1.1 This data protection policy/code of conduct ("Policy") is applicable to data subjects in the European Economic Area. This Policy gives important information about:
1.1.1 the data protection principles with which Hainan Airlines Holding Company Limited (hereinafter the "Company", "we", "us" or "our") must comply;
1.1.2 what is meant by personal information (or data) and sensitive personal information (or data);
1.1.3 how we gather and use personal information and sensitive personal information in accordance with the data protection principles under the General Data Protection Regulation (EU) 2016/679 ("GDPR"); and
1.1.4 data subjects' rights and obligations in relation to data protection.
1.2 This Policy applies to all personal information collected by or on behalf of the Company, and may include personal information about its customers, potential customers, website visitors and job applicants.
1.3 We will review and update this Policy as we deem necessary or in accordance with our data protection obligations.
1.4 The Company may obtain, keep and use personal information (also referred to as personal data) about its customers, potential customers, website visitors and job applicants for a number of specific lawful purposes.
1.5 This Policy sets out how we comply with our data protection obligations and seek to protect personal information. Its purpose is also to ensure that our staff understand and comply with the rules governing the collection, use and deletion of personal information to which they may have access in the course of their work.
1.6 We are committed to complying with our data protection obligations, and to being concise, clear and transparent about how we obtain and use personal information, and how (and when) we delete that information once it is no longer required.
|"criminal records information"||means personal information relating to criminal convictions and offences, allegations, proceedings, and related security measures;|
|"data breach"||means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information;|
|"data subject"||means the individual to whom the personal information relates;|
|"personal information" or "personal data"||means information relating to an individual who can be identified (directly or indirectly) from that information;|
|"processing"||means obtaining, recording, organising, storing, amending, retrieving, disclosing and/or destroying information, or using or doing anything with it;|
|"pseudonymised"||means the process by which personal information is processed in such a way that it cannot be used to identify an individual without the use of additional information, which is kept separately and subject to technical and organisational measures to ensure that the personal information cannot be attributed to an identifiable individual;|
|"sensitive personal information"||(sometimes known as "special categories of personal data" or "sensitive personal data") means personal information about an individual’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), genetics information, biometric information (where used to identify an individual) and information concerning an individual’s health, sex life or sexual orientation.|
|"Websites"||means any website(s) owned or operated by the Company.|
3.DATA PROTECTION PRINCIPLES
3.1 The Company will comply with the following data protection principles when processing personal information:
3.1.1 we will process personal information lawfully, fairly and in a transparent manner;
3.1.2 we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
3.1.3 we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
3.1.4 we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information are deleted or corrected without delay;
3.1.5 we will keep personal information in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the information is processed; and
3.1.6 we will take appropriate technical and organisational measures to ensure that personal information are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
4.1 The Company may issue privacy notices from time to time, informing you about the personal information that we collect and hold relating to you, how you can expect your personal information to be used and for what purposes.
4.2 We will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
4.3 When personal information is collected
4.3.1 We collect personal information where it is necessary for us to conduct our everyday activities or functions.
4.3.2 Here are some examples of situations where we collect personal information:
(a) when you register for an account on our Websites, apps or kiosks;
(b) when you complete purchase orders, requests or applications for our products, services and/or facilities (by telephone, in person, by post, on forms, through our Websites or by any other means);
(c) when you communicate with us directly in relation to our products, services and/or facilities (by telephone, in person, by post, on forms, through our Websites or by any other means);
(d) when you use services and/or facilities that are made available on our Websites or at our physical locations;
(e) when you conduct certain types of transactions such as refunds;
(f) when you enter, and when you interact with us during, any of our promotions, competitions, contests, lucky draws or special events;
(g) when you subscribe to any of our membership programmes;
(h) when you participate in our surveys and other types of research; or
(i) when you apply for employment with us.
4.4 What personal information is collected
4.4.1 The provision of your personal information is voluntary unless otherwise indicated as mandatory. If you do not provide any personal information to us which is mandatory, we may not be able to provide the products and/or services that you require of us.
4.4.2 The types of personal information which we may collect include the following:
(a) contact information such as names, addresses, telephone numbers, email addresses, usernames;
(b) billing information such as billing address and credit card information;
(c) unique information such as identity card numbers, passport numbers, photographs and date of birth;
(d) contact and marketing preferences;
(e) details of any membership that you have with us;
(f) details of your visits to our Websites, such as traffic data, location data, and the resources that you access on our Websites;
(g) details of your online identifiers, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags;
(h) your transaction history with us; and
(i) if you are a candidate for employment, any personal information that you provide to us during the recruitment process including personal details from your resume and any application form that you submit to us. Such personal information may include your employment history and working eligibility rights.
4.4.3 You may, in certain circumstances, provide us with personal information relating to third parties (for example, your next-of-kin, travelling companion or, if you are a candidate for employment, any person whom you have nominated as your referee). When this happens, you are deemed to have represented and confirmed to us that you have obtained the consent of such third party to provide his/her personal information to us for processing in the manner set out in this Policy.
4.5 Purposes for collection, use and processing of personal information
4.5.1 The personal information which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances at hand and your consent, including for example:
(a) to assess, process and provide our products, services and/or facilities requested by you;
(b) to provide you with any assistance that you have requested;
(c) to maintain and improve our customer relationship with you;
(d) to establish your identity;
(e) to administer and process any payments (including refunds) related to products, services and/or facilities or other commercial transactions requested by you;
(f) to conduct credit reference checks and establish your creditworthiness, where necessary, when providing you with products, services and/or facilities;
(g) to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings between us;
(h) to provide you with information and updates on products, services, facilities, loyalty programmes, promotions, launches, campaigns, contests and/or events offered or organised by us and our affiliated partners from time to time, in accordance with your consent;
(i) for direct marketing purposes via SMS, phone, email, fax, mail, instant messaging, social media and/or any other appropriate communication channels, in accordance with your consent;
(j) to administer our loyalty or rewards programmes;
(k) for internal administrative purposes and record-keeping;
(l) to send you seasonal greetings messages from time to time;
(m) to monitor, review and improve our products, services, facilities, promotions and/or events;
(n) to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products, services and/or facilities;
(o) to process, combine and/or analyse your personal information for the above purposes;
(p) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(q) for our audit, risk management and security purposes;
(r) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(s) to transfer or assign our rights, interests and obligations under any agreements entered into with us;
(t) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, legislation, regulation, direction, court order, by-law, guideline, circular or code applicable to us from time to time ("Applicable Law");
(u) to enforce or defend our rights and your rights under, and to comply with, our obligations under any Applicable Law.
4.5.2 We will notify you in advance of any other purpose(s) for which we intend to use your data and obtain your consent where necessary, unless we are permitted by the GDPR or any other Applicable Law to process your personal information without your consent.
4.6 Transfer of personal information
4.6.1 In order to smoothly conduct our business operations and/or to fulfil our obligations to you, we may disclose the personal information that we have collected from you to third parties, for one or more of the purposes set out at paragraph 4.5 of this Policy. Examples of third parties to whom we may disclose your personal information include:
(a) third party service providers, agents, affiliates or related companies who provide operational services in connection with our business such as data entry, telecommunications, information technology, logistics, storage and warehousing, delivery, assembly, installation, printing and postal services, credit checks, credit facilities or services relating to marketing and promotional activity;
(b) our professional advisors, consultants and/or auditors; and
(c) relevant government regulators or authorities (in accordance with any Applicable Law).
4.6.2 The third parties with whom we conduct business are only authorised to use your personal information to perform the service for which they were hired. As part of our agreement with them, they may be required to adhere to the GDPR and/or any policies that we provide, and to take reasonable measures to ensure your personal information is secure.
4.6.3 We may transfer the personal information collected from you to jurisdictions inside or outside of the European Economic Area, the People's Republic of China and other locations that we may notify to you from time to time, for the purposes set out at paragraph 4.5 of this Policy, subject always to our information security obligations set out at paragraph 11 of this Policy. For data subjects inside the EEA, the Company will not transfer their personal information outside of the EEA without first receiving their explicit consent to do so.