Article 1. General information about Pacific Airlines
Pacific Airlines Joint Stock Company (Pacific Airlines Joint Stock Aviation Company), is the first low-cost airline in Vietnam, based at Tan Son Nhat International Airport, Ho Chi Minh City, Vietnam. With the operating criterion of providing cheap air tickets every day, Pacific Airlines currently operates passenger and cargo services to domestic destinations of Vietnam and some international destinations by fleet modern Airbus.
Article 2. Pacific Airlines’ commitment regarding the protection of personal data
Pacific Airlines undertakes in particular to respect the following principles:
- Your personal data are processed lawfully, fairly, and transparently, in accordance with the applicable laws;
- Your personal data are collected for specific, explicit and legitimate purposes and are not further processed in way incompatible with these purposes, in accordance with the applicable laws;
- Your personal data are stored in an appropriate and relevant manner and are limited to what is necessary to the purposes for which they are processed, in accordance with the applicable laws;
- Your personal data are accurate, kept up to date and all reasonable steps are taken to ensure that inaccurate data, having regard to the purposes for which they are processed, are erased or rectified without delay, in accordance with the applicable laws;
- In accordance with the applicable laws, Pacific Airlines implements appropriate technical and organizational measures to ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
Furthermore, Pacific Airlines contractually imposes the same level of personal data protection on its subcontractors (service providers, suppliers, etc.).
In addition to aforementioned principles, Pacific Airlines undertakes to comply with all other principles required under the applicable regulations on the protection of personal data, and more specifically concerning the rights conferred on data subjects and the obligations relating to cross-border transfers of personal data.
Article 3. Items of personal data which may be collected and processed by Pacific Airlines
- General data
When using our services and in particular the services accessible on our website, our call center and sales agencies, Pacific Airlines may collect and process the following categories of personal information:
- Name, passport number and other identifying information: name, gender, date of birth, passport or other personally identifiable number (date of issuance, place of issuance), nationality, language;
- Your contact details and personal account or registration details: contact information, such as telephone number, mailing address, email address, fax number; home address, mobile number, private email address, hobbies, preferences and information related to Customer’s special needs;
- Your payment information: payment information of credit or debit card such as name of cardholder, card number, expiry date, verification code;
- Information about your reservations, bookings and purchases: reservation and booking information such as your flight, prices and the date of your reservation or booking;
- Information collected when you use our website, mobile applications and other digital media: personal information that is collected automatically when Customers using Pacific Airlines’ website and mobile applications such as IP information, cookies, website log;
- Our communication with you: communication, communication preferences (unsubscribe from newsletters, selection of information regarding reservations), registration of your questions, survey, research, complaints or phone calls;
- Information relating to social media: Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services by using a social network account, we may receive your social network profile including your contact details, interests and friend list.
- Sensitive data
Pacific Airlines may also collect certain information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs which can be considered as ”sensitive personal data” pursuant to the law of Vietnam and applicable regulations of other countries. Subject to your express consent, Pacific Airlines may collect, use and share your special categories of sensitive data with third parties for the purposes as described in Article 5 below with a view to providing you with assistance during your travel (medical needs and persons with reduced mobility).
- Cookies and similar technologies
When you use our website, Pacific Airlines may collect information via cookies and similar technologies. For more information, please read our Cookies Policy on our website.
Article 4. Methods of personal data collection
Pacific Airlines may collect the personal information or data set forth in Article 3 of this Private Policy through our website and sales offices, namely when you book a flight and communicate with us via social media, when you subscribe to our newsletter or when you register for electronic new letters, register to participate in Pacific Airlines’ events or promotional contests. Furthermore, your personal data may be obtained from our group companies, partners or other service providers when you request for our services (travel agents, third party platform providers, hotels, car rental companies, …) subject to your consent to provide Pacific Airlines with your personal information or from public authorities or governmental organizations.
Article 5. Purposes of personal data collection and processing
Personal information or data provided to us is primarily used to serve your interests and privileges when you enjoy travelling with us, purchasing or using our services, including accessing to our websites or contacting us. For this reason, the main purposes for which we collect and process your personal data are as follows:
- To perform our contractual obligations and enable an appropriate level of service to our customers
In order to handle and perform the contract of carriage and/or travel arrangement, Pacific Airlines will process the information including your name and surname, passport number and other identifying information for issuance of your ticket such as your contact details in order to inform you properly about changes of your flight status according to Article 3 of this Privte Policy.
Pacific Airlines offers you the possibility to indicate some sensitive information such as information about your specified medical needs or special meals provided on board. Collection and processing of these sensitive personal data will be subject to your express consent and will be exclusively used by Pacific Airlines in order to perform the contract of carriage and provide you with an appropriate level of customer care services.
- To ascertain a high level of security and safety on our flights
Pacific Airlines uses your personal information in order to protect safety of all passengers by namely (i) checking every passenger identity before they check-in, (ii) maintaining a list of the passengers who have not observed the safety rules, public orders or disciplines, either on board or on the ground, and for which Pacific Airlines will refuse the carriage or restrict it to specific conditions, (iii) sharing your identifying information and your booking and travel information with public authorities or governmental organizations for the purpose of border control, immigration, entering the territory of a State, security or combatting terrorism.
- Accounting and financial requirement
We collect, store and use your data for internal business purposes, such as to record keeping and to comply with our legal and fiscal obligations. These data will be kept for a period of 10 years pursuant to applicable laws.
- For customer care purposes
Your personal data are used by Pacific Airlines to provide you with customer care services enabling Pacific Airlines namely (i) to receive information, comments, suggestions, claims of Members to improve the service quality of Pacific Airlines, (ii) to contact and communicate with customers regarding their enquiries, (iii) perform statistical analysis in order to develop and improve Pacific Airlines services and offerings on the basis of personal information and customer’s requests and (iv) to provide more quickly responsive support to customers and improve the content and designs of Pacific Airlines’ website and mobile applications, (v) to realize surveys regarding the satisfaction of customers and for better understanding of customers’ needs subject to the express consent of customers, and (vi) handle potential complaints or claims of passengers.
- To communicate with you
We use your contact details to communicate with you with a view to performing our services contracted with you or loyalty programs, as well as to answer your questions or to handle your complaints.
- For direct marketing purposes
Pacific Airlines may use your personal information for purposes of direct marketing such as (i) to send you latest promotions and offers in connection with our products and services, (ii) to send you e-newsletters, magazines, promotions or other marketing communications, (iii) to analyse which information is relevantly suitable to you, (iv) to communicate with you for marketing campaign and strategy to serve Members’ best interests and preferences, (v) to send you personalized ads and special offers for aviation related products and related ancillary services through our booking comfirmation emails, (vi) send you latest offers from Pacific Airlines and our partners relating to our services and products.
We only send you direct marketing notifications as described in the first paragraph subject to your prior consent (opt-in).
You can always object to the use of your personal data for such direct marketing purposes, by clicking the unsubscribe link in the email or contacting us.
Article 6. Legal basis of the processing of your personal data
Pacific Airlines processes your personal data (i) on the basis of your explicit consent, (ii) to perform the contract of carriage or take steps at the request of the data subjects prior to entering into a contract, (iii) to exercise and comply with legal obligations according to applicable laws or (iv) to perform Pacific Airlines’ legitimate rights and interests.
Your consent may be always withdrawn at any time in accordance with Article 9 below. In such case, be aware that the withdrawal of your consent shall not affect the lawfulness of the previous processing based on your consent before the withdrawal. Furthermore, if you refuse to provide Pacific Airlines with some of personal data or if you provide Pacific Airlines with incomplete or inaccurate information required for the performance of the contract or for compliance with legal obligations, be aware that we may not be able to provide or deliver you all or parts of the services, which you may have requested from us in full quality.
Article 7. Period for Personal data retention
Pacific Airlines will retain your personal data collected on our internal system in the period of services provision or up to fulfilling the purposes for which it was collected or in so far as such data is necessary to the compliance with statutory obligations and to solve any dispute or until the information proivided are required to be deleted by you.
Article 8. Potential recipient of your personal data
- Potential recipient of your personal data
Pacific Airlines may disclose the personal data to third parties, such as authorized Pacific Airlines’ employees, business partners (our travel agents, car rental companies, hotels, credit card companies…), service providers or travel-related businesses pursuant to the purpose of performing our services (bookings and travel arrangements, support services and customer care services, loyalty programs, statistical analysis,…), excersing our legal obligations (security and safety on board, PNR information,…), our legitimate interests (direct marketing purposes of Pacific Airlines or our partners subject to the express consent of customers,…) and for the purpose of providing the best services to you.
As any airline company, Pacific Airlines may be required to provide personal information to public authorities (customs, immigration, police, etc.), such as for the completion of mandatory immigration formalities or for the purpose of preventing and fighting terrorism and other serious offences. Moreover, pursuant to the Directive 2016/681 of European Union in 27 April 2016, Pacific Airlines may be required to provide competence authorities with information on passengers’ booking, check-in and boarding procedures.
The disclosure personal data to sub-contractor will be conducted on a contractual basis where requires and ensures the protection of your personal data in accordance with this Private Policy and the applicable laws.
- Transfers of personal data to third countries
You are informed that Pacific Airlines may transfer your personal data to third parties located outside the European Union, such as mainly Vietnam and the USA in order to be processed and stored.
In such context, Pacific Airlines, by issuing and implementing Bindings Corporate Rules (BCRs), undertakes to protect your personal data in accordance with the applicable laws.
Article 9. Your rights to the personal data collected
- Subject to the applicable laws, you, as the personal data subjects, have the following rights:
- The right of access
You have the right to ask Pacific Airlines, at any moment, for confirmation that certain of your personal data are processed by Pacific Airlines, as well as to provide you with certain information such as the categories of personal data concerned, the purposes of the processing and the recipients or categories of recipient of those data.
- The right of rectification
You have the right to obtain from Pacific Airlines the rectification of inaccurate or incomplete personal data concerning you.
- The right to be forgotten
You have the right to obtain the erasure of your personal data stored by Pacific Airlines in accordance with the applicable laws, such as in situations where your personal data are no longer necessary to the initial purposes for which they were processed as well as situations where these data were processed unlawfully.
- The right to restriction of processing
You have the right to obtain from Pacific Airlines a limitation of the processing of your personal data without deleting the concerned personal data in the conditions in accordance with the applicable laws.
- The right to data portability
You have the right to recover some of your data for your own use or to transmit them to another company/enterprise in the conditions in accordance with the applicable laws.
- The right to object
You have the right to object at any time to the processing of your personal data for prospecting and direct marketing purposes.
- The right to withdraw consent
When the processing of your personal data is subject to your prior consent, you have the right to withdraw your consent at any time. You shall be aware that the withdrawal of consent shall not affect the lawfulness of the previous processing based on your consent before the withdrawal.
In case of such withdrawal, it may mean we will not be able to provide or deliver you all or parts of the services, which you may have requested from us in full quality, if you withdraw the consent relating personal information which directly affects our service provision or service quality.
- The right to lodge a complaint
You have the right to lodge a complaint to the competent authorities in the event of violation by Pacific Airlines of the applicable legislation regarding the protection of personal data.
You can exercise your rights listed above by sending a postal mail or an email to the following address:
3rd Floor, Vietnam Airlines Building – Tan Son Nhat International Airport, Tan Binh District, City. Ho Chi Minh City, Vietnam
When submitting your request, please provide the necessary identification information (name, first name, e-mail) as well as any other information necessary to the confirmation of your identity.
Article 10. Personal information of children
We collect, share and use personal information of a child under fourteen (14) years who hold a Korean nationality, only when obtaining consent of the child’s parents, legal representative and/or guardian, who may request to view, edit their child’s personal information or to alter or withdraw the consent at our sales offices or via sending a postal mail or an email to the address provided in Article 9 above.
For a child who is in a Member State of European Union and below the minimum age permitted to giving consent in accordance with Member State’s regulations (13 for Denmark, Spain and the United Kingdom, 14 for Austria and Italy, 15 for Czech Republic and France, 16 for Germany and The Netherlands), we may collect information of the child requiring consent after obtaining the consent or authorization from his or her parents or guardian.
For a child who hold another nationality, we may collect information of the child after obtaining consent or authorization from his or her parents or guardian in accordance with the applicable laws on data protection.
Article 11. Technical measures for protecting personal information
To secure the safety of personal information from a loss, theft, leak, falsification, or damage, Pacific Airlines’ employees may take the following technical, managerial, physical measures as:
- The important personal information is stored and managed in password protected mode within the limited access.
- Given the risk of hacking, likelihood and severity of damage to the rights and freedoms of natural persons, Viet Nam Airlines undertakes:
- To prevent customers’ personal information from leakage or damage by hacking or computer virus.
- To control the access suspension system, unauthorized accesses from outside.
- To take appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including the pseudonyms and encrypted of personal data.
- To ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- To restore the availability and right to access to personal data in a timely manner in the event of a physical or technical incident;
- To ensure a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures with a view to ensuring the security of the data processing;
- To operate an exclusive organization for protecting personal information.
Article 12. Communication with you and notify to the local authority in case of a breach of your personal data
- We will notify immediately, after we are aware of that your personal data are breached, to you and to the local authority in accordance with the applicable laws. This notification about your personal data breach will describe in clear with plain language the nature of the personal data breach and contain at least the following information and measures:
- Name and contact details of the data protection officer or other contact point where more information can be obtained;
- Description of the likely consequences of the personal data breach.
- Description of the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
- The notification to you as referred to in paragraph 12.1 of this Article shall not be required if any of the following conditions are met:
- Pacific Airlines has taken appropriate technical and organizational protection measures, in particular those that render the personal data unintelligible to any person who is not authorized to access it, such as encryption.
- Pacific Airlines has taken subsequent measures which ensure that the high risk to your rights and freedoms referred to in paragraph 1 is no longer likely to materialize.
- It would involve disproportionate effort for Pacific Airlines. In such a case, there shall instead be a public communication or similar measure whereby you are informed in an equally effective manner.
Article 13. The Data Controller and the Data Protection Officer.
The Data Controller is Pacific Airlines Joint Stock Aviation Company, a lawfully incorporated under the law of Vietnam, having its head office 112 Hong Ha, Ward 2, Tan Binh District, City. Ho Chi Minh City, Vietnam.
Pacific Airlines guarantees that the protection for personal information is implemented comprehensively and our Data protection officers comply with this Private Policy.