Personal Data Protection Policy

This document constitutes the personal data protection policy (hereinafter the “Policy”) of Elite Airline. Based on our company’s desire for transparency, this policy has been drafted to be easily understandable and accessible and translate the commitments of Elite Airline under the European Regulation (EU) 2016/679 on personal data protection (hereinafter “RGPD/GDPR” or “GDPR”) as well as on the amended Kuwait Data Protection Act.

This personal data protection policy is intended for anyone who enters into a relationship with Elite Airline, which includes passengers who have purchased a travel ticket or anyone who has made a booking through our intermediary or by the intermediary of a third party (online travel agency or not, or tour operators, etc.) as well as anyone visiting our websites or using our mobile services and applications (hereinafter “User”). The Policy is accessible via various means, which are made available to natural persons by Elite Airline to enter into a relationship with the company (websites, applications, or mobile services, etc.).

This Policy is likely to evolve, so please consult it regularly.

As the organization of your flight with Elite Airline was able to be preceded by contacts with facilitators who collected and processed data, especially if you have made a booking through a travel agency, a third-party website, or a tour operator, please contact them directly to find out about their personal data processing policy or direct any requests concerning the processing of your personal data to them.

Any questions concerning the Data Protection Policy of Elite Airline can be submitted using the heading Contact: accessibility@eliteair.com.kw

Article 1 - Personal Data Collection and Processing

Personal data are collected and processed by Elite Airline in accordance with RGPD/GDPR principles and requirements.

Thus, we collect and process data, documents, and information in order to fulfill lawful, explicit, and legitimate objectives and purposes, according to loyal processes in the context of managing the customer relationship and making contact, with a view to providing transport services and additional services, in compliance with the rules applicable to our specific business activity.

Therefore, as part of the processing we perform:

• We make sure we indicate whether the requirement for the provision of personal data by you is of a regulatory nature or a contractual nature or if this provision affects the conclusion of a contract;
• We make sure we indicate whether the person concerned is required to provide such personal data or if it is optional and we inform you of any consequences that there may be for the person concerned by not providing these data;
• When this is the case, we make sure we indicate the existence of automated decision-making including profiling. To this end, we provide you in such a case on the one hand, with useful information concerning the reasoning underlying this computerised decision and on the other hand, we provide information as to its importance and expected consequences of this potential processing for the person concerned;
• When this is the case, we make sure we indicate our intention to the person concerned to carry out further processing of personal data for purposes other than that for which the personal data were originally collected. We therefore provide prior information about the other purpose and any other information allowing its comprehension in a transparent way;
• We communicate restricted data concerning our customers and contacts only to authorised recipients. These may be competent departments of Elite Airline as well as experts, subcontractors, and partners involved in the provision of the services, as well as the airport authorities or the public authorities empowered to receive communication of personal data in the framework of applicable law;
• We undertake to ensure the transparency of data processing and collection by providing people with adequate information in all cases of the collection or receipt of data, when the data are transmitted directly by the persons or are transmitted to us by third parties or when they are collected using technology;
• We undertake to:
  • Minimize processing,
  • Ensure the regular updating of data,
  • Proceed to a proportionate retention of data according to criteria determined in particular in the light of the purpose of the processing, contractual or operational requirements or to meet our regulatory obligations according to applicable law,
  • Take into account the rules governing commercial solicitations by email and telephone,
  • Oversee relations with partners and subcontractors by all means to ensure our legal obligations are complied with,
  • In the case of the transfer of data destined for a country located outside of the European Union, to take all possible measures, in accordance with RGPD/GDPR requirements, ensuring compliance with the applicable regulations in Europe. In fact, Elite Airline uses providers providing services including from or in countries outside of the territory of the European Union,
  • Make our collaborators aware of the personal data protection and confidentiality requirement,
  • Ensure data and processing security,
  • Take into account all the rights recognized to natural persons under the applicable regulations.

Within Elite Airline, the principles and requirements of the right to the protection of personal data are accompanied by organisational and technical measures in order to concretely apply the provisions of GDPR. Elite Airline is available to provide any further information or clarifications on this subject.

Article 2 - Processing of Personal Data Based on Relationship with Elite Airline

A. In the context of information and communication

Elite Airline processes personal data for the purposes of external information or communication intended for anyone who wants to know more about our activities or be informed over time. This includes managing operations related to our event activities, managing newsletters, and the organisation of our activities on social networks.

B. In the context of managing bookings and implementing air transport contracts

Elite Airline processes personal data for the purposes of:

• Managing bookings for passengers, issuing travel tickets, implementing air transport contracts, and additional associated services (choice of seat, purchase of a specific meal tray, taking out insurance, downloading the services application provided by our partners allowing access to an on-board entertainment offer). We process data electronically for the purpose of enabling the conclusion of the Contract of Carriage and must have the identification data in order to record them in the Passenger Name Records (PNR) containing the information concerned (passenger identity, contact information, ticket price, trip route/s, and date/s). According to the regulations applicable to travel, Elite Airline must also collect the main information contained on the travel documents (for example: passport or identity card number, date and country of issuance, expiry date, passenger nationality). Some destination or overflight countries require the sending of additional data such as data contained in the Passenger Name Records (PNR) (these records contain information on the additional services contracted, the means of payment used, the trip itinerary, last names, first names, gender, date of birth, etc.). These data are transmitted to the relevant authorities for any flight to or from Kuwait territory. In addition, this information is likely to vary according to the State of departure and/or destination of the flight and possibly overflight and/or transit States. When it has not been previously requested, this information must be provided when passengers check in at the terminal or online. The data collected may also be transmitted to airlines who operate flights with an Elite Airline flight number.
• To collect sums that are due to Elite Airline or its partners, to combat payment fraud;
• To ensure the follow-up of your relationship with Elite Airline and its partners to provide a better service (such as your location in the terminal); in order to provide information in the case of a flight irregularity/ies, in order to collect the opinions of the people on the quality of our services to improve them, in order to manage claims, or to provide an after-sales service;
• To ensure communication with the relatives of passengers in the event of an emergency, to provide you with the necessary assistance due to your physical condition or still further in order to provide the necessary care in the event of a health problem on-board our flights;
• To fulfill our legal obligations with regard to the authorities of the departure, destination, transit, and overflight country necessary for the implementation of the Contract of Carriage.

C. In the context of managing and monitoring the customer relationship

Elite Airline processes personal data for the purposes of enabling you to manage your data within a dedicated account, accessible online, placed under your control with credentials that you must keep confidential.

Generally, in the context of managing and monitoring the relationship with our customers, personal data are processed by Elite Airline for the purposes of:

• Offering products and services similar to those that you have already contracted with the company or different services and products when you have consented to receive other commercial solicitations;
• Facilitating the subscription of the Contract of Carriage by air when making a booking or selecting additional services allowing you to go back to your order when interrupted while placing it;
• Communicating good deals to you corresponding to your requests, to take into account your participation in games-contest or promotional actions, as well as loyalty schemes;
• Ensuring the achievement of operations of administrative nature related to managing the commercial relationship, including accounting, compiling statistics, managing unpaid debts and amicable or legal disputes, managing security incidents, and managing rights relating to personal data.

D. In the context of the provision of web and mobile services and technologies

Elite Airline processes data in the context of implementing websites accessible at the address www.eliteair.com.kw as well as in the context of mobile sites or applications that can be downloaded from the Apple® Store and Android® Store (hereinafter the “Sites”). Data processing is mainly for the purpose of enabling Elite Airline to understand the uses of websites by its visitors and customers and offer customized use, allow access to the user’s personal account and offer on-board services of entertainment.

Cookies and trackers: When visiting the Sites, cookies or tracker technologies are likely to be put in place automatically within the User’s web browser software and be stored in the terminal used. There are traditionally three types of cookies: browser cookies, statistics/audience measurement cookies, and advertising cookies. Browser cookies allow services to be provided to users of Sites when placed there as well as.