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Privacy Policy

PRIVACY POLICY

Public Joint Stock Company «Aeroflot - Russian Airlines»

SHORT VERSION

At Aeroflot, we take privacy and the protection of your Personal Data seriously.

Personal Data means information that can directly or indirectly identify you or other individuals (“Personal Data”). This typically includes information such as your surname, name, middle name, name suffix, patronymic date of birth, nationality, passport details, address, email address, telephone number and your status as ‘Aeroflot Bonus’ member or a member of another SkyTeam Alliance airline’s Loyalty Program. Personal Data can also include other information such as IP address, shopping habits, information about your gender, age, health, information about your lifestyle or preferences such as your hobbies and interests.

The categories of Personal Data, that we process, depend on how you use our services. We use your Personal Data to provide our website services in alignment with your preferences, to deal with your requests, to contact you regarding tailored products and services which may be of interest to you, to provide prize draws, games or competitions, or to carry out relevant administrative services. All Personal Data is processed in accordance with applicable data protection laws.

We do not disclose your Personal Data to any third party except to data processors that assist us with providing our services and authorized state and regulatory authorities. With your consent we use cookies for marketing, performance and statistical purposes.

As our valid customer, we also offer you various choices to control how your Personal Data is used.

In addition, if you have an Aeroflot Bonus Account, you can update your marketing preferences in your ‘My Account’ section. Alternatively, you can contact our customer service team at digital@aeroflot.ru.

If you would like to receive more information about the processing of your Personal Data by us and on the cookies that we use, please see the extended version of this Privacy Policy

EXTENDED VERSION

Content:

1.  Our Privacy Principles

2.  Our Privacy Policy

2.1  Who is Responsible for what happens with your data?

2.2  Who is Aeroflot’s Data Protection Officer?

2.3  When do we ask for your consent?

2.4  What happens if our customer is a child?

2.5  For which purposes do we process your Personal Data?

2.5.1  Surfing on our Sites – with or without Cookies

2.5.2  Contact

2.5.3  Suggestion of our products and services which may be of interest for you; marketing communication

2.5.4  Competitions and games

2.5.5  Purchase of Services (e.g. flight tickets)

2.5.6  ‘Aeroflot Bonus’ Program

2.5.7  Facilitating immigration formalities, entering the territory of a State or fulfilment of statutory obligations in relation to Passenger Name Records

2.6  Who is receiving your Personal Data?

2.6.1  Our service providers (processors)

2.6.2  Other recipients (controllers)

2.6.3  Sharing your Site usage information

2.6.4  Details about recipients of your Personal Data

2.7  To which countries do we transfer your Personal Data?

2.8  How long do we process your Personal Data?

2.9  How we process your Personal Data (methods of processing, operations to be performed on your Personal Data)

2.10  What are your rights?

2.11  Can you withdraw your consent to the processing of Personal Data?

2.12  Can you complain with the data protection authorities?

2.13  Do you have to provide your Personal Data to order on the Sites or become a member of the ‘Aeroflot Bonus’ Program?

2.14  How do we protect your Personal Data?

2.15  Can we change our Privacy Policy?

 

1. Our Privacy Principles

 

We take privacy seriously. Here are our 6 privacy promises to you:

  • We will ALWAYS respond to any questions on processing of your Personal Data without undue delay.
  • We will ALWAYS ensure that your Personal Data is used in line with applicable data protection laws.
  • We will ALWAYS be transparent with you about how we use your Personal Data. This includes informing you about what information we collect, what we do with it, with whom we share it and whom you should contact if you have any concerns.
  • We will ALWAYS provide you simple options to say 'STOP' when you are no longer happy with our marketing communications.
  • We will ALWAYS protect online and offline data in a similar manner.
  • We will ALWAYS take reasonable steps to make sure no unauthorized person accesses your Personal Data.

2. Our Privacy Policy

We are committed to safeguard your privacy and ensure that your Personal Data is protected. This Privacy Policy explains the types of Personal Data we collect and how we process and protect that data.

This Privacy Policy applies to Personal Data processed by us in connection with the services and products we offer to you, including but not limited to contracts for carriage by air and ancillary services (“Service(s)”). This includes Personal Data collected offline through our customer services or in-store, direct marketing campaigns, competitions, surveys and online through the Aeroflot website, applications and branded pages on third party platforms and applications accessed or used through such websites or third party platforms (“Sites”). The Sites include the ‘Aeroflot – Online Tickets’ mobile application and the ‘Aeroflot Entertainment’ mobile application (each an “App”).

This Privacy Policy also applies to our targeted content, including online offers and advertisements for products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Sites”) based on your use of the internet. These Third Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third Party Sites.

 

2.1. Who is Responsible for what happens with your data?

Public Joint Stock Company «Aeroflot - Russian Airlines», (“Aeroflot” or “we”; “our”; “us”), being a data controller, is responsible for processing of your Personal Data in relation to the Services. You can contact us via mail at Arbat St., 10, Moscow 119002, Russian Federation, by phone under +7-495-223-55-55 or by email under digital@aeroflot.ru if you have any questions.

 

2.2. Who is Aeroflot’s Data Protection Officer?

The Data Protection Officer of Aeroflot is Sergey V. Menshenin. You can contact the Data Protection Officer under tel. +49 (0) 69 273 006 11.

 

2.3. When do we ask for your consent?

By using our Services and our Sites, you acknowledge that we are processing your Personal Data in accordance with this Privacy Policy. If you do not wish that we process your Personal Data in this way, please do not use our Service or Sites or otherwise provide our Sites with your Personal Data.

We process your data to provide you the Services and the Sites. In certain instances, we only process your data if you have consented, for example in certain cases where we process your Personal Data for marketing purposes, use cookies or process your sensitive data. Where we process your data on the basis of your consent, we will ask for your consent explicitly. We may also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy or before sharing your Personal Data with group companies or relevant subsidiaries of Aeroflot for the purposes of marketing.

 

2.4. What happens if our customer is a child?

Our Services and Sites are intended for adults, but there could be instances where some customers under the age of 18 decide to view or purchase Services on our Sites. Our rule is that if we know a customer is under the age of 18, we will not use such customer’s Personal Data for marketing purposes unless parental consent is provided to us in writing. We will not sell any Services to customers under the age of 18.

To provide parental consent, please write to the Aeroflot contact details as listed in Section 2.1. Note however that access to certain parts of our Sites and/or eligibility to receive prizes, samples or other rewards may be limited to users over a certain age. We may use your Personal Data to carry out age verification checks and enforce any such age restrictions.

 

2.5. For which purposes do we process your Personal Data?

We collect your Personal Data directly when you visit our Sites and/or when you provide us with Personal Data when you purchase Services or as a member of the ‘Aeroflot Bonus’ program or other customer loyalty programs, such as the Loyalty Programs of other SkyTeam Alliance airlines (each a “Loyalty Program”), register for prize draws, games or competitions, subscribe to our newsletter, receive information or mailings, use our applications, complete a survey, and/or make a comment or enquiry or contact our customer services. We may also receive Personal Data about you from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.

In more detail, we process the following categories of Personal Data for the following purposes:

 

2.5.1. Surfing on our Sites – with or without Cookies

2.5.1.1. Which Personal Data do we collect about you?

For this purpose (Surfing on our website) we process the following Personal Data: Information about the type of browser you use, details of the web pages you have viewed, your IP and device address, your Cookie ID, hyperlinks that you have clicked, your user name, gender, networks, the websites you visited before arriving at our relevant Sites and information collected by cookies or similar tracking devices and any other information you choose to share when using Third Party Sites, e.g. when visiting Aeroflot’s sites on social media networks, such as Facebook, ВКонтакте (vk.com), Instagram, Twitter or Aeroflot’s YouTube channel). Our Sites involve simple links to social media networks; Aeroflot does not transmit any Personal Data to the provider of the relevant social media network when you click on such link.

 

2.5.1.2. What is the purpose of processing your Personal Data?

We (and third party service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our relevant Sites. Cookies are files that store information on your computer hard drive or browser that mean that we can recognise that you have visited us before. We use cookies and similar technologies (like pixels, fingerprints and other tools) to improve our products and your experience on our Sites by evaluating the use of our Sites, products and services and understand your browsing and shopping habits, analysing the effectiveness of our advertisements, personalising your website experience as well as evaluating statistics on website activity, evaluating (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you've visited it before and what site referred you to it, reviewing the Services that you have searched online and ended up purchasing them, making our Sites easier to use and to better tailor our Sites and our Services to your interests and needs, identifying that you have visited our Sites but did not purchase a Service, collecting information about your device and linking this to your Personal Data so as to ensure that our Sites present the best web experience for you and supplementing the Personal Data that you provide to us with other information that we hold or that we may receive from commercially available sources, such as public databases and data aggregators, and third parties. For more information about the use of cookies, please see our Cookie Policy.

 

2.5.1.3. How long do we store your Personal Data?

Please check our Cookie Policy. to learn about the storage periods for each cookie.

 

2.5.1.4. What is the legal basis for processing your Personal Data?

Some cookies and similar technology used on our Sites are necessary for the performance of a contract with you or necessary for legitimate interests of Aeroflot. For all other cookies and similar technologies used on our Sites, your consent is the legal basis for processing your Personal Data. To obtain your consent, we ask you to accept the use of such cookies and similar technologies through a cookie banner, a pop-up window or similar means on our Sites.

It is always possible for you to visit our Sites without disclosing your Personal Data. This requires that you have disabled cookies. Please note, however, that without cookies you may not be able to use all of the features of our websites or online services.

For more information about the use of cookies, please see our Cookie Policy..

 

2.5.2. Contact

2.5.2.1. Which Personal Data do we collect about you?

For this purpose (Contact) we process the following Personal Data: Surname, name, middle name, name suffix, patronymic, title, postal address, email address, home telephone or mobile number, frequent flyer number of the ‘Aeroflot Bonus’ program or the relevant Loyalty Program of another SkyTeam Alliance airline, passwords, payment history, payment information (i.e. bank or credit card details), order history / wishlist, age, date of birth, gender, passport details (number, country of issue, expiry date), posts and other content you submit to our Sites, other Personal Data you voluntarily provide to us, information on the handling of your request (including information on special needs or disabilities), queries from us and further information submitted with your request. Please, however, refrain from sending us information on your health or other sensitive data (data on your racial or ethnic origin, political opinions, religious or other beliefs, membership or otherwise of a trade union or condition or sexual life) in unencrypted emails.

 

2.5.2.2. What is the Purpose of processing your Personal Data?

We process your Personal Data whenever you contact us and respond to your enquiries and comments. We process your Personal Data that you enter when you book a flight or other Service or when you register for the ‘Aeroflot Bonus’ program or when you subsequently update or amend data in your user account. We process Personal Data to provide you with our Services that you request from us, including responding to your queries or comments. We look at the Services you buy at our Sites and that you have viewed on our Sites.

 

2.5.2.3. How long do we store your Personal Data?

We store your Personal Data only as long as required for the relevant purpose, unless we are required by the law to store them for a longer period.

 

2.5.2.4. What is the legal basis for processing your Personal Data?

Applicable data protection legislation allows Aeroflot to process your Personal Data for the purpose of performance of a contract with you (i.e. fulfil your contact request).

If you provide to us Personal Data that is considered sensitive (e.g. information on your health, racial or ethnic origin, political opinions, religious or other beliefs, membership or otherwise of a trade union or condition or sexual life), your separate explicit consent will be the legal basis for processing your Personal Data.

 

2.5.3. Suggestion of our products and services which may be of interest for you; marketing communication

2.5.3.1. Which Personal Data do we collect about you?

For this purpose (Suggestion of our products and services which may be of interest for you ) we process the following Personal Data: Surname, name, middle name, name suffix, patronymic, title, postal address, email address, mobile number, frequent flyer number of the ‘Aero-flot Bonus’ program or the relevant Loyalty Program of another SkyTeam Alliance airline, order history/wishlist (including purchases you make on our Sites, including the Apps, or in-store), payment history, age, date of birth, gender, passport details (number, country of issue, expiry date), Services you view on our Sites, brands you prefer, favourite store, actions you take on our website or when viewing our emails, answers you provide in researches or competitions, marketing surveys, your shopping habits and preferences and information about your lifestyle, such as your hobbies and interests.

 

2.5.3.2. What is the purpose of processing your Personal Data?

We process your Personal Data to suggest tailored products or services that we think may be of interest to you. We may do this by sending you – via post, email, newsletter, SMS, push notifications or phone – details of products, services, special offers, promotions and other information. We also contact you to offer the opportunity to take part in customer research surveys, promotions, prize draws or competitions. You may also receive in-store promotions (such as special coupons) from us when you have an account with us or are a member of a Loyalty Program.

 

2.5.3.3. How long do we store your Personal Data?

We store your Personal Data only as long as required for the relevant purpose, unless we are required by the law to store them for a longer period.

 

2.5.3.4. What is the legal basis for processing your Personal Data?

Your separate express consent in receiving marketing communications shall be the legal basis for processing.

You can opt out of receiving such marketing communications at any time by clicking the ‘unsubscribe’ link at the bottom of the communications we send you. If you are a member of the ‘Aeroflot Bonus’ program, you can opt out of receiving such marketing communications at any time by clicking on ‘My Account’ – ‘User Settings’ – ‘Mailing List Subscriptions’ – ‘Aeroflot News’ – ‘No’.

Please also see below additional information on how we process your Personal Data in context of our Loyalty Program.

 

2.5.4. Competitions and games

2.5.4.1. Which Personal Data do we collect about you?

For this purpose (Competitions and games) we process the following Personal Data: Surname, name, middle-name, patronymic, suffix, title, postal address, email address, home telephone or mobile number, age, date of birth, gender, frequent flyer number of the ‘Aeroflot Bonus’ program or the relevant Loyalty Program of another SkyTeam Alliance airline, passport details (number, country of issue, expiry date), user generated content or any other Personal Data that you submit – as required for the competition or game.

 

2.4.4.2. What is the purpose of processing your Personal Data?

We process your Personal Data to carry out prize draws, games or competitions where you participated. We process your Personal Data when you enter into a competition, to determine the winner or to provide the prize or select the prize if you win.

 

2.5.4.3. How long do we store your Personal Data?

We store your Personal Data only as long as required for the relevant purpose, unless we are required by the law to store them for a longer period.

 

2.5.4.4. What is the legal basis for processing your Personal Data?

Applicable data protection legislation allows Aeroflot to process your Personal Data for the purpose of performance of a contract with you (i.e. carry out prize draws, games or competitions).

 

2.5.5. Purchase and Providing of Services (e.g. flight tickets, online store, online check-in)

2.5.5.1. Which Personal Data do we collect about you?

For this purpose, we process the following Personal Data: Surname, name, middle name, name suffix, patronymic, title, postal address, email address, home telephone or mobile number, frequent traveller number of the ‘Aeroflot Bonus’ program or the relevant Loyalty Program of another SkyTeam Alliance airline, passwords, payment history, payment information (i.e. bank or credit card details), order history / wishlist, age, date of birth, gender, passport details (number, country of issue, expiry date), travel itinery, information on the handling of your request (including information on special needs or disabilities) and other Personal Data you voluntarily provide to us.

 

2.5.5.2. What is the Purpose of processing your Personal Data?

We process your Personal Data to process your online and / or offline purchase and deliver the relevant Service(s) to you as ordered. Your payment related Personal Data may be transferred to payment providers to process your payments.

 

2.5.5.3. How long do we store your Personal Data?

We store your Personal Data only as long as required for the relevant purpose, unless we are required by the law to store them for a longer period.

 

2.5.5.4. What is the legal basis for processing your Personal Data?

Applicable data protection legislation allows Aeroflot to process your Personal Data for the purpose of performance of a contract with you (i.e. your purchase of Services).

If you provide to us Personal Data that is considered sensitive (e.g. information on your health, racial or ethnic origin, political opinions, religious or other beliefs, membership or otherwise of a trade union or condition or sexual life)), your consent will be the legal basis for processing your Personal Data.

 

2.5.6. Aeroflot Bonus’ Program

This Section applies only if you register for a membership in the ‘Aeroflot Bonus’ Program. Please note that Loyalty Programs of other SkyTeam Alliance airlines are governed by the privacy policies of the relevant airlines, and not by the present Privacy Policy.

 

2.5.6.1. Which Personal Data do we collect about you?

For this purpose, we process the following Personal Data: Surname, name, middle name, name suffix, patronymic, title, postal address, email address, home telephone or mobile number, frequent flyer number of the ‘Aeroflot Bonus’ program, passwords, payment history, payment information (i.e. bank or credit card details), order history/wishlist, age, date of birth, gender, passport details (number, country of issue, ex-piry date), account status and details regarding miles collected and redeemed, information on the handling of your request (including information on special needs or disabilities), communication with you (including marketing communications) and other Personal Data you voluntarily provide to us.

Such Personal Data may also include information that may give an indication about sensitive Personal Data about you (e.g. your health when you purchase products that are used to treat a certain health or wellbeing status).

 

2.5.6.2. What is the purpose of processing your Personal Data?

We process your Personal Data to provide you all Services under the ‘Aeroflot Bonus’ Program. Your data may be transferred to payment providers to process your payments.

 

2.5.6.3. How long do we store your Personal Data?

We store your Personal Data for three years after you provide them to us, unless we are required by the law to store them for a longer period.

 

2.5.6.4. What is the legal basis for processing your Personal Data?

Applicable data protection legislation allows Aeroflot to process your Personal Data for the purpose of performance of a contract with you (i.e. your membership in the ‘Aeroflot Bonus’ Program).

If you provide to us Personal Data that is considered sensitive (e.g. information on your health, racial or ethnic origin, political opinions, religious or other beliefs, membership or otherwise of a trade union or condition or sexual life), your consent will be the legal basis for processing your Personal Data.

 

2.5.7. Facilitating immigration formalities, entering the territory of a State or fulfilment of statutory obligations in relation to Passenger Name Records

2.5.7.1. Which Personal Data do we collect about you?

The categories of Personal Data collected for this purpose are generally referred to as Passenger Name Records (“PNR”) depend on the requirements of the relevant country. PNR may in particular include the date of reservation/issue of ticket, date(s) of intended travel, name(s), available frequent traveller and benefit information (i.e. free tickets, upgrades, etc.), other names on PNR, including number of travellers on PNR, available contact information (including originator information), available payment/billing information, travel itinerary for specific PNR, travel agency/travel agent, code share information, split/divided information, travel status of passenger (including confirmations and check-in status), ticketing information, including ticket number, one-way tickets and automated ticket fare quote, baggage information, seat information, including seat number, general remarks including other supplementary information, special service information and special service request information, collected advance passenger information, system information and historical changes to the PNR.

 

2.5.7.2. What is the purpose of processing your Personal Data?

Many countries require airlines to provide passenger data to them for arriving and departing from the country or even for flying over the territory of the relevant country. There is a number of different purposes, such as ensuring security and protection of life and safety of the public, immigration formalities as well as fighting crime and terrorism.

 

2.5.7.3. How long do we store your Personal Data?

We store your Personal Data only for the duration of our statutory obligation to retain your Personal Data.

 

2.5.7.4. What is the legal basis for processing your Personal Data?

Compulsory laws and bilateral agreements between countries form the legal basis for processing. For example, the European Union has entered into agreements on the use and transfer of PNR with the United States of America, Canada and Australia.

 

2.6. Who is receiving your Personal Data? 2.6.1. Our service providers (processors)

We may share your Personal Data with the following data processors (i.e. service providers):

  • Relevant companies of Aeroflot Group and trusted third parties which directly support our promotional activities, Site administration and the ‘Aeroflot Bonus’ Program;
  • Trusted third parties to help us process and analyze your Personal Data, to give us insights about you that we can use to improve our advertising, products and services, and to track the effectiveness of a particular promotion or campaign;
  • If you purchase Services from us, trusted third parties to allow delivery of the Services you have ordered (e.g. service provider of our online booking system).

Unless you provided consent, each trusted third party is not authorised by us to use your Per-sonal Data in any other way. Each trusted third party will be required by us to implement ade-quate technical and organizational measures to protect your Personal Data.

 

2.6.2. Other recipients (controllers)

We may share your Personal Data with the following controllers (i.e. third parties that process your Personal Data for their own purposes):

  • Social media platforms (e.g. Facebook, Instagram) so that they can help us deliver our advertisements directly to your social media page or mailbox;
  • Law enforcement or other agencies if we are required to do so by law, or by a warrant, subpoena or court order to disclose your Personal Data.
  • Third party suppliers of services which you purchase through our Sites. These include:
    • Flight insurance: Joint Stock Company “AlfaStrakhovanie”, 115162,Moscow, Shabolovka street, 31 bld. B;
    • Airport transfer: Limited Liability Company “Aeroexpress”, 141400, Khimki, territory of International Airport “Sheremetievo”;
    • Airport transfer: Limited Liability Company “Iway Transfer”, 630007, Russia, Novosibirsk, Kommunisticheskaya street, 6, office 707;
    • Hotel bookings: Limited Liability Company “Hotelbook-Service”, 105120, Moscow, 3rd Syromyatnichesky lane, 3/9 bld. 6;
    • Rental cars: Europcar International S.A.S.U., 5/6 Place de Freres Mont-golfier, Immeuble Le Mirabeau, 78280 France.

 

2.6.3. Sharing your Site usage information

We may with your consent share site usage information with trusted third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you tailored content, including more relevant advertising for services and products which may be of interest to you. These trusted third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to help us deliver customized content and advertising to you when you visit our relevant Sites or third party sites.

 

2.6.4. Details about recipients of your Personal Data

Upon your request, we will provide you with more details about third parties involved in processing of your Personal Data, namely their names, addresses and role in Personal Data processing.

 

2.7. To which countries do we transfer your Personal Data?

Many of the recipients of your Personal Data (see Section 2.6 above) are based in the European Union / the European Economic Area and the UK. However, we may need to transfer your Personal Data to a location outside of the European Economic Area, including to countries that do not offer the same level of protection with respect to Personal Data as required in the European Economic Area and where there is no adequacy decision by the European Commission. If your Personal Data should be transferred to such country, we have, where required by applicable data protection legislation, ensured that an adequate level of data protection is achieved by an recognized legal mechanism, e.g. by means of the EU-U.S. Privacy Shield certification, so-called Standard Contractual Clauses, as published by the European Commission or Binding Corporate Rules. Please note that such recognized legal mechanism is not required where the transfer is necessary for the conclusion or performance of a contract concluded in the interest of you between Aeroflot and another natural or legal person, such as the third party suppliers specified in Section 2.6.2 above.

For situations where we conduct cross-border transfers of your Personal Data internally within different locations of Aeroflot, Aeroflot has, in order to maintain an adequate level of data protection, committed itself to comply with the so-called Standard Contractual Clauses.

 

2.8. How long do we process your Personal Data?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data have been fulfilled and once our statutory obligations to retain records have expired.

 

2.9. How we process your Personal Data (methods of processing, operations to be performed on your Personal Data)

We processes your Personal Data either manually or automatically by means of collection, recording, systemization, accumulation, storage, specification (update, modification), retrieval, usage, transfer (provision, access), depersonalization, blocking, deletion, destruction and other operations on personal data, which are allowed under applicable data protection law.

 

2.10. What are your rights?

You have the right to request from us:

  • Confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data;
  • Rectification of inaccurate Personal Data;
  • Erasure of Personal Data;
  • Restriction of processing of Personal Data;
  • To receive the Personal Data which you have provided to us and to have transmitted those Personal Data to another data controller without hindrance.

You have the following rights:

  • To object to any decision that significantly affects you being taken solely by automated processing;
  • Not be subject to any decision that significantly affects you being taken solely by automated processing;

To exercise any of your rights please contact us directly at PJSC Aeroflot, 119002, Moscow, Arbat Street, 10 or via email to digital@aeroflot.ru.

 

2.11. Can you withdraw your consent to the processing of Personal Data?

If your consent is the legal basis for the processing of your Personal Data, you can withdraw your consent at any time. This will not affect the lawfulness of the processing based on your consent before the withdrawal. You can withdraw your consent by sending us an email to the email address listed in Section 2.1, under ‘My Account’ in your ‘Aeroflot Bonus’ user account, or by calling us under the phone number listed in Section 2.1.

 

2.12. Can you complain with the data protection authorities?

If you think that the processing of Personal Data by us violates applicable data protection laws, you can lodge a complaint with the competent supervisory authority.

 

2.13. Do you have to provide your Personal Data to order on the Sites or become a member of the ‘Aero-flot Bonus’ Program?

You are not legally required to provide the Personal Data. However, if you do not want to provide your Personal Data, you may not purchase Services or register as a member of the ‘Aeroflot Bonus’ Program.

In order to purchase Services on our Sites or register as a customer or a member of the ‘Aeroflot Bonus’ Program, you must provide the Personal Data as listed in Section 2.5.5 and Section 2.5.6. If you shop products that may give an indication about your sensitive Personal Data (e.g. health data), we can only process this order and only credit points in the ‘Aeroflot Bonus’ Program if you consent that we process such data.

Marketing communications are part of the ‘Aeroflot Bonus’ Program. Registration for the ‘Aeroflot Bonus’ Program, therefore, includes consent to receive marketing communications.

If you do not provide the relevant Personal Data or if you reject cookies or do not provide your consent in context of other services than purchasing Services or the ‘Aeroflot Bonus’ Program, you may not receive such services at all or without interruption.

 

2.14. How do we protect your Personal Data?

We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. Our security measures are being improved continuously as new technology develops. The processing and transmission of data through our Sites is encrypted by Secure Sockets Layer protocol (“SSL”), which is an encrypting technology to ensure the highest possible security for the transmission of your data, including Personal Data, between your web browser and our internet system. The URL of a website with SSL connection to your browser starts with “https://”. Most browsers indicate SSL-encrypted websites by displaying an icon that depicts a closed padlock. This icon might be located in the address bar or the bottom status bar. If you have turned off your status bar, this icon may not be visible, even on websites that use SSL.

Our Sites may contain hyperlinks to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites. Once you have left our relevant Sites, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the relevant privacy policy for the website you visit.

 

2.15. Can we change our Privacy Policy?

We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy here. To the extent processing of your Personal Data be based on your consent, we must not change the scope of such processing, unless you have given additional consent to the changed scope of such processing. We encourage you to visit this area frequently to stay informed.