The Airline Seat Company Limited/Canadian Affair is committed to respecting your privacy and protecting your personal information
The Airline Seat Company Limited/Canadian Affair and its affiliates (hereinafter « The Airline Seat Company Limited/Canadian Affair ») are committed to protecting your privacy. As a tour operator and distributor of travel services, we attach particular importance to protecting the personal information that you share with us and we strive to maintain your trust in this regard.
When you travel with The Airline Seat Company Limited/Canadian Affair, we need to collect some personal information about you such as your name, email address, passport number and payment details. This information is used, for example, to process your booking, to provide you our best possible customer experience and to keep you safe and secure. Some of this information is shared with The Airline Seat Company Limited/Canadian Affair’s trusted partners such as hotels and airport ground handlers to ensure that your baggage arrives safely at your destination. We are also required to share some of your information with government border control and airport authorities for reasons of security.
We have developed and implemented internal policies and procedures designed to provide adequate protection of the personal information in our possession and we review these on a regular basis.
We educate our employees about the importance of protecting personal information by providing them with training on this topic.
We take reasonable measures to ensure that our agents, mandataries, representatives and other external organizations comply with the provisions of the privacy protection legislation in force(e.g. airport service providers, incoming tour operators, hotel operators, administrative support, data processing and data storage companies, payment processors, etc.).
We have a dedicated group of employees responsible for matters of protection of personal information and have appointed a Data Protection Officer for privacy related issues.
What Is the Scope of Application of this Policy and Controller?
The provisions of this policy apply to all personal information collected and processed by The Airline Seat Company Limited/Canadian Affair within the framework of its activities, unless otherwise indicated when collecting such personal information.
The data controller collecting and/or processing your personal information is The Airline Seat Company Limited/Canadian Afffair, an affiliate of Transat A.T. Inc.:
The Airline Seat Company Limited
10 Eastbourne Terrace – 1st floor
However, in cases where you directly transacted with our airline carrier, Air Transat, the data controller shall be Air Transat A. T. Inc., an affiliate of Transat A.T. Inc.:
Air Transat A.T. inc.
The data controller’s representative in the European Union is:
Air Consultants France
13 Avenue du Général Leclerc
94700 Maisons Alfort, France
If certain Airline Seat Company Limited/Canadian Affair sites refer you to other websites operated by third parties, the information collected by said third parties on these other sites are not subject to this policy, when it is not used by The Airline Seat Company Limited/Canadian Affair. We therefore encourage you to review the privacy policies of these websites before disclosing your personal information to any third party.
What Is Considered Personal Information?
Personal information is any information that identifies you or can be used to identify you. Your personal information may include, for example, your name, your contact details, information relating to your travel itinerary (e.g. your booking reference number) or information on how you use our website and mobile app or how you interact with us.
This information may be collected from you during any interactions you have with us, for example when you visit our website, make a booking, call us or send us an email, answer a survey, enter a contest or a draw or subscribe to a loyalty program organised by The Airline Seat Company Limited/Canadian Affair or on behalf of the Airline Seat Company Limited/Canadian Affair. It may also come from one of our suppliers who provides services to you on our behalf, or from one of our suppliers or partners, for example when you book via a travel agency.
What Personal Information Do We Collect?
We may collect and process the following categories of personal information:
Your name, date of birth, gender, nationality and passport number. If your children are included in the booking, we will collect their identification information.
Your telephone number, physical address and email address. If you book via a travel agency, the agency may choose not to share your contact information with us.
During the booking process we collect information about your booking that may include your date of travel, flight reservations, hotel reservations and any ancillary services such as Option Plus, upgrades, extra baggage and payment details.
When you travel with us we collect and process information in relation to your travel such as your travel itinerary, check-in information, electronic boarding pass, medical needs, special dietary requirements and any additional assistance or preferences.
Adherence to special programs
If you register your child of 2 to 11 years old to the Air Transat A.T. Inc. Kids Club program, we will collect your child’s name, date of birth, gender as well as your name and email address as their parent or legal guardian.
When you communicate with us via email, online or via social media, we store your communication. When you contact us by telephone, for instance by calling our reservation department or our customer relations department, we may record your telephone calls for training purposes or to prevent fraud. We also collect your questions or complaints.
Previous bookings with The Airline Seat Company Limited/Canadian Affair
We collect information about services we have provided to you in the past, including your previous travel arrangements (flights and other bookings), interactions, lost luggage and customer feedback.
Use of our websites
When you navigate on one of our websites or subscribe to our newsletter, we may collect your IP address, browser type, operating systems, referring website, preferred language,web-browsing behavior and universally unique identifier (“UUID”).
We may also receive your location data.
We collect information that you enter during contests or comments that you choose to share on our social media platforms. Depending on your social network settings, we may receive information from your social network provider.
Sensitive personal information
When providing services to you, we may collect personal information that is considered sensitive as it could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences.
Should you request special medical assistance during a flight, this may reveal information about your health (e.g. need for a wheelchair or oxygen). In addition, your religious beliefs may be revealed when you request special meals or advise us of other dietary requirements. Likewise, your travel document details may contain information that may reveal your racial or ethnic origin.
When providing sensitive personal information, explicit consent to the processing of this information must be given. This sensitive personal information will be used strictly to allow us to provide any special services requested and to fully perform our obligations.
Third Party bookings
How Do We Use Your Personal Information?
We use your personal information for the following purposes:
To provide you with our services
We may use your personal information to process and manage your booking and to fulfil your travel arrangements and purchases. For example:
• To identify you in order to issue your ticket;
• To ensure you receive specified medical attention or dietary requirements;
• In case of non-provision, objection or restriction to processing or erasure of any information necessary to provide you with our services, or in the event you wish to restrict or withdraw consent previously given to us for the collection and use of your sensitive personal information, we may not be able to provide certain or all of our services to you. In such circumstances, cancellation fees may apply.
To communicate with you and keep you informed
We may need to contact you by email and/or by telephone for administrative or operational reasons, for example to send you confirmation of your bookings and your payments, to inform you about your travel itinerary, to notify you when check-in is available or to advise you of disruption and changes to your flights.
We will also use your contact information for commercial prospection and to send you marketing communications, if you agreed to receive such communications.
Your opinion is very important to us, so we may seek your feedback via email, social media or surveys.
We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our customer and to improve our services and experiences for customers.
To personalise and improve your customer experience
We may use the communications you exchange with us and information about how you use our websites to improve our products and services and to ensure that you receive advertising and communications from us that are relevant to you.
To improve your shopping experience on our websites
We may use personal information about your use of our websites through cookies and other technologies and mobile applications to:
• Track and analyse your usage of our websites to improve the relevance of our website content and to understand what is relevant to you
• Measure the effectiveness of and to improve the relevance of our advertisement and promotions;
• Conduct market, product or sales research and analysis to improve our products and services;
• Customize our marketing communications to you, if you agreed to receive such communications;
• Execute relationship marketing campaigns and retargeting using social media and other advertisement partners;
• Contact you to offer you more information about a product or service, if you agreed to receive such communications.
What Is Our Legal Basis For Processing Your Information?
The legal basis for processing your information will depend on the reason or reasons your information was collected. We will only process your personal information where we have a legal basis to do so. According to privacy laws, the legal basis for processing your information may be:
• To process your booking, fulfil your travel arrangements and otherwise perform the contract we have with you;
• To comply with a legal obligation;
• Because you have consented to The Airline Seat Company Limited/Canadian Affair using your information for a particular purpose.
• Because it is in the Airline Seat Company Limited/Canadian Affair’s legitimate interest to use your personal information, in particular, to enhance and improve our products and services, personalise our offers, develop new products and prevent fraud.
How Long Do We Retain Your Personal Information?
For example, your personal information related to a booking will be retained to fulfil the specific travel arrangements you have made. Afterwards, we will keep the information for a period of time which enables us to handle or respond to any complaints, queries, concerns or legal procedures relating to the booking.
We will actively review the information we hold and either delete it securely or anonymize it, when there is no longer a legal, business or customer need for it to be retained. In any event, we will erase or anonymise your information 7 years after your last interaction with us as a customer.
How Do We Keep Your Personal Information Safe?
We have implemented a combination of material, organisational and technological means to ensure the confidentiality of the personal information that we hold, to protect such information against loss or theft and to prevent any unauthorized access, transmission, reproduction, use or amendment thereof.
We use industry standard SSL (Secure Sockets Layer) encryption for the transmission of personal information on our websites, for example when you pay by credit card online. You can verify this protection by looking for the padlock symbol on many browsers. SSL allows a secure connection between your internet browser and our internet server, using a private (or secret) key to encrypt the information.
If you are a resident of a member state of the European Economic Area (“EEA”), your personal information may be accessed and processed outside the EAA by the Airline Seat Company Limited/Canadian Affair, whose servers are located in England, and/or by one of our trusted third party service providers. Except as provided for in article 49 of the General Data Protection Regulation n°2016/679, when your personal information is transferred outside of the EAA, we require that an adequate level of protection according to the data protection legislation in force be in place.
In this respect, we specify that : (i) England has been recognized by the European Commission as ensuring an adequate level of protection, likewise New-Zealand, Argentina, Switzerland and Israel ; (ii) with regard to the transfer of data to the United-States, your personal information will only be transferred to third-parties who undertook to provide guarantees as to the secure processing of personal data in accordance with the Privacy Shield recognized by the European Commission as ensuring an adequate level of protection; for additional information, please refer to the website https://www.privacyshield.gov/; (iii) for other countries, we have ascertained that the recipients of your personal information have put in place the appropriate safeguards in order to ensure that your personal information is adequately protected, the whole in accordance with the data protection legislation in force.
With Whom Do We Share Your Information?
To ensure that we can provide you with the products and services you have requested from us, we may need to disclose your personal information to trusted third parties, including:
• Regulatory authorities and law enforcement agencies such as immigration, customs, airport authorities, border security control for legal compliance and to ensure the safety of our customers, passengers and employees;
• Service providers, such as reservation agents, catering agents, travel service providers, freight providers, car rental or hotel providers and airport ground handling services to facilitate your travel and any other requests you have made;
• Other passengers named on your booking as part of the online check-in process;
• Technology service providers, whose systems we may use to notably, process your booking and travel, enhance your customer experience, conduct customer surveys or provide you with personalized marketing communications on our behalf;
• Forensic and investigatory service providers for investigating a data breach or incident.
• The Airline Seat Company Limited/Canadian Affair's affiliates, as part of providing the travel services.
Re-targeting technologies use your cookies or advertising IDs and display advertisements based on your past browsing behavior.
Your Rights Concerning Your Personal Information
In light of the obligation to ensure the security and confidentiality of the personal information being processed, two valid pieces of identification must be provided in support of any request made pursuant to the rights listed hereunder.
You have the right to access and rectify your personal information. You also have the right to withdraw your consent to processing of your personal information. Accessing the personal information contained in your file and rectifying such personal information is free of charge.
Accuracy and rectification of your personal information
We make every effort to keep the personal information in our possession accurate, complete, and up to date. However, you are in the best position to quickly inform us of any changes to your personal information, and we therefore ask you to inform us of any required amendments.
At any time, you may request that the appropriate corrections be made to the personal information that we hold about you. If applicable, we will forward the amended information to the third parties that have access to your personal information.
Withdrawal of consent to process personal information
When we process your information based on consent you have previously given, you may withdraw said consent at any time.
EEA residents Rights to data portability, to object, to restriction of processing and to erasure
In addition to the rights detailed above, if you reside in a member state of the EEA, you shall have the right, with regards to your personal information, to erasure, to restriction on processing, to object on legitimate grounds to processing as well as to obtain data portability, in circumstances described in the EU General Data Protection Regulation no 2016/679 (“GDPR”). A small fee may be required, upon notice from us, to cover the administrative costs of processing such requests.
You may also lodge a complaint with the competent Supervisory Authority in order to enforce your rights.
In addition, if you are a resident of France, you have the legal right to direct generally or particularly how your personal information may be used after your death.
Furthermore, when your personal information has been collected in France and you do not wish to be contacted by telephone for commercial solicitation purposes, you can register, without cost, to the list of opposition to telephone solicitation on the website www.bloctel.gouv.fr.
Please see the section How to Contact Us for information on the procedure for contacting us.
How to Contact Us
We will attempt to process your request within thirty (30) days of receipt thereof. If we are unable to respond within this time, you will be notified.
Updating of This Policy
This Policy is subject to amendment in particular to account for the rapid evolution of the rules pertaining to protection of personal information and privacy. This version was last updated on May 29, 2018. Any new version will automatically come into effect as soon as it is published by the Airline Seat Company Limited/Canadian Affair. Therefore, please visit the Airline Seat Company Limited/Canadian Affair’s websites regularly for any modifications.