Privacy Policy - General

At 4-Airways, safeguarding your privacy and protecting your personal information is a priority. This Privacy Policy ("Policy") outlines how we, 4-Airways LTD, a company registered in Malta under registration number C-106288 with our main offices located at 15, Level 1, Suite 4, Naxxar Road, Birkirkara BKR 9049, Malta, handle your personal data. When we refer to "4-Airways," "we," "us," or "our," we mean 4-Airways LTD. "You" or "your" refers to the individual providing us with personal data, and "personal data" holds the definition specified in Article 4 of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), effective from May 25, 2018.

All personal data collected is managed and utilized in line with this Policy, the Data Protection Act of Malta (Chapter 440 of the Laws of Malta), as amended and applicable ("DPA"), and the GDPR. 4-Airways LTD is deemed a data controller under the DPA and the GDPR.

Whenever we request your personal data, rest assured it will only be used in accordance with this Policy. This Policy governs the collection, usage, and processing of your personal data in connection with your interactions with us as a customer or prospective customer, whether you're traveling with us, using our services, accessing our websites or mobile applications, engaging with our agent services or call centers, or booking our services through third parties like agents and other operators. However, we're not liable for the handling of your personal data by third parties for their own purposes, and you should refer to their privacy policies for details.

This Policy became effective on May 20, 2024. We reserve the right to modify or amend this Policy at any time at our discretion. If changes are made to our Privacy Policy, we'll update the modification date below and request that you review and accept the revisions. Your continued use or access of our services or products, or your purchase of any of our services or products after any changes to this Policy, signifies your acceptance of those changes.

Please review this Policy carefully, as accessing, purchasing, or using any of our services or products indicates your consent to all the terms and practices outlined herein, including the collection, usage, processing, and disclosure of your personal data. If you disagree with any part of this Policy, please refrain from accessing, using, or purchasing any of our services or products.

If you have any questions or concerns regarding this Policy or its implementation, please feel free to contact us at info@4airways.com.

What types of personal data do we collect?

We collect personal data concerning you, your travel plans, your utilization of our services and products, and your interactions with our websites, call centers, and mobile applications. This collected personal data encompasses, but is not restricted to:

  • Your first and last name.
  • Contact details, such as residential address, email address, telephone number, and fax number.
  • Date of birth, nationality, and passport details when you make flight reservations with us.
  • Personal details and photographs (including passport and other identification documents) when you make flight reservations with us.
  • Personal preferences (e.g., food and beverage choices) and dietary needs.
  • Medical information (e.g., allergies for medical purposes and disabilities).
  • Details about your travel arrangements, including reservation specifics, travel schedules, additional assistance requirements, and other pertinent travel-related details.
  • Records of services previously provided to you, encompassing past travel arrangements like flights and other reservations, as well as associated matters like upgrades.
  • Data concerning your usage of our websites, call centers, and mobile applications, including page visitation information.
  • Details about your interactions with us and our personnel.
  • Information utilized to enhance our services, fulfill administrative obligations, and safeguard our business interests. This includes accounting, billing, and auditing, verification of credit or payment cards, fraud detection (including data received from external banks and credit rating institutions), security and legal purposes, statistical and marketing analysis, testing, system maintenance and development, and other relevant purposes.
  • Any other information that may be necessary to fulfill obligations resulting from contracts between you and us, and/or to conduct customer surveys and/or offers.

This personal data may encompass information you provide directly to us or through entities or agents we collaborate with, as well as data we gather when you utilize our services or products.

When and why do we collect "sensitive personal data"?

Certain types of personal information, such as data pertaining to race, ethnicity, religion, or health, are classified as "sensitive personal data" according to the DPA and the GDPR. Generally, we aim to limit the instances in which we process sensitive personal data. However, there may be occasions when this occurs due to the following reasons:

  • You have specifically requested medical assistance from us and/or an airport operator, such as wheelchair or oxygen aid.
  • You have sought our approval to fly with a medical condition or due to pregnancy.
  • Alternatively, you have voluntarily provided such information to us (or to a third party, such as the agent or broker through whom you made your booking).

Additionally, you may have made other requests concerning your travel arrangements that could potentially imply or suggest information about you that falls under the category of "sensitive personal data". For instance, if you request a particular type of special meal, this could imply or suggest specific religious beliefs or a particular medical condition.

By furnishing any personal data that is, or may be deemed, "sensitive personal data", you expressly consent to our collection, utilization, sharing with third parties, and transfer of this Personal Data outside the European Economic Area, as outlined in this Policy.

Should you retract your consent, it may impact our ability to furnish all or some of the products or services you have requested from us. Please be aware that under these circumstances, you will not be entitled to cancel or receive a refund for any fees you have already paid.

For what purposes do we utilize your personal data?

We process, manage, and transmit personal data to ensure optimal service provision, particularly for the following reasons:

  • We utilize personal data to fulfill your requests and facilitate your flight should you choose to travel with us. This involves sharing your personal data with relevant authorities, such as passport control and border agencies, and, if necessary, with pertinent law enforcement and customs agencies. Additionally, we may need to contact you for clarification on your application.
  • Addressing general inquiries you may have regarding our services.
  • Ensuring that you or any passenger are not subject to or targeted by any economic or commercial sanctions or travel bans stipulated by law or regulation.
  • Accounting, billing, immigration and customs procedures, health and safety measures, security protocols, and legal compliance.
  • Fulfilling obligations and enforcing rights stemming from any contractual agreements between you and us.
  • Internal record-keeping and administrative tasks.
  • Safeguarding your personal data that we hold and/or process for security purposes.
  • Training our employees to provide our services and products effectively.
  • Conducting statistical analyses to enhance our products and services.
  • Enhancing our marketing efforts, where you have consented to receive information about us, our services, products, and offers.
  • Periodically using your personal data to request feedback on our services and those of third-party providers, aiding us in their enhancement and development.

Despite the aforementioned:

We utilize your personal data to fulfill your travel arrangements and provide the services you have requested. This may entail processing information about travel arrangements not directly provided by us but integral to your overall travel, such as airport arrangements and customs and immigration procedures.

Additionally, please note that at certain airports where we operate, facial recognition and related biometric technologies are employed to streamline passenger boarding processes.

We may also use your personal data to offer tailored services and provide you with a more personalized experience, including:

  • Sending relevant messages and information that we deem of interest to you before, during, and after your trip with us.
  • Customizing and personalizing your travel experience.

Furthermore, we may use and retain your personal data, including your purchase history, for administrative purposes, encompassing accounting, billing, auditing, payment verification, fraud detection, immigration and customs procedures, security measures, health and safety protocols, legal and administrative functions, and system testing, maintenance, and development.

With whom do we share your personal data?

Your personal data may be disclosed to a third party that acquires us or substantially all of our assets.

We may also share some of your personal data or obtain your personal data from the following categories of third parties:

  • Airports, government authorities, law enforcement agencies and regulators when necessary to get you to your destination or required by law. and regulators when necessary to get you to your destination or as required by law. For example, for specific travel routes, we are required by law to provide border control agencies with information regarding your travel documents and travel itinerary.
  • Travel agents or other companies through which you book your 4-Airways flights
  • Vendors who provide services to us to help us manage our business and improve our services and your customer experience. For example, we may share your personal information with companies that provide ground services to us at the airports where we operate. We may also disclose your information to our contact center or to companies that help us get your feedback on our services. At 4-Airways, we carefully select our suppliers who process your personal data on our behalf and require that they meet high security standards. for the protection of your personal data.
  • Credit and Debit Card Companies
    4-Airways shares some of your personal information, which includes information about your payment method and flight reservation, with the credit or debit card company that issued the card you used to make your reservation. To ensure the security of your transactions and to prevent or detect fraudulent transactions, we may also share your information with our fraud detection partner.
  • Our partners who offer travel-related products and services on our website, promote offers or co-host contests on our website.

From time to time, we make available certain offers from third parties through our website or publish contests co-organized by third parties. If you choose to purchase products or services offered on our websites by third parties (e.g., car rentals), accept offers or enter a contest, some of your personal information, such as your contact details and billing information, may be collected directly by or disclosed to that third party.

As such, if you purchase their products or services, our partners may collect or transfer your information to them. Please be sure to review the relevant privacy policies and terms of use of these partners before purchasing their goods or services, using their websites, applications or services, or providing them with any personal data.

In addition to the parties mentioned above, we may disclose your personal data when required to do so by the law of any jurisdiction to which 4-Airways may be subject.

4-Airways and other airlines are required by laws of various countries to provide border control agencies and other public authorities with access to booking and travel information and other personal data (including data obtained from official photo identification documents). Therefore, any information we have about you and your travel arrangements may be disclosed to customs, immigration and public authorities of any country in your itinerary.

In addition, the laws of several countries require 4-Airways and other airlines to collect passport and associated information from all passengers prior to travel to or from those countries. When necessary, 4-Airways will provide this information to the appropriate customs and immigration authorities.

When do we collect personal data about you?

We collect personal data about you when you use our services or products (whether provided directly by us or by another company or agent), when you travel with us, and when you use our website, call centers or mobile applications. The following are examples of when we collect personal data about you:

  • when you book or search for a flight or other products or services on our website or mobile applications;
  • when you book or search for a flight or other products or services through our other sales channels, such as through a travel agent
  • when communicating with our call centers or service agents or sales representatives
  • when you travel with us and use the airports where we operate
  • if you use the salon facilities provided by us or our agents
  • if you use our in-flight communication and entertainment services
  • if you complete a customer survey or provide us with feedback
  • if you participate in a contest or sign up for a promotion
  • if you choose to interact with us through social networks, such as Facebook.

In addition, we may receive personal data about you from third parties, such as:

  • companies contracted by us to provide you with services
  • Companies involved in your travel plans, including relevant airport operators and customs and immigration authorities.
  • Companies (e.g., car rental suppliers and hotels) that participate in our programs.
How we use cookies?

To improve our services, provide you with more relevant content and analyze how visitors use our website and application, we may use technologies such as cookies, pixels or tracking software. Please note that in most cases we will not be able to identify you from the information we collect using these technologies.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website to improve the experience of our website visitors. This software does not allow us to collect any personal data. In addition, to understand how our customers interact with the emails and content we send, we use pixels that allow us to know whether the emails we send are opened or whether the content of our emails is displayed in text or html format.

 

We also use cookies on our website, mobile application or in our emails. Cookies are small pieces of information that your browser stores on your computer's hard drive. They enable you to navigate our website or application and allow us to provide you with features such as remembering aspects of your last flight search to speed up subsequent searches. You can delete cookies if you wish; while certain cookies are necessary to view and navigate our website or application, most features will remain accessible without cookies.

For more information on how we use cookies and how you can delete them, you can read our Cookie Policy in a later section of this page.

When will we send you marketing communications?

You may receive marketing communications from us if you have opted to receive such material.

We may use third parties to send marketing communications on our behalf. If we ever want to allow a third party to send you direct marketing unrelated to 4-Airways, we will first ask your permission before sharing your data with them.

If you have previously agreed to our use of your information for direct marketing purposes, you may change your mind at any time by changing your preferences and opting out or by writing to us at info@4airways.com.

Security, storage and transfer

We are committed to ensuring that your personal data is secure at all times. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

All our employees and suppliers with access to your personal data and/or who are associated with the processing of such data are contractually obliged to respect the confidentiality of your personal data. For example, if you are a passenger on a flight operated by us, you can be assured that none of our crew will take a photo of you while you are on our aircraft and then upload the photo to social media, nor disclose it to anyone. person the fact that you are flying on our aircraft, nor disclose any confidential information about you that they may become aware of during your flight (in each case, unless disclosure is necessary for any reason set forth in this Policy).

Your personal data will be stored and processed by our systems and may also be stored and processed by systems of an external data processor designated by us. The personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area (" EEA "). It may also be processed by employees operating outside the EEA who work for us or for one of our suppliers. These employees may be engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy, the DPA and the GDPR (as applicable), all applicable European Union regulations and all applicable data protection laws. applicable to 4-Airways, and we will also ensure that there is a written agreement between us and each such company containing data protection obligations that are no less onerous than those set out in this Policy, the DPA and the GDPR, to ensure that your personal data is adequately protected.

We will retain your personal data for as long as we need it for the purpose for which it is processed. For example, when you book a flight with us, we will retain information relating to your booking so that we can fulfill the specific travel arrangements you have made and, thereafter, we will retain the information for a period to enable us to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive the loyalty rewards due to you.

We will actively review the information we hold and securely delete it, or in some cases anonymize it, when there is no longer a legal, business or customer need to retain it.

Transmission of information through the Internet

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.

Links to third party websites

Our websites, online services and mobile applications may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services.

You are advised to check these policies before submitting any personal data to these websites or using these services.

Telephone calls

We may monitor or record telephone conversations to enhance your and our safety, to enable us to handle complaints efficiently, to improve our customer service and for staff training purposes. If your telephone conversation with us will be recorded, you will receive a message to that effect before you begin your conversation with us.

Providing information about another person

If you provide us with personal data about another person, you confirm that you have appointed them to act on your behalf, to consent to the processing of their personal data, and that you have informed them of our identity, this Policy, and the purposes (as set out in this Policy) for which their personal data will be processed.

How to access, review, transfer and delete your personal data

We will make your personal information available for review pursuant to a simple request from you. If you tell us that personal data, we hold about you is incorrect or used inappropriately, we will correct, update or delete such personal data as appropriate. You also have other rights, such as the right to ask us to delete personal data or to request portability of personal data or restriction of processing, or to object to processing.

For information on how to access your personal data and exercise your rights, please contact us at: info@4airways.com.

 

Complaint, applicable law and jurisdiction

Any dispute arising out of or relating to the acceptance, interpretation or enforcement of this Policy shall be subject to the exclusive jurisdiction of the competent Court of Malta, which shall apply the laws of Malta; provided that:

  1. any dispute relating to 4-Airways shall be submitted to the exclusive jurisdiction of the competent Court of Malta, which shall apply the laws of Malta; and,
  2. If this Policy is incorporated by reference into a contract that has its own choice of law and jurisdiction, then any dispute arising out of or relating to the acceptance, interpretation or enforcement of this Policy shall be subject to the jurisdiction of and subject to the law applicable to that contract.

You also have the right to file a complaint with a supervisory authority.

More details

Further details of your rights can be accessed on the website of the Office of the Information and Data Protection Commissioner of Malta at: https://idpc.gov.mt

and on the European Commission's website at:

http://ec.europa.eu/justice/data-rotection/individuals/rights/index_en.htm