We collect information when you purchase flight tickets or access other products on our website (www.airvistara.com) , mobile application or through travel agents/platforms whether offline or online (collectively referred to as the “Website”) or when you travel with us, such as your contact details, travel information payment details etc. We also collect information about your preferences from your interactions with our in-flight and other staff, and from specific requests you make. In addition to this we collect device and technical information from you when you use theWebsite. For more information, please refer Section 1 “The types of Customer Data we collect”.

We use your information to fulfil our contract of carriage with you and to the extent required for administering your membership with our frequent flyer programme, Club Vistara. We also use your information to maintain our Website, and to tailor our products and services to your preferences to provide the best service possible. In addition we use your information to market our products and services to you, and those of our, partners, affiliates and agents/service providers under appropriate legal basis.  For more information, please refer Section 3 “How we use your Customer Data”.

We share your data with our third party service providers, affiliates etc. to the extent necessary for them to provide their services such as payment processors and ground handling agents. We use these third parties services solely to process or store your information for the purposes described in this Privacy Policy. We also share your information with our interline, code share and strategic alliance partners, other carriers who help us provide our services and our stations and with government bodies as required by law. For more information, please refer Section 4 “Disclosure of your Customer Data”.

Our technology infrastructure is cloud-based and outsourced. We transfer your information to airports and ground staff in destinations that you are flying to and where we operate. Our staff are located in our offices around the world. For more informaton, please refere Section 5 “Transfer of information overseas”.

TSAL will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, and for satisfying any legal, business, accounting or reporting requirements or as required by relevant laws. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For EU, Singapore and UK residents, we will endeavour to delete data within 30 days of a request for erasure or contact you if it will take longer. For more information, please refer Section 8 “Retention”.

You have various rights in relation to your data.

More Information for non-EU , non- Singapore and non- UK residents, please refer Section 6 “Non EU, UK and Singapore Data Subject Rights”.

More Information for EU, Singapore  and UK residents, please refer Section 7 “EU,UK and Singapore Data Subject Rights”.

TSAL will amend this Privacy Policy from time to time and the updated versions will be posted on TSAL’s Website. Please check back from time to time to see any updates or changes to this Privacy Policy.

For more information, please refer Section 13 “Updates to the Privacy Policy”

 All these reference sections should direct the customer to the relevant section by just clicking

If you have any concerns or complaints, please contact us at the addresses mentioned in Section 14 “Contact us”.

The types of Customer Data that TSAL collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.

There are two broad categories of Customer Data that TSAL collects:

1. Personal Data- The data we collect includes but is not limited to:
   • personal information that can be used to identify an individual, such as name, gender, date of birth, passport or other personal identification numbers;
   • contact information, such as mailing address, phone number, email address;
   • payment information, such as credit or debit card information, including the name of cardholder, card number, billing address and expiry date through our passenger service system;
   • travel information, such as ticket numbers, destinations, flight information;
   • information on your other purchases made through TSAL, such as tracking your purchases of chargeable seats, excess baggage, seat upgrades, etc. through the Website (as defined below), packages such as the Vistara Getaways and other linked travel arrangements;
   • your customer preferences, such as dietary, seating, places that you would like to visit or other service preferences;
   • information about your in-flight WiFi usage, such as whether you use in-flight WiFi, what WiFi plan you used, the mode of payment to pay for in-flight WiFi and how much data was utilised for your WiFi session;
   • information about your interactions with our ground staff, such as the details of any complaint cases, incidences of lost baggage, call details, and other information relevant to assist our ground staff to service you;
   • health information, such as doctors’ notes, disability certificate, vaccination status, pre departure test results, medical certificates and letters and requests related to medical conditions;
   • information we receive fromyou on official social media channels and Website;
   • information we receive from flight bookings made via our travel agents, online booking platform,and corporate booking platform;
   • information you choose and/or consent to submit when you use features on the Website or other online facilities, including, but not limited to: (a) audio clips and images you submit to us via the chatbot to provide travel recommendations and complaints ; and (c) your location information.
   • business contact information, such as the contact details of the employees of our vendors and corporate customers collected by TSAL.
   • Information received through white label solutions managed by third parties on behalf of TSAL such as Purple Ticket Gift Card, Zoom Car, etc.

2. Technical Data- This includes device and technical information you give us when using our Website such as IP addresses, cookie identifiers or other unique identifiers, like mobile carrier, time zone setting, operating system, platform, etc.

   For purposes of this Privacy Policy statement, Customer Data means both Personal Data and Technical Data.

   We also use Customer Data to derive statistical data, such as the number of passengers. This is processed and stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand TSAL's customer profile and improve TSAL's service offering.

Special categories of information or “sensitive personal data”

Certain categories of Customer Data, such as information about your race, ethnicity, religion, or health, are considered special categories of information, or “sensitive personal data” under the applicable laws including GDPR. Similarly, medical and financial data such as bank account details, payment details,etc. and personal identifiers such as passport details are treated as sensitive for the purpose of the Singapore PDP Act.

Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your travel arrangements that reveal or suggest something about you that could be considered “sensitive personal data”, or if you otherwise choose to provide such information to us (or a third party such as the travel agent through which you made your booking), or if such information is required by public or regulatory authorities for health, customs and immigration purposes

For example:

• if you request a particular type of meal, e.g. halal or kosher meals, this may imply or suggest that you are a member of a particular religion; or

• if you request specific medical assistance from us and/or an airport operator, e.g. the provision of a wheelchair, this may reveal that you have a particular medical condition.

How we collect data from you

TSAL collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised and/or persons who have been validly identified as being your authorised representative (e.g. your organisation’s corporate travel manager/agent) pursuant to our then-current security procedures).

TSAL also collects Customer Data from third parties which are located in various countries. This includes, but is not limited to, travel agents,  partners (including, amongst others, airlines and non-airlines), our service providers, travel agents, banking partners, other airline partners to facilitate travel on code share or multi-airline flights, or through the Website, any posts on TSAL-specific pages on social media websites and other channels including our ticketing counters and airport operations.

Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to TSAL has authorised the disclosure, is informed of and agrees to the provisions of this Privacy Policy.

The collection of the following types of Customer Data is mandatory to enable TSAL to fulfil our contract of carriage with you. These types of Customer Data are marked as mandatory on our booking form. If you do not provide this information, we will not be able to provide you with our services and/or products required.

• Passenger details, e.g title, first/given name, last/family name, date of birth, meal type, whether you are a resident of EU, UK, Singapore, California or other country/states.
• Contact details, e.g. email address, mobile phone number, home number or business number.
• Payment details, e.g. the name on the credit or debit card, the credit or debit card number, expiry date and card verification value (CVV) on the credit or debit card, and billing address which will be transmitted to our payments processors.

Additional information may be mandatory if you are flying to a specific country, or if you are flying on behalf of a business registered in a specific country, e.g. your gender, nationality, passport number, the country of issue of your passport, the name, GST registration number, vaccination status and address of the business you are flying on behalf of, and your business email address and phone number. These mandatory fields will be clear when you make a booking.

Wherever applicable the collection of the following types of Customer Data will be mandatory to enable TSAL to administer your membership with Club Vistara: (i) title; (ii) last/family name; (iii) first/given name if you do not have a last/family name; (iv) date of birth; (v) email address; (vi) mobile phone number; (vii) mailing address; (viii) gender; (ix) nationality; and (x) whether you are a resident of EU, UK, Singapore, California or Other country/state

These types of Customer Data are marked as mandatory on our sign up / enrolment form. If you do not provide this information, you will not be able to benefit from points accruals and membership tier benefits and we will not be able to provide you with our services and/or products required.

The failure to supply the following types of Customer Data will result in (i) TSAL being unable to update you on our latest products and/or launches; and/or (ii) your inability to enter or participate in contests, promotions or redemption activities organised by TSAL:

• Contact Information e.g. email address, telephone number; and
• Country of residence. 

If you are an EU / UK / Singapore resident, we are required to disclose the legal basis for processing your data under the GDPR / Singapore PDP Act.

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 (e.g., seat selection, insurance, etc.), fulfilling such booking and investigating potential fraudulent transactions);
• notify you about changes to our services, including changes in flight timings through flight alert messages via TSAL’s mobile services facility;
• facilitate airport, internet check-in and self check-in;
• provide airport services such as processing information relating to connecting flights, arrangements at airports and customs and immigration facilities;
• provide baggage related services such as processing of any baggage related queries, including mishandled or missing baggage claims;
• provide in-flight catering and other services (e.g. to provide you with a personalised inflight experience);
• in accordance with our contract with you as a Club Vistara member,in case applicable 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; and 
  • For seamless integration with our affiliates in case of a merger, amalgation etc.
  • Curate a loyalty program in collaboration with our affiliates in case of merger or amalgamation.

As it is in our legitimate interests to be responsive to you, to provide customised services and marketing and to ensure the proper functioning of our products, services and organisation, we will use your Customer Data to:

• improve the Website and ensure that the content from the Website is presented in the most effective manner for you and your device;
• administer the Website 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 opt-out of receiving these surveys at any time by contacting us;
• send you service emails, such as reminders when you have not checked out your purchases on the Website. You can opt-out of receiving service emails at any time by contacting us;
• respond to your enquiries, requests or feedback;
• enforce our terms, conditions and policies;
• allow you to participate in interactive features of the Website, when you choose to do so;
• customise our products and services to you, including by responding to and catering for your customer preferences;
• personalise the content you see on theWebsite, by enabling you to save your preferences and suggesting content for your next flight;
• keep the Website safe and secure;
• aggregate Customer Data into anonymised statistical data (such as 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;
• Curate a loyalty program in collaboration with our affiliates in case of merger or amalgamation.

to customise our marketing e.g. send you targeted marketing on places you would like to visit, based on your responses to optional questions on the Website and your prior travels.

If you are a resident of EU, UK or Singapore, you can object to this profiling and opt-out of receiving such targeting marketing. For more information on this right, please refer the para with the heading “Objection” under Section 7 below; and

• 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; and
  • 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).

If you are an EU, UK or Singapore resident, you can object to this profiling and opt-out of receiving such targeted marketing. For more information on this right, please refer the para with the heading “Objection” under Section 7 below.

• if you are an employee of an entity with a contractual relationship with us:
  • to contact you to perform our services, and in particular, 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; and
  • communicate with you about products, services, promotions, events and other news and information we think will be of interest to you.

If you are an EU, UK or Singapore resident, you can object to this profiling and opt-out of receiving such targeted marketing. For more information on this right, please refer the para with the heading “Objection” under Section 7 below; and

With your consent where and in the manner 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 you for Club Vistara.

You have the right to withdraw your consent to receive marketing communications at any time by contacting us at dpo@airvistara.com or unsubscribe through the option provided in such marketing communications.

TSAL will share your Customer Data with selected third parties, partners, affiliates etc. in the situations set out below:

• our travel and freight service providers or travel-related businesses and service providers (including ground personnel and security personnel, partner airlines, airport management, airport operators;
• our interline, code share and strategic alliance partners so that they can fulfil their contract of carriage for the flights you booked through TSAL and, where applicable, provide you with the relevant benefits of their frequent flyer programme. Where Customer Data is shared with such partners, the Customer Data will be used by that partner in accordance with their respective Privacy Policy;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
• analytics and search engine providers that assist us in the improvement and optimisation of the Website.
• affiliates to provide you with services in case of our merger or amalgamation with any of our affiliates.

TSAL will share the Customer Data with staff and service providers in order to customise your preferences and improve services when you travel with TSAL:

• For the purposes of our contract with you, i.e. to:
  • Fulfill bookings and facilitate air travel and ancillary services for  the passengers;
  • Manage passengers who travel on flights operated by our interline, code share and strategic alliance partners and/or are Club Vistara  members;
  • Manage passengers during flight disruptions and provide necessary assistance and services;
• As it is in our legitimate interests to be responsive to you, to provide customised services and marketing, to:
  • Respond to complaints or compliments received by TSAL from passengers who are sharing their flight experience on our flights;
  • Providing an enhanced customer experience and personalising offers to passengers;
  • Anticipating the servicing needs of passengers on flights with us;
  • Understanding customers better through analytics and research (including marketing research) to support personalisation;
  • Contacting customers about Club Vistara  related updates, surveys  and offers;  and
• For the purposes of undertaking targeted direct marketing and other forms of marketing or advertisement, provided we have the consent of the recipient and/or have provided the opportunity to opt-out, in each case where required by applicable law.   

TSAL will also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry. In particular, each of the passengers who are grouped under the same Passenger Name Record (“PNR”) number shall be deemed to be authorised representatives of each of the other passengers under the same PNR number.

TSAL will disclose your Customer Data to law enforcement agencies, public, regulatory authorities, border control agencies or other organisations for national security, customs and immigration purposes, if legally required to do so, or if we have a good faith belief that such use is necessary to:

• comply with legal obligation, process or request;
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues;
• protect the rights, property, health or safety of TSAL, passengers, a third party or the public as required or permitted by law (including exchanging Customer Data with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We will also disclose your Customer Data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
• if of our assets are acquired by a third party, in which case Customer Data held by us about our customers will be one of the transferred assets;
• to comply with legal obligations, processes or requests (such as disclosing Customer Data to executors in response to court orders).

In addition, we may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. TSAL also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an person or corporate entities. Further, TSAL will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

TSAL’s registered and corporate office is based in Gurugram, Haryana, India. TSAL’s infrastructure is primarily based on Cloud and its Core Systems are Software as Service (SaaS) in nature where its Customer Data is stored and accessed. Customer Data will be accessible to TSAL’s offices and appointed agents, including groundhandling agents, sales agents and contact centre agents, in India and around the world in connection with TSAL’s performance of the contract with you.

This means that Customer Data may be transferred to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA"), Singapore or  the UK.

We will transfer Customer Data to airports and ground personnel in destinations that you are flying to in and where we operate. The Customer Data is transferred outside the EEA, Singapore or the UK or country of your residence on the basis that it is necessary for the performance of the contract between you and TSAL. 

We will also transfer Customer Data to our interline / code share partners in strategic alliances for the purposes of performing any contract of carriage .  Please click here for a list of our partners.

If you are a resident of EU, Singapore or UK, where we transfer Customer Data outside the EEA, Singapore or the UK, this is done on the basis that it is necessary for the performance of the contract of carriage between you and TSAL.

We will ensure the same standard of protection to Customer Data as required under the applicable law and undertake any other measures required under applicable law to effect such transfer. 

The Customer Data will also be processed by staff operating outside the EEA, Singapore or the UK who work for us, for our suppliers or our business partners. Such staff are engaged in, among other things, the processing of your payment details and the provision of support services. 

If you are not a resident in the EU, UK or Singapore you may have certain rights in relation to the Customer Data we hold about you, which we detail below.

Right of access.

You have the right to know whether we are in possession or are processing Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.

Where permitted by law, TSAL reserves the right to charge a reasonable administrative fee for this service. TSAL reserves the right to deny you access to your Customer Data, if the burden or expense of providing access would be unreasonable to TSAL or disproportionate to your interest, or if the request is frivolous or vexatious  and may provide an explanation as required by applicable laws.

Right of correction.

You have the right to seek corrections of any Customer Data held about you that is inaccurate or incomplete. TSAL reserves the right to charge a reasonable administrative fee for this service.

Right of option to withdraw consent.

You may, at any time, withdraw your consent given or deemed to have been given in respect of the collection, use, processing, transfer or disclosure of Customer Data for any purpose by TSAL. However, this may affect our ability to provide services to you.

Right of erasure.

You may request that we erase the Customer Data we hold about you in the following circumstances:

• you believe that it is no longer necessary for us to hold the Customer Data we hold about you;
• we are processing the Customer Data we hold about you on the basis of your consent and you wish to withdraw your consent and there is no other ground under which we can process the Customer Data;
• we are processing the Customer Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Customer Data;
• you no longer wish us to use the Customer Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
• you believe the Customer Data we hold about you is being unlawfully processed by us.

Also note that you may exercise your right to restrict our processing of the Customer Data whilst we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Customer Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.

Where you have requested that we erase Customer Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Customer Data or providing links to the Customer Data to erase the Customer Data too.

Feedback and complaints.

If you have any concerns, feedback or complaints about the use and/or sharing of your Customer Data, we are open to receiving your feedback or complaints.

Exercise of Rights.

To exercise any of your rights, please contact us at dpo@airvistara.com. We will respond to your access request as soon as possible. If we are unable to respond to your access request within 30 days, we will inform you by when we can provide the response.

If you are a resident in the EU, Singapore or UK, you may have certain rights in relation to the Customer Data we hold about you, which we detail below. Some of these only apply in certain circumstances where TSAL is holding authority of the data and legally/contractually allowed as per the local laws as set out in more detail below. We also set out how to exercise those rights.

These rights include:

• The right of access. More Information
• The right of data portability. More Information
• The right of rectification. More Information
• The right of erasure. More Information
• The right to restrict processing. More Information
• The right to object. More Information

Please note that we will require you to provide us with proof of identity and address before responding to any requests to exercise your rights. Such information may include the following: 

• Full Name;
• Mailing Address;
• Email Address;
  
• Contact Number;
  
• A copy of an official identity document (e.g. Identity Card or Passport information) with all information apart from your full name and address redacted (if applicable); and 
• Club Vistara number (if applicable).

We will respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further periodin certain circumstances). Any extension required to respond to your request shall be communicated to you. To exercise any of your rights, please contact us at dpo@airvistara.com. Please note that requests sent in via other channels or which do not contain sufficient supporting information may take longer to process and/or we may not be able to respond within the prescribed timelines.

Complaints.

In the event that you wish to make a complaint about how we process your Customer Data, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.

If you are a UK resident and are dissatisfied with the way we have handled your complaint or request and want to make a complaint, you may write to the Information Commissioner, who is an independent regulator. Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

The right of access.

You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.

If you require more than one copy of the Customer Data we hold about you, we may charge an administration fee.

We may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person) or where another exemption applies. We may refuse any request or deny you access to your Customer Data if the request is excessive or unfounded and will provide you the explanations in writing as required by applicable laws.

The right of portability.

You have the right to receive a subset of the Customer Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Customer Data to another party.

The relevant subset of Customer Data is data that you provide us with your consent or for the purposes of performing our contract with you.

If you wish for us to transfer the Customer Data to another party, please ensure you detail that party and note that we can only do so where it is legally, contractually and technically feasible. We are not responsible for the security of the Customer Data, its transmission or its processing once received by the third party. We also may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person).

The right of correction.

You have the right to correct any Customer Data held about you that is inaccurate or incomplete. TSAL reserves the right to charge a reasonable administrative fee for this service. Please note that whilst we assess whether the Customer Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

To exercise any of your rights, please contact us at dpo@airvistara.com. Please note that requests sent in via other channels or which do not contain sufficient supporting information may take longer to process and/or we may not be able to respond within the prescribed timelines.

All data privacy requests should be sent to dpo@airvistara.com. If you are a Club Vistara member, you may correct any Customer Data by logging into your account, subject to verification of relevant information/documents by TSAL.

The right of erasure.

You may request that we erase the Customer Data we hold about you in the following circumstances:

• you believe that it is no longer necessary for us to hold the Customer Data we hold about you;
• we are processing the Customer Data we hold about you on the basis of your consent and you wish to withdraw your consent and there is no other ground under which we can process the Customer Data;
• we are processing the Customer Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Customer Data;
• you no longer wish us to use the Customer Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
• you believe the Customer Data we hold about you is being unlawfully processed by us.

Also note that you may exercise your right to restrict our processing of the Customer Data whilst we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Customer Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.  Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.

Where you have requested that we erase Customer Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Customer Data or providing links to the Customer Data to erase the Customer Data too.

To exercise any of your rights, please contact us at dpo@airvistara.com.

Restriction of Processing to Storage Only.

You have a right to require us to stop processing the Customer Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Customer Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

You may request we stop processing and just store the Customer Data we hold about you where:

• you believe the Customer Data is not accurate, for the period it takes for us to verify whether the Customer Data is accurate;
• we wish to erase the Customer Data as the processing we are doing is unlawful but you want us to just store it instead;
• we wish to erase the Customer Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
• you have objected to us processing Customer Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Customer Data whilst we determine whether there is an overriding interest in us retaining such Customer Data.

The right to objection.

At any time you have the right to object to our processing of Customer Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Customer Data for that purpose.

You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below by contacting dpo@airvistara.com referencing: Data Subject Rights.

You may object where we are processing the Customer Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing.

Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Customer Data whilst we make the assessment on an overriding interest. Please refer para with the heading “Restriction of Processing to Storage Only” under Section 7.

We reserve the right to charge a reasonable administrative fee for dealing with your request.

TSAL will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, and for satisfying any legal,  business, accounting or reporting requirements  or as required by applicable laws.

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

If you withdraw your consent to marketing, we will remove you from our marketing database.

TSAL needs your assistance to ensure that your Customer Data is current, complete and accurate. As such, please inform TSAL of changes to your Customer Data by contacting TSAL and submitting your updated particulars to TSAL in writing (see Section 14). TSAL reserves the right to charge a reasonable administrative fee for this service.

If you are a Club Vistara member, you may update your Customer Data at any time by logging on to your account subject to verification of relevant information/documents by TSAL.

TSAL will also request Customer Data updates from you from time to time. As detailed above, your booking information or flight itinerary will be disclosed to the appropriate customs and immigration authorities as required by law. As such, it is important to ensure that the Customer Data contained in your booking information or flight itinerary is current, complete and accurate.

TSAL takes reasonable security arrangements to ensure the protection of your Customer Data in its possession or within its control to prevent any unauthorised access, collection, use, disclosure, copying, modification or disposal, or similar risks; and the loss of any storage medium or device on which personal data is stored. Please note however, that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Customer Data, we cannot guarantee the security of your Customer Data transmitted through any channel, such as the Website; any transmission is at your own risk.

TSAL may, from time to time, provide you with links to other websites for your convenience and information. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You access these websites at your own risk and TSAL is not responsible for these websites.

Whilst we will protect your Customer Data on the Website, we cannot control or be responsible for the policies of other sites we may link to, or the use of any Customer Data you may share with them.  Please note that this Privacy Policy does not cover these other websites, and TSAL would recommend that you are apprised of their specific policies.

In addition, some features on the Website rely on third party services, including Application Programming Interface services provided by Google LLC and/or any of its subsidiary companies (collectively, “Google”). Where you choose to use any feature on the Website that relies on a service provided by Google, you consent to the disclosure of information, including Customer Data, necessary for such use to Google, and agree that the information so disclosed may be processed in accordance with the Google terms and conditions including its Privacy Policy.

TSAL cannot distinguish the age of persons who access and use the Website. 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 (see Section 14) to remove the relevant Customer Data and unsubscribe the minor.

If we become aware that Customer Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account. 

TSAL will amend this Privacy Policy from time to time, and the updated version will be posted on the Website and date stamped so that you are aware of when the Privacy Policy was last updated. Please check back frequently to see any updates or changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice via email notification. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language. 

If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact TSAL in writing at the address below referencing ‘Privacy Policy':

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: Data Protection
Copy to: custrelations@airvistara.com

European Union Representative

If you are located in Europe Union, our EU representative is Rickert Rechtsanwaltsgesellschaft mbH. You can contact our European Union representative via the following methods:

• Email: art-27-rep-tata@rickert.law
• Postal Address: Rickert Rechtsanwaltsgesellschaft mbH - TATA SIA Airlines Limited Colmantstraße 15 53115 Bonn Germany

United Kingdom Representative

If you are located in United Kingdom, our UK representative is Rickert Services Ltd UK. You can contact our UK representative via the following methods:

• Email: art-27-rep-tata@rickert-services.uk
• Postal Address: Rickert Services Ltd UK- TATA SIA Airlines Limited -PO Box 1487 Peterborough PE1 9XX United Kingdom