take part in a promotion, we may ask for your personal details to help us run the promotion and keep in touch with you about our services and any special offers that we think may be of interest. Any information which you provide will be used in accordance with the terms of this Privacy Statement and you can unsubscribe from further communications from us at any time.
Legal basis for using your data
We will only collect, use and share your personal information where we have an appropriate legal basis to do so. Appropriate legal bases include:
- where we need to use your personal information to perform a contract or take steps to enter into a contract with you, for example to take payment for and manage the terms of any travel booking you have with us, or complete your travel arrangements, if you are a passenger on a flight booking;
- our legitimate interests as a commercial organization, for example we may record calls to our customer service center so that we can review our call handling processes and ensure we provide a continuously high standard of customer service; we may use customer contact information to keep our customers informed about flight changes and other important service messages; we may also let you know about our new routes and special offers that may be of interest to you - in these cases we will respect your privacy rights and ensure you may object to processing as explained in the “Your Rights” section below;
- where we need to use your personal information to comply with a relevant legal or regulatory obligation that we have, for example in some countries we are required to share Advance Passenger Details with law enforcement officials in destination airports before departure, as described in the "Advance Passenger Information" section; and
- where we have your consent to using your personal information for a particular activity, for example to share special offers from ourselves and our partners that we consider may be of interest to you.
In case you are natural person using our services within the territory of the People’s Republic of China, appropriate legal bases also include:
- the processing is necessary for the response to public health emergencies, or for the protection of life, health, and property safety of natural persons in emergencies (vital interest);
- the personal information is reasonably processed for news reporting, media supervision, and other activities conducted in the public interest;
- the personal information disclosed by you personally or other legally disclosed personal information of you processed in accordance with applicable regulation;
- other circumstances as provided by laws or administrative regulations.
To help you understand the legal grounds on which we process your data, please click the link below to see a table that sets out the legal bases upon which we process your personal information in certain circumstances. There may be one or more legal bases applicable to the activities listed. These may be amended and updated from time to time.
Further details
In order to ensure that you are properly booked and checked in we will need to process personal information about you such as your name, address, date of birth, contact details, next of kin, passport details, credit card details, frequent flyer number, frequent flyer username and password, PNR reference, ticket number.
Legal basis for using personal information
To perform our contract with you.
Further details
To ensure that we can carry out any additional services you request we will process special categories of data, such as your religion, or medical history.
Legal basis for using personal information
To perform our contract with you.
Further details
In order to ensure that we book you into suitable hotel accommodation and transport you there where there is a flight disruption, we will need to process personal information about you such as your name, address, date of birth, contact details, next of kin, passport details, credit card details, frequent flyer number, PNR number, ticket number, identifiers for professionals.
Legal basis for using personal information
To perform our contract with you.
Further details
Where you utilize our transport service, we will need to process personal information about you such as your name, address, date of birth, contact details, next of kin, passport details, credit card details, frequent flyer number, PNR number, ticket number, identifiers for professionals, in order to ensure that your passenger transport is booked properly. We may also need to process special categories of personal data such as health care information, and GPS tracking information.
Legal basis for using personal information
To perform our contract with you.
Further details
In order to provide you with customer support including for inbound calls relating to bookings, to modify bookings, special services, cancellations and refunds, ancillary sales, and outbound calls for disruption related messages we will need to process personal information about you such as your name, address, date of birth, contact details, bank account details, next of kin, credit card details, passport details, frequent flyer details, PNR number, ticket number, identifiers for professionals. We may also process sensitive personal information such as health data, race or ethnicity, religion.
Legal basis for using personal information
Legitimate interests.
It is in our legitimate interests to ensure that our business runs smoothly and that we provide you with timely customer support, without undue delay and complication. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data.
If you are a data subject protected by the GDPR or RS Personal data protection law you have rights to restrict or object to this processing, however please note that this may adversely affect our ability to provide you with effective customer support.
Further details
In order to communicate with you to provide updates regarding your flight, for example, if there are likely to be delays to your flight we will need to process personal information about you such as your name, address, date of birth, credit card number, frequent flyer number, PNR number, ticker number, passport details and contact details.
Legal basis for using personal information
To perform our contract with you.
Further details
In the event that you require emergency medical attention and services we will need to process personal information about you such as your name, date of birth, address, contact details, next of kin, passport details, PNR number, ticket number, identifiers for professionals, as well as special data such as your religion, race or ethnicity and health data.
Legal basis for using personal information
To protect your vital interests.
Further details
In the event that there is an emergency and we need to locate family members and next of kin, we will need to process personal information about you such as your name, date of birth, address, contact details, next of kin, passport details, social security number, credit card details, frequent flyer details, PNR number, ticket number, identifiers for professionals, as well as special data such as your religion, race or ethnicity and health data, biometric information, medical identifiers, sensitive information about family members, criminal convictions.
Legal basis for using personal information
To protect your vital interests.
Further details
In order to communicate with your next of kin in cases of emergency we will need to process personal information about you and your next of kin including your names, addresses and contact details.
Legal basis for using personal information
To protect your vital interests.
Further details
In order to communicate with you regarding new offers and services from either us or our affiliates, such as new routes or send you reminders of your unfinished bookings we will need to process personal information about you such as your name, address, contact details, date of birth, frequent flyer details, PNR number, ticket number, identifiers for professionals and passport details.
Legal basis for using personal information
Legitimate interests.
It is in our legitimate interests to promote our business and develop our relationship with you. In order to do this we may wish to bring to your attention new offers from us or our affiliates or send you reminders of your unfinished bookings. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data.
If you are a data subject protected by the GDPR or RS Personal data protection law you have rights to restrict or object to this processing, however please note that this may adversely affect our ability to update you on such new offers and services from us or our affiliates.
Further details
In order to communicate with you regarding new offers and services from third parties we will need to process personal information about you such as your name, date of birth, address, contact details, frequent flyer details, identifiers for professionals, and passport details.
Legal basis for using personal information
Legitimate interests.
It is in our legitimate interests to promote offers and services from third parties in certain circumstances, based upon our understanding of your preferences. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data.
If you are a data subject protected by the GDPR or RS Personal data protection law you have rights to restrict or object to this processing, however please note that this may adversely affect our ability to update you on such new offers and services from such third parties.
Further details
In order to obtain feedback from you via surveys in relation to our services and other matters related to our business we will need to process personal information such as your name, address, date of birth, contact details, next of kin, bank account details, frequent flyer details, ticket number, identifiers for professionals, passport details, and PNR number.
Legal basis for using personal information
Legitimate Interests.
It is in our legitimate interests to engage in surveys with you in order to ascertain certain information for the purposes of how we conduct our business. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data.
If you are a data subject protected by the GDPR or RS Personal data protection law you have rights to restrict or object to this processing, however please note that this may adversely affect our ability to conduct surveys with you.
Further details
In order to enter you into the competitions or prize draws and award the prizes we will need to process personal information such as your name, address, contact details, frequent flyer details and passport details, PNR number.
Legal basis for using personal information
Legitimate Interests.
It is in our legitimate interests to promote our business by engaging with consumers through competitions or prize draws. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data.
If you are a data subject protected by the GDPR or RS Personal data protection law you have rights to restrict or object to this processing, however please note that this may adversely affect our ability to provide you with the opportunity to participate in competitions or prize draws.
Further details
In order to enter you in to the frequent flyer program we will need to process personal information such as your name, address, contact details, employee ID (if relevant), passport details, credit card number, frequent flyer details, Etihad Guest number, PNR number, ticket number, any identifiers relating to your profession (if relevant).
Legal basis for using personal information
To enter into a contract with you for the frequent flyer program.
Further details
In order to handle complaints made by you, we will need to process your personal information such as your name, date of birth, address, contact details, bank account details, passport details, frequent flyer details, PNR number and ticket number, and may include special categories of data such as data concerning health where relevant to your complaint.
Legal basis for using personal information
Legitimate Interests.
It is in our legitimate interests to ensure that we handle your complaints in an efficient manner, without undue delay and complication. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data.
If you are a data subject protected by the GDPR or RS Personal data protection law you have rights to restrict or object to this processing, however please note that this may adversely affect our ability to provide you with effective complaints handling.
Further details
In order to comply with a legal or regulatory obligation, including providing specific information to law enforcement or similar bodies upon request we will need to process your personal information such as your name, date of birth, address, passport details, frequent flyer details.
Legal basis for using personal information
Processing is necessary for compliance with a legal obligation to which we are subject.
Further details
In order for us to comply with a request by law enforcement or similar bodies to share information with them we may need to process your personal information such as your name, date of birth, address, passport details, frequent flyer details.
Legal basis for using personal information
Legitimate Interests
It is in our legitimate interests to be able to share information with law enforcement or similar bodies from time to time, subject to their legitimate requests. We will need to be able to process this information in order for us to comply with legitimate requests, including in cases where we determine that we are not compelled to by applicable laws.
Prior to sharing that information we will ensure that by properly exercising our right to act in our legitimate interest to share the requested data we will not be overriding your interests or fundamental rights and freedoms which require protection of your personal data.
Further details
In order for us to defend the claim brought by you or a third party, we may need to process your personal information such as your name, address, data of birth, passport details and frequent flyer details. We may also need to process your special categories of data such as your racial or ethnic origin, political, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation.
Legal basis for using personal information
Legitimate Interests
It is in our legitimate interests to be able to commence or defend legal claims as and when we consider it necessary for the protection of our business. We will need to be able to process this information in order for us to instruct our legal counsel and fully defend ourselves against the claim you may bring.
It is unlikely that by us properly exercising our rights to commence or defend claims we will override your interests or fundamental rights and freedoms which require protection of your personal data.
Further details
In the event that Air SERBIA wishes to commence a claim against you, we may need to process your personal information such as your name, address, data of birth, passport details and frequent flyer details. We may also need to process your special categories of data such as your racial or ethnic origin, political, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation.
Legal basis for using personal information
Legitimate Interests
It is in our legitimate interests to be able to commence or defend legal claims as and when we consider it necessary for the protection of our business. We will need to be able to process this information in order for us to instruct our legal counsel and fully defend ourselves against the claim you may bring.
It is unlikely that by us properly exercising our rights to commence or defend claims we will override your interests or fundamental rights and freedoms which require protection of your personal data.
*In case you are using our services and buying a ticket on the territory of the People’s Republic of China, please note that data such as bank account details, credit card details, health or medical history data, race or ethnicity, religion and biometrics will be processed based on consent given in the Payment section during ticket purchase, and only for the purpose listed above and marked by *.
How we share information with others
- We work closely with a number of trusted partners with whom we need to share information to help us provide our services: our subsidiaries:
- Air SERBIA GROUND SERVICES BEOGRAD, seated in Republic of Serbia, Aerodrom Nikola Tesla Beograd,
- AIR SERBIA CATERING BEOGRAD, in Republic of Serbia, Aerodrom Nikola Tesla Beograd and our outstations
- Partner airlines where you are traveling on a booking which involves a codeshare;
- Frequent flyer and other reward and partner programs where required to enable you to earn or utilize frequent flyer miles by virtue of your membership of Etihad Guest;
- Banks and payment providers, to authorize and complete payments;
- Other third parties who help manage our business and deliver services. For example, these may include IT service providers who help manage our IT and back office systems, or third party booking agents;
- With customs and / or immigration departments or other regulatory authorities or government entities, to comply with legal obligations and ensure the safety of all our passengers and customers; and
From time to time we may share information about you with government organizations and agencies, and international organizations, to comply with applicable laws, regulations and rules, and legitimate requests from law enforcement, regulatory and other governmental or international agencies, or when to do so is in our legitimate interests, even if we are not compelled to share that information by applicable law. Further information about when we do this can be found above.
If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose or transfer information to a potential or actual third party purchaser of our business or assets.
More about direct marketing, profiling and automated decision making
Direct marketing
We are committed to keeping you informed about our products and services in line with your personal preferences or sending you reminders of your unfinished bookings. We will always ask your permission before sending marketing material, whether about our services or those of our preferred partners.
We will usually send this by email but we may choose to contact you in other ways for example by phone, post, SMS and/or other electronic means if that is more appropriate. You can ask us to stop sending you marketing material at any time by contacting us.
Managing your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
- You can also click the "unsubscribe" link that you will find on any online newsletters, which you receive, or contact our customer support team by email;
- You can change the way your browser or device manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below.
We recommend you routinely review the privacy statements and preference settings that are available to you on any social media platforms.
More about profiling and analytics
We may use some of the information you provide to analytics and us in order to perform profiling with the data. We will do this either with your consent or where it is in our legitimate interests.
One of the methods by which we do this is by installing and using Cookies on your browser or device. You can learn more about how to adjust settings relating to Cookies on your browser and device, and about our Cookie Policy in the section titled Cookies and Mobile, below.
Some of the legitimate purposes we profile and analyze data include:
- to allow us to enhance our provision of services to you;
- to provide you with tailored content online and optimize your experience of our websites;
- to offer personalized products when you fly with us or use our other services;
- to obtain a better understanding of our customers, what you would like to see from us, and how we can improve our services for you;
- to share advertising material we believe may be of interest to you, including from our third party partners;
- to help us operate our services more efficiently, including to ensure that our most loyal customers obtain the best services.
If you are an individual with rights under the Personal Information Protection Law of People’s Republic of China (“PIPL”), where a decision may have a significant impact on your rights and interests is made through automated decision making, you shall the right to request clarification from us and the right to refuse us for making decision only through automated decision making.
If you are a Data Subject with rights under the GDPR then we will take steps to ensure that prior to profiling your information for a legitimate interest that that interest is not overridden by your own interests or fundamental rights and freedoms. If you are a Data Subject with rights under the GDPR you may have rights to object to us profiling your personal information.
Transferring personal information globally
We operate our business on a global basis. The countries to which we commonly disclose your personal information include the Republic of Serbia, and the countries where you are flying to and from. Some of these countries, for example, the UAE and the USA, have laws which do not offer, in the opinion of the European Commission or other supervisory authorities, an adequate level of data protection.
In case you are natural person using our services within the territory of the People’s Republic of China, in order to meet requirements of applicable regulations, we will need your consent for transferring your personal information globally.
We will always strive to adopt the highest standards of privacy protection, wherever your personal information is located and adopt appropriate measures (consistent with locally applicable laws) to secure an adequate level of privacy protection. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. Transfers will be limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:
- we ensure transfers within Air SERBIA subsidiaries and outstations will be covered by an agreement (called an "intra-group agreement") which contractually obliges each Air SERBIA subsidiary to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred;
- where we transfer your personal information to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information; or
- where we receive requests for information from government entities, international organizations or regulators, we carefully validate these requests to ensure that it is legally appropriate to share the requested personal information.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above. See also the section titled "Your Rights", below.
How we protect and store your information
How we protect your information
We invest an appropriate level of resources to protect the security and confidentiality of personal information.
We offer the use of secure communication transmission software (known as "secure sockets layer" or "SSL") that encrypts all information you input to our website before it is sent to us. SSL is an industry standard encryption protocol and this ensures that the information is reasonably protected against unauthorized interception;
We also follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorized access to that information; and
We take all reasonable and appropriate steps to protect your personal information but cannot guarantee the security of any data you disclose to us via email or online.
Where you disclose information to us using our mobile app, please ensure that your device remains safe. We cannot be held responsible for any data misuse arising from unauthorized access to your device.
Storing your personal information
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this statement. Where your information is no longer required, we will ensure it is disposed of in a safe manner. In some circumstances we may need to store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. Should you require information about how we retain particular information you can contact us.
In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Our policy on "Cookies"
A cookie is an element of data that a website sends to your browser, which then stores it on your system. Cookies may collect personal information about you. Cookies allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our website. Cookies also allow us to make Air SERBIA Website more user-friendly by, for example, allowing us to take you to the language site of last use, so that we can give you a better experience when you return to our website.
A cookie will be deployed on your device when you visit Air SERBIAunless you indicate that you do not wish this to happen or if you have turned this feature 'off' in your web browser or device settings.
For more information about how our cookies work and information about how to manage your cookie settings please visit our Cookie Policy.