For purposes of this CCPA Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Personal Information does not include any aggregate consumer information, de-identified information, information that cannot be reasonably linked to you, or ly available public information i.e., information that is lawfully made available from federal, state, or local government records. However, publicly available does not include biometric information collected by a business about a consumer without the consumer’s knowledge.

California residents have the right to know the categories of Personal Information we collect, the purpose for collecting such personal information, and the categories of third parties to whom the personal information was shared for a business purpose or sold.

We collect Customer Data from the following sources:

• directly from you or persons authorized by you to act on your behalf:
• collected automatically and indirectly from you;
• from service providers that provide services to you on our behalf;
• from our partners including airline partners and Club Vistara partners;
• issued by us to you, for e.g., in the case of your Club Vistara membership number;
• from third party sources, such as social media platforms when you interact with our social media channels or analytics providers.

We will use the Customer Data in the following ways;

1. In accordance with our contract of carriage with you, we will use the Customer Data, to:
   • process and assist you with any transactions related to your booking (e.g., making a booking, providing services related to the booking (such as, seat selection, accommodation, etc.), fulfilling such booking and investigating potential fraudulent transactions);
   • notify you about changes to our services, including through flight alert messages via TSAL’s mobile services facility;
   • facilitate airport, web check-in and self-check-in;
   • provide airport services, such as, processing information relating to connecting flights, arrangements at airports, customs and immigration facilities;
   • provide baggage related services such as processing of any baggage related queries, including mishandled or missing baggage claims; and/or
   • provide in-flight catering, connectivity services, inflight entertainment services and other services (e.g., to provide you with a personalized inflight experience).
2. In accordance with our contract with you as a Club Vistara member, we will use the Customer Data, to:
   • maintain your Club Vistara account;
   • facilitate membership related transactions and services;
   • enable the member to log in using the Club Vistara account on any of the platforms hosted by TSAL;
   • Send you membership status updates and other account related information.
3. We will use your Customer Data in carrying out our business purpose, to be responsive to you, to provide customized services and marketing, to ensure the proper functioning of our products, services and organization, to improve the TSAL website/mobile app, the connectivity services or in-flight entertainment services, to ensure content from the website/mobile app the connectivity services or in-flight entertainment is presented in the most effective manner for you and your device;
   • administer TSAL website/mobile app or connectivity services or in-flight entertainment services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
   • monitor and record calls for quality, training, legal compliance, analysis, and other related purposes in order to pursue our legitimate interest to improve service delivery;
   • send you surveys by post or email (including surveys related to Club Vistara, if you are a member, as detailed below). You can unsubscribe/ opt-out of receiving these surveys at any time by contacting us (Refer 15(i));
   • send you service emails, such as reminders when you have not checked out your purchases on our website/mobile app. You can unsubscribe/ opt-out of receiving service emails at any time by contacting us (Refer 15(i));
   • respond to your enquiries, requests or feedback;
   • enforce our terms, conditions and policies;
   • allow you to participate in interactive features of our website/mobile app, the connectivity services or in-flight entertainment, when you choose to do so;
   •  customize our products and services including connectivity services to you, by responding to and catering for your customer preferences;
   • personalize the content you see on our website/mobile app, connectivity services or in-flight entertainment services, by enabling you to save your preferences and suggesting content for your next flight;
   • keep our website/mobile app and/or connectivity services provided or in-flight entertainment services safe and secure;
   • to communicate with you about your use of the connectivity services, to fulfill your orders, and for other customer service purposes;
   • to tailor the content and information that we may send or display to you, to offer airline and flight customization, and personalized help and instructions, and to otherwise personalize your experiences while using the connectivity services. For example, we may customize the language of the connectivity services, advertisements displayed in the connectivity services login pages based on the airline you are travelling with, the departing and arrival destinations, and where you sit during your flight;
   • to better understand how users’ access and use the connectivity services on an aggregated basis, to improve the connectivity services and respond to user desires and preferences and for other research and analytical purposes. For example, we may use this information to better manage the provision of the internet services, or to improve connectivity on an aircraft;
   • to administer surveys and questionnaires;
   • to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority;
   • to protect the safety, rights, property, or security of our flight/staff, the connectivity services, any third party or the general public; to detect, prevent, or otherwise address fraud, security or technical issues; to prevent or stop the activity that TSAL, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to conduct audits and to enforce this CCPA Notice;
   • aggregate Customer Data into anonymized statistical data (such as the number of passengers flown on a particular journey), which we will use for statistical analysis so that we can better understand TSAL's customer profile and improve TSAL's service offering;
   • to customize our marketing e.g., send you targeted marketing on places you would like to visit, based on your responses to optional questions on our website / mobile app / inflight entertainment systems and your prior travels.
4. In relation to Club Vistara:
   • market and communicate to Club Vistara members information on TSAL and Club Vistara promotions, contests, events, and lucky draws, including those conducted by Club Vistara partners (with your consent where required by applicable laws);
   • contact Club Vistara members regarding product and customer related surveys and market research;
   • respond to email and call enquiries from Club Vistara members;
   • provide services to celebrate special occasions;
   • send Club Vistara members Club Vistara-related news and Club Vistara e-statements and associated promotions and offers (with your consent where required by applicable laws).
5. if you are an employee of an entity with a contractual relationship with us:
   • to contact you to perform our services, to monitor and record calls for quality, training, legal compliance, analysis, and other related purposes in order to pursue our legitimate interest to improve service delivery;
   • enforce our terms and conditions against your employer;
   • communicate with you about products, services, promotions, events and other news and information we think will be of interest to you.
6. With your consent where required by applicable laws, we will use your Customer Data to:
   • send you marketing and promotional materials in relation to products and services offered by TSAL, TSAL’s partner airlines and service partners, as well as TSAL’s appointed agents including in relation to Club Vistara; and
   • register for Club Vistara.

TSAL cannot distinguish the age of persons who access and use our website/mobile app. Thus, if a minor (according to applicable laws) has provided TSAL with Customer Data without parental or guardian consent, the parent or guardian should contact TSAL to remove the relevant Customer Data and unsubscribe / opt-out the minor.

You have the right to request that we disclose what Customer Data we collect, use and disclose. You also have the right to request the specific pieces of Customer Data we have collected about you, as well as information about disclosure for business purposes of your Customer Data to third parties. Once we receive, verify and confirm your request, we will endeavor to disclose to you the information in relation to your Customer Data that you have requested.

You have the right to request the deletion of any of your Customer Data that is maintained/retained by TSAL. Please note that this is a limited right as we may be able to retain certain Customer Data subject to any exception under the CCPA, CPRA or another lawful and legal obligation/requirement. Once we receive, verify, and confirm your request, we will delete (and direct our service providers to delete) your Customer Data from our records, unless an exception applies.

You have the right to not be discriminated against for exercising any of these rights. In this regard, TSAL will not:

• deny you any services;
• charge different prices or rates for the services;
• provide a different level of quality of services; or
• suggest different rates or levels of quality of services.

We may offer you a different price or rate, or a different level or quality of goods or services, if the difference is reasonably related to the value of your data to us.

TSAL does not sell personal data as defined in section 1798.140(t) of the CCPA. Therefore, this right does not exist. 

You have the right to rectify any Customer Data held about you that is inaccurate. Subject to CCPA, TSAL reserves the right to charge a reasonable administrative fee for this service.

You have the right to limit the use of sensitive personal information. TSAL only processes sensitive personal information under limited circumstances, which is necessary for the performance of services. 

If you are a California resident, California Civil Code Section 1798.83 permits you to make a request, once in a calendar year, for information regarding the disclosure of your Customer Data to third parties for those third parties direct marketing purposes. To make this request, please submit a request via email at dpo@airvistara.com.

At this time, the website/mobile app does not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions. For information about “Do Not Track,” please visit http://allaboutdnt.com/

To exercise your rights under the CCPA and CPRA, please submit a request via email at dpo@airvistara.com or by filling in a data request form available here.

We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the personal information already maintained by us. We will not use this additional information for any other purpose than to respond to your request.

You may designate an authorized agent to make a request in certain circumstances on your behalf. Such an authorized agent must be registered with the California Secretary of State.

We will endeavor to fulfil your request within 45 days of receiving that request. If we require additional time, we will inform you of the reason and the extension period in writing.

Subject to CCPA, TSAL reserves the right to charge a reasonable administrative fee for addressing your request. The information provided to you against your request shall be limited to the duration of the preceding period of 12 months of the business’s receipt of the verifiable request.

The information shall be made in writing and delivered through your account with TSAL. In case you do not maintain an account with us then the same shall be sent via post or electronic mail at your option.

i) Contact Us

DPO
TATA SIA Airlines Limited
Intellion Edge, Tower A,
9th Floor, South Peripheral Road,
Sector – 72, Gurugram,
Haryana-122101, India
E-mail: dpo@airvistara.com referencing: [California Privacy Notice].

ii) Updates to the CCPA Notice

TSAL will amend this CCPA Notice from time to time, and the updated versions will be posted on TSAL’s website/mobile app and date stamped so that you are aware of when the CCPA Notice was last updated. Please check back frequently to see any updates or changes to this CCPA Notice. Subject to applicable laws, the English version of this CCPA Notice will prevail over any version of this CCPA Notice in another language.