Privacy Policy

 

Flybe is committed to respecting your privacy and will protect your Personal Information

 

KEY SUMMARY

We collect, process and store your Personal Information:

  • if you visit our website or use our app;
  • if you submit your Personal Information on our website or our app;
  • if you book a flight or service with us through a third party;
  • in connection with a flight or service you have purchased from us; or
  • if you call, email or write to us.

Some of the flights and services that we offer are provided by third parties and, if you purchase those flights or services, that third party will process Personal Information about you.

We share your Personal Information with third party service providers and another airline operator (in the circumstances described below) that act on our behalf to provide flights and/or services to us.  Examples are companies that provide ground handling services at airports, IT services companies that manage reservations and boarding on our behalf and payment processing organisations.

We use cookies, which are text files containing small amounts of information that are downloaded to your computer or mobile device.  To find out more click here: Cookie Policy

This Privacy Policy explains what Personal Information we process, why we process it, how it is legal and your rights.

 

1.    INTRODUCTION

We are Flybe Limited (having company number 02769768) of New Walker Hangar Exeter International Airport, Clyst Honiton, Exeter EX5 2BA.

We are a Controller under Data Protection Law and take your privacy seriously. We ask that you read this Privacy Policy very carefully because it contains important information about how we process your Personal Information and your rights.

If you would like this notice in another format (for example, audio, large print, braille) please contact our Data Protection Officer using the contact details provided below.

 

2.    WHAT IS THE PURPOSE OF THE PRIVACY POLICY?

This Privacy Policy sets out the basis on which any Personal Information we collect from you, or that is provided to us by a third party, will be processed by us.

 

3.    OUR DATA PROTECTION OFFICER

We have appointed a Data Protection Officer who is responsible for overseeing any questions you may have in relation to this Privacy Policy.

If you have any questions about this Privacy Policy or Personal Information that we hold about you, including any requests to exercise your rights, please contact our Data Protection Officer using the details set out below:

 

Controller

Flybe Limited

Address

New Jack Walker Hangar

Exeter International Airport

Clyst Honiton

Exeter, EX5 2BA

Data Protection Officer

Peter Atkinson

Email

[email protected]

Telephone Number

01392 364520

 

In addition, you have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

 

4.    CHANGES TO THIS PRIVACY POLICY

This version of the Privacy Policy was last updated on 21 May 2018 and historic versions can be obtained by contacting our Data Protection Officer using the contact details provided above.

This Privacy Policy may be updated from time to time.  If the change impacts you or your Personal Information, we will inform you of changes made to this Privacy Policy.

 

5.    THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

We collect or store Personal Information (and Special Categories of Personal Information) about you at different points in our relationship with you:

  • when you browse or visit our website or use our app;
  • if you create an account with us;
  • if you subscribe to any of our publications;
  • if you enter a competition or provide feedback;
  • if you book a flight or buy a service from or through us; and
  • if you e-mail, write or call us.

If you book a flight with or purchase a service offered by us through a third party (for example an online travel agent or holiday company), then that third party will send us Personal Information about you that we will use to provide the flight or service.

 

5.1    PERSONAL INFORMATION

We collect the following Personal Information:

Type of Personal Information

Personal Information includes:

Advanced Passenger Information
  • full name
  • nationality
  • date of birth
  • gender (where required)
  • number and type of travel document (e.g. passport or ID), its expiry date and country of issue

Contact Data
  • billing address
  • delivery address
  • email address
  • telephone numbers

Financial Data
  • bank account
  • payment card details

Identity Data
  • first name
  • maiden name
  • last name
  • username or similar identifier
  • marital status
  • title
  • date of birth
  • gender
  • passenger name record (or PNR)

Marketing and Communications Data
  • your preferences in receiving marketing from us and our third parties
  • your communication preferences

Profile Data
  • username and password
  • purchases or orders made by you
  • interests
  • preferences
  • feedback
  • survey responses

Technical Data
  • internet protocol (IP) address
  • login data
  • browser type and version
  • time zone setting and location
  • browser plug-in types and versions
  • operating system and platform
  • other technology on the devices you use to access our website or our app

Transaction Data
  • details about payments to and from you
  • details of flights and services you have purchased from us

Usage Data
  • information about how you use our website, app, flights and services

 

 

5.2    SPECIAL CATEGORIES OF PERSONAL INFORMATION

In addition to the above Personal Information, we also process the following types of Special Categories of Personal Information:

  • health and disability information, which you provide to us when requesting any form passenger assistance and records of illnesses or treatments received during a flight with us; and
  • racial or ethnic origin (i.e. nationality), which you provide to us when completing your booking or providing the Advanced Passenger Information.

 

5.3    PERSONAL INFORMATION OF YOUR PARTY

If you are travelling as a party, you will need to provide the above Personal Information (and in some cases Special Categories of Personal Information) in relation to the party members and you must have their consent to provide us with such Personal Information.

 

5.4    OUR PROCESSORS

As part of your booking, we may provide Personal Information about you to the following third parties, who will process your Personal Information as our processor:

 

Processor

Description

Data Location

Type of Personal Information

Processor's privacy policy

Adyen B.V.

Simon Carmiggeltstraat 6-50

1011 DJ

Amsterdam

The Netherlands

 

Payment processing

Inside EU (UK)
  • Contact Data
  • Financial Data
  • Transaction Data

Link to Adyen privacy policy

Lloyds Bank PLC trading as Cardnet

Phoenix House

Christopher Martin Road

Basildon

Essex

SS14 3EZ

 

Payment processing

Inside EU (UK)
  • Contact Data
  • Financial Data
  • Transaction Data

Link to Lloyds privacy policy

PayPal (Europe) S.à r.l. et Cie, S.C.A.

22-24 Boulevard Royal

L-2449 Luxembourg

Luxembourg (G-D)

 

Payment Processing

Inside EU (UK)
  • Contact Data
  • Financial Data
  • Transaction Data

Link to PayPal UK privacy policy

AIB Group (UK) PLC

92 Ann Street

Belfast

BT1 3HH

 

Payment Processing

Inside EU (UK)
  • Contact Data
  • Financial Data
  • Transaction Data

Link to AIB privacy policy

Optima Value Group Ltd (T/A Optima Connect)

3 Distillery Lane, Edinburgh, EH11 2B		 Marketing Partner Inside EU (UK)
  • Contact Data
  • Transaction Data
  

From time to time, it may be necessary for us to contract with another airline operator to provide the flight for you.  In this case, we will provide your Personal Information to such other airline operator solely for the purpose of providing the flight to you.

 

6.    HOW WE USE YOUR PERSONAL DATA

We are required to tell you what we use your Personal Information for and the lawful basis on which we can process your Personal Information:

 

Purpose

Type of Personal Information

Lawful basis for processing

Details

To monitor browsing on our website or use our app

 
  • Technical Data
  • Legitimate interest
  • Consent

To improve the functionality and content of our website or our app.

 

For more information please see our Cookie Policy.

 

To create an account with us

 
  • Identity Data
  • Contact Data
  • Legitimate interest

To collect information about our potential customers.  We will not send you any electronic marketing unless you have expressly consented to receive it.

 

To improve the speed at which you can purchase flights and services from us.

 

To process and complete your booking (boarding passes and coupons)

 
  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Marketing and Communications Data
  • Performance of our contract with you
  • Legitimate interest

To collect payments from you and deliver boarding passes and/or coupons to you.

 

If we have a claim against you (for example, if you have broken your contract with us) it is in our legitimate interest to pursue that claim.

 

To process your request for any form of passenger assistance

 
  • Special Category of Personal Information
  • Performance of our contract with you
  • Consent

To enable us to meet your specific requirements for passenger assistance, both in departing and arriving airport.

To enable you to participate in a prize draw or competition

 
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Performance of the prize draw or competition  terms and conditions
  • Legitimate interests
  • Consent

To promote our business through prize draws and competitions to you.  We will not send you any electronic marketing unless you have expressly consented to receive it.

 

To enable you to complete a survey

 
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Legitimate interests

To obtain feedback from you on our flights and services so that we can make improvements to them.

 

To manage and protect our business and our website or app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 
  • Identity Data
  • Contact Data
  • Technical Data
  • Legitimate interests
  • Necessary to comply with a legal obligation

To manage our business and ensure the effective provision of administration and IT services, network security.

 

To prevent fraud.

To process information about other passengers in your booking and the age range of any children traveling with you

 
  • Identity Data
  • Contact Data
  • Performance of a contract with you

To process and complete the booking for you and each member of your party

To collect and process Advance Passenger Information

 
  • Identity Data
  • Contact Data
  • Legal obligation
  • Performance of a contract with you

To provide the authorities in the destinations that we fly to with the relevant passport and travel information.

 

To use data analytics to improve our website or app, flights and services, marketing (including advertisements), customer relationships and experiences

 
  • Technical Data
  • Usage Data
  • Legitimate interests

To define types of customers for our flights and services.

 

To keep our website or app updated and relevant.

 

To develop our business and inform our marketing strategy.

 
To send operational and service communications
  •  Identity Data
  • Contact data 
  • Performance of our contract with you
  • Legitimate interest

To contact by email or SMS for administrative or operational reasons related to your booking including: (i) booking confirmation; (ii) travel itinerary updates; (iii) notification when check-in is open; (iii) pre-trip update emails allowing you to manage your booking (which includes the ability to book seats and bags and other voluntary changes); and (iv) disruption alerts or events that may affect your flight.

NOTE: These communications are not made for marketing purposes and therefore you will continue to receive them even if you opt out of receiving marketing communications.

To send marketing and promotional materials to you

 
  • Identity Data
  • Contract Data
  • Consent

To promote our flights and services to you.

We may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information.  Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table above.

Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with flights or services or issue tickets).  In this case, we may have to cancel your ticket or not provide the service to you, but we will notify you if this is the case at the time.

 

7.    WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

 

7.1    OTHER AUTHORITES

In addition to the Advanced Passenger Information, we may disclose Personal Information to customs and immigration authorities, border control agencies and law enforcement bodies when this is necessary to get you to your destination or is required by law.  For example, for specific travel routes we are required to provide border control agencies with information that relates to your travel and itinerary.

We may also disclose your Personal Information to the Civil Aviation Authority (CAA) or other aviation authorities, for the purposes of ensuring compliance with and the enforcement of the Air Travel Organisations Licence (ATOL) or similar regulations.

 

7.2    OUR GROUP COMPANIES AND FRANCHISES

We will share your Personal Information with:

(a)  members of the Flybe group, which include:

  • Flybe Aviation Services Limited; and
  • Flybe Group plc;

(b)  Flybe franchises that operate flights for and on behalf of us.  These include:

  • Blue Islands Limited (trading as Blue Islands);
  • Eastern Airways (UK) Limited and Air Kilroe Limited (trading as Eastern Airways); and
  • Stobart Air Unlimited Company (trading as Stobart Air).

 

7.3    OUR SERVICE PROVIDERS

We will share your Personal Information with the following companies that provide services to us and act as our Processors:

 

Processor

Description

Data location

ADVAM (Inventive IT Limited)

National Car Parks Limited

Car parking bookings and payments

Inside EU (UK)

Amadeus IT Group S.A.

Passenger services systems

Inside EU and Outside EU

Ground Handlers (See Glossary)

Ground handling services

See Glossary

SITEL UK Limited and its Group companies

Customer services

Outside EU (RS)

SITA Information Networking Computing USA Inc.

(‘’SITA’’) trading as World Tracer

World Tracer: Baggage handling and repatriation

Outside EU (US)

We require all our Processors to respect the security of your Personal Information and to treat it in accordance with the law.

We do not allow our Processors to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

 

7.4    CODE SHARE AIRLINES AND THIRD PARTY SERVICE PROVIDERS

If you booked a flight with us and the flight is provided by one or more airlines (for example, a Code Share Airline (please see Glossary) or another airline operator (in the circumstances described above), then those other airlines will also be Controllers and you should review their privacy information on their websites.

If you purchase any of the following services that we offer, then the relevant third party service provider will be a Controller for the purposes of Data Protection Law.  You can access the privacy policies of those third party service providers from them directly.

 

Third party

Service

Data Location

Privacy policy link

AIG Europe Limited

Insurance

Inside EU (UK)

Link to AIG privacy policy

Booking Holdings

Hotel bookings

Inside EU (UK)

Link to Booking.com privacy policy

AVIS Budget EMEA Limited

Car hire

Inside EU (UK)

Link to AVIS privacy policy

AVIS Budget EMEA Limited

Car hire

Inside EU (UK)

Link to Budget privacy policy

Avios Group (AGL) Limited

Travel rewards programme

Inside EU (UK)

Link to AVIOS privacy policy

Creation Financial Services Limited

Flybe branded credit card

Inside EU (UK)

Link to Creation privacy policy

 

 

8.    MARKETING

We provide you with choices about marketing and advertising that you receive from us and third party Tourism Marketing Partners.

We have established a Preference Centre where you can view and make certain decisions about how we use your Personal Information.

A welcome email will be sent to you once you have opted in to receive marketing from us.

Within the Preference Centre you can select your marketing preferences.  If you do not wish to receive marketing information from us you can opt-out by sending an email to [email protected].

We will get your explicit consent before we share your Personal Information with any company outside the Flybe group of companies or franchises described in Section 7.2 above for marketing purposes.

 

9.    PROFILING

We may use the Personal Information (including Technical Data) that we collect about you to create a profile about you in order to suggest flights, services and offers that may interest you. 

We will only send this to you by electronic means if you have explicitly consented to receive such information in our Preference Centre.

Please use the Preference Centre to manage your preferences.

 

10.    INTERNATIONAL TRANSFERS

Some of our Code Share Partners or another airline operator (in the circumstances described above) are based outside the European Economic Area (EEA).

Where this is the case, your Personal Information will be processed in accordance with the applicable carrier’s privacy policy and, if your booking is made via a reservation system provider (Global Distribution System (GDS)), with its privacy policy.  These are available at http://www.iatatravelcenter.com/privacy or from the applicable carrier or GDS provider directly.  You should read this documentation, which applies to your booking and specifies, for example, how your Personal Information is collected, stored, used, disclosed and transferred.

Whenever we transfer your Personal Information outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.  For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.  For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the 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.

The Glossary also lists those third parties.  Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.

 

11.    DATA SECURITY

We use technical and organisational measures to safeguard your Personal Information, for example, we process all payment card transactions in accordance with the Payment Card Industry Data Security Standard and use secure connections on our website and our app to ensure that your Personal Information is encrypted.  In terms of the latter, this means that we convert your Personal Information into a computer code, which will make it harder for hackers to access your Personal Information on our website or our app. If you want to know how we are keeping your data secure, please contact our Data Protection Officer who can provide more details.

While we will use all reasonable efforts to safeguard your Personal Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Information that are transferred from you or to you via the internet.  If you have any particular concerns about your Personal Information, please contact our Data Protection Officer using the contact details provided below.

 

12.    DATA RETENTION

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Information are available from us on request to our Data Protection Officer.  We shall keep your Personal Information relating to Advanced Passenger Information for a period 10 years from the date when you first provided us with a copy of such Personal Information.

 

13.    YOUR LEGAL RIGHTS

You have rights, as a Data Subject, under the Data Protection Law in relation to your Personal Information.  You have the right to:

 

(a)  Request access to your Personal Information

(b)  Request correction of your Personal Information

(c)  Request erasure of your Personal Information

(d)  Object to processing of your Personal Information

(e)  Request restriction of processing your Personal Information

(f)    Request transfer of your Personal Information

(g)  Right to withdraw consent

 

These rights are explained in more detail below.  If you wish to exercise any of the rights set out above, please contact our Data Protection Officer using the contact details provided above.  We will respond to any rights that you want to exercise within a month of receiving your request, unless your request is complex, in which case we will respond within 3 months.

 

Your right

Description

Request access to your Personal Information

This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

 

Request correction of the Personal Information that we hold about you

You can require us to correct any mistakes in your information which we hold free of charge.

 

If you would like to do this, please let us have enough information to identify you (e.g. account number, user name, registration details) and let us know the information that is incorrect and what it should be replaced with.

 

Request erasure of your Personal Information

This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it.

 

You can ask us to erase your Personal Information where:

  • you do not believe that we need your Personal Information in order to process it for the purposes set out in this Privacy Policy;
  • if you had given us consent to process your Personal Information, you withdraw that consent and we cannot otherwise legally process your Personal Information;
  • you object to our processing and we do not have any legitimate interests that mean we can continue to process your Personal Information; or
  • your Personal Information has been processed unlawfully or have not been erased when it should have been.

Object to processing of your Personal Information

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.

You also have the right to object where we are processing your Personal Information for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your Personal Information.

This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:

  • if you want us to establish the Personal Information’s accuracy;
  • where our use of the Personal Information is unlawful but you do not want us to erase it;
  • where you need us to hold the Personal Information even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your Personal Information but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your Personal Information to you or to a third party.

We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format.

This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Information.

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 flights or services to you.  We will advise you if this is the case at the time you withdraw your consent.

Please be aware that there are exceptions and exemptions that apply to some of the rights, which we will apply in accordance with Data Protection Law.

 

 

GLOSSARY

 

Term

Definition

Advance Passenger Information

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Code Share Airline

means aviation business arrangement with an airline listed below in which two or more airlines share the same flight.  Each airline publishes and markets the flight under its own airline designator and flight number as part of its published timetable or schedule.  A seat can be purchased on each airline's designator and flight number, but is operated by only one of these cooperating airlines, commonly called the "operating carrier" or more precisely (and in line with definitions in IATA Standard Schedules Information Manual): "administrating carrier";

 

Contact Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Controller

shall have the meaning given to it in the Data Protection Law;

 

Data Protection Law

means the regulations on the protection of natural persons with regard to the processing of personal data and on the free movement of such data known as the General Data Protection Regulation ((EU) 2016/679) and any national legislation implementing this Regulation and related statutory instruments as amended or in force from time to time;

 

Data Protection Officer

means the person whose details are set out in Section 3 of the Privacy Policy,

 

Data Subject

shall have the meaning given to it in the Data Protection Law;

 

Financial Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Global Distribution System or GDS

means a computerised network system owned or operated by a company that enables transactions between travel industry service providers, mainly airlines and travel agencies. A mirror image of the passenger name record (PNR) in the airline reservations system is maintained in the GDS system.  If you book an itinerary containing air segments of multiple airlines through a travel agency, the your passenger name record in the GDS system would hold information on their entire itinerary, each airline you fly with would only have a portion of the itinerary that is relevant to them;

 

Ground Handler

means a third party ground handler listed below that we work with at an airport to deal with aircraft for our flights between the time it arrives at a terminal gate and the time it departs on its next flight,

 

Identity Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Marketing and Communications Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Personal Information

means "Personal Data" as defined in the Data Protection Law;

 

Preference Centre

means our preference centre details of which are emailed to you when you have consented to receive email marketing from us in the first instance;

 

Processor

shall have the meaning given to it in the Data Protection Law;

 

Profile Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Special Categories of Personal Information

shall mean the special categories of Personal Data as set out in the Data Protection Law;

 

Technical Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Tourism Marketing Partner

means a third party marketing partner listed below that we work with to provide information to you that will be of interest when you fly from or to a particular destination;

 

Transaction Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

Usage Data

means the Personal Information described as such in Section 5.1 of the Privacy Policy;

 

we, us and our

means Flybe Limited; and

 

you, your

means the person browsing our website, creating an account with us, booking a flight or purchasing a service from us.

 

 

Code Share Airlines:

Code Share Airline

Privacy policy link

Aer Lingus

Link

Air France

Link

Air India

Link

Alitalia

Link

British Airways

Link

Cathay Pacific

Link

Emirates

Link

Etihad

Link

Finnair

Link

Singapore Airlines

Link

Virgin Atlantic

Link

Note: All Code Share Airlines will operate and have a reservation system that allows airlines to book other Code Share Airline flights.  This is known as a Global Distribution System.

 

Ground Handlers:

Acciona

AHS

Air France

Air Ouest

Aurigny

Aviapartner

Aviapartner

Dalcross

GH Verona

Groundforce

LuxAir

Menzies

Portway Handling

Sky Handling

Swissport

This is Doncaster

 

Tourism Marketing Partners:

Tourism Marketing Partners

Website

Atout France

Link

Bergerac Tourism

Link

Birmingham Marketing

Link

Brittany Tourism

Link

Devon’s Top Attractions

Link

Edinburgh’s Christmas Markets

Link

Visit Manchester

Link

Marketing Manchester

Link

Titanic Belfast

Link

Tourism Ireland

Link

Tourism South East

Link

Visit Aberdeenshire

Link

Visit Belfast

Link

Visit Britain

Link

Visit Devon

Link

Visit Doncaster

Link

Visit England

Link

Visit Guernsey

Link

Visit Holland

Link

Visit Jersey

Link

Visit Scotland

Link

Visit Wales

Link

 

Note: No Personal Information is transferred between us and our Tourism Marketing Partners