Uganda Airlines commits to respecting your privacy and protecting your personal information.
Uganda Airlines will be transparent about the information we are collecting and what we will do with it.
Uganda Airlines will use the information you give for the purposes described in this Policy, which include providing you with services you have requested and enhancing your experience with us.
Uganda Airlines will also use the information collected to help us understand you better and so that we can give you relevant offers.
If at any time you inform us that you do not want to receive any further marketing messages we will stop sending them. We may, however, continue to send important service messages containing information relating to a product or service you have purchased to keep you informed about your booking and travel itinerary.
Uganda Airlines will put in place appropriate measures to protect your information and keep it secure.
Uganda Airlines will at all times respect your data protection rights.
If you have further questions please get in touch with us by writing to the Manager Security using the details provided in Section (T) below.
This Policy is issued by each of the Controllers listed in Section (T) below (together “Uganda Airlines”, “we”, “us” and “our”) and is addressed to individuals outside our organization with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (U) below.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Information, or changes in applicable law. We encourage you to read this Policy carefully and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
Collection of Personal Information
Collection of Personal Information: We collect or obtain Personal Information below. In brief, it means details which identify you or could be used to identify you. This includes information such as your name and contact details, your travel arrangements and purchase history. This may also include information about how you use our websites and mobile applications.
Information provided to us: We obtain Personal Information when that information is provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you create an online profile with us, or when you submit a job application).
Relationship information: We collect or obtain Personal Information in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer). We collect your Personal Information whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you travel with us when you use our website or mobile applications or interact with us via email or our contact centres.
Information you make public: We collect or obtain Personal Information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
App data: We collect or obtain Personal Information when you download or use any of our Apps.
Site data: We collect or obtain Personal Information when you visit any of our Sites or use any features or resources available on or through a Site.
Registration details: We collect or obtain Personal Information when you use, or register to use, any of our Sites, Apps, products, or services (e.g. when you become a member of our Loyality/reward program).
Content and advertising information: If you interact with any third-party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Information from the relevant third-party provider of that content or advertising.
Third-party information: We collect or obtain Personal Information from third parties who provide it to us (e.g., companies contracted by us to provide services to you, companies involved in your travel plans, including airlines involved in your prior or onward journey, relevant airport operators and customs and immigration authorities, Companies with whom we participate in a loyalty scheme with and other customer programmes (e.g. car hire providers and hotels), credit reference agencies; law enforcement authorities; etc.
Creation of Personal Information
We also create Personal Information about you in certain circumstances, such as records of your interactions with us (including records of your telephone conversations with us), and details of your purchase history.
Categories of Personal Information we Process
We Process the following categories of Personal Information about you:
Personal details: given name(s); preferred name; and photograph.
Demographic information: gender; date of birth/age; nationality; passport details; salutation; title; and language preferences.
Contact details: correspondence address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Purchase details: records of purchases and prices, including details of where you booked your flight (if on ugandairlines.com or if you used another sales channel such as a travel agent or our call center), details of your previous travel arrangements, such as your previous flights and any travel-related issues, such as upgrades received, your baggage requirements, airport disruption, lost luggage and your customer feedback.
Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
Information relating to our Sites and Apps: : device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Information); username; password; security login details; usage data; aggregate statistical information.
Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
Content and advertising information: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
Information collected about your travel arrangements: : information regarding your interaction with staff and cabin crew before, during and after the flight, information, photographs and other images which are collected from you as you pass through security at the airport.
Travel information: details of your booking, travel itinerary, details of any additional assistance you require, and other information related to your travel with us such as dietary requirements.
Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
Other interactions with us: information if you have entered a competition or registered for a promotion.
If you provide us with another individual’s Personal Information, you must ensure that you have the permission of that individual before you provide it to us (for example, if you are making a booking for another individual). When you are making a purchase for someone else, we may collect your payment details but may communicate with the other individual directly about the purchase.
Sensitive Personal Information
We may collect and Process Sensitive Personal Information in the ordinary course of our business. Uganda Airlines will limit the circumstances where we collect and process Sensitive Personal Information. Examples of when we may collect and process Sensitive Personal Information include situations where:
- You make a specific request for medical assistance, such as the provision of wheelchair assistance or oxygen
- You have sought clearance to fly with a medical condition or because you are more than 28 weeks pregnant.
- You have chosen to provide such information to us or it has been passed to us by a third party such as the travel agent through which you made your booking
- Biometric information (e.g. facial recognition information) may be collected during the security clearance process prior to, and after flying with us
- You have requested services which may imply or suggest your religion, health or other information (e.g. when you disclose your dietary requirements to us).
Where it becomes necessary to Process your Sensitive Personal Information for any reason, we rely on one of the following legal bases.
Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations)
LEGAL BASIS FOR PROCESSING
Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud)
Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights
Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
If you provide Sensitive Personal Information to us, you must ensure that it is lawful for you to disclose such information to us, and you must ensure a valid legal basis applies to the Processing of that Sensitive Personal Information.
Purposes of Processing and legal bases for Processing
The purposes for which we Process Personal Information, subject to applicable law, and the legal bases on which we perform such Processing, are as follows.
Disclosure of Personal Information to third parties
We disclose Personal Information to other entities within the Uganda Airlines group, for legitimate business purposes and the operation of our Sites, Apps, products, or services to you), in accordance with applicable law. In addition, we disclose your Personal Information to:.
- You and, where appropriate, your appointed representatives
- Legal and regulatory authorities (including customs and immigration authorities of any country in your itinerary or to which your flight may fly over), upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- Accountants, auditors, lawyers and other outside professional advisors to Uganda Airlines, subject to binding contractual obligations of confidentiality
- Third party Processors (such as payment services providers; baggage handling organizations, other operators at airports supporting our services, etc.), located anywhere in the world, subject to the requirements noted below in this Section (H)
- Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights
- Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties
- Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)
- The other organizations supporting the loyalty scheme including
If we engage a third-party Processor to Process your Personal Information, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Information; together with any additional requirements under applicable law.
Government Access to Uganda Airlines booking records
Under US Law, for example, the US Customs and Border Protection (CBP) receives certain travel and reservation information, known as Passenger Name Record (PNR) data about passengers flying to the USCBP has undertaken that it uses this PNR data for the purposes of preventing and combating terrorism and other transnational serious crimes. The PNR may include information provided during the booking process or held by airlines or travel agents. The information will be retained for at least three years and six months and may be shared with other authorities.
Further information about these arrangements, including measures to safeguard your Personal Information can be obtained if you Click Here (this link is an external website, not ugandairlines.com. Please note that Uganda Airlines isn't responsible for the information contained on this website and that different terms and conditions may apply).
Airlines are also required by other Governments to provide passenger data to the control authorities. Accordingly, any information we hold about you and your travel arrangements may be disclosed to the customs, immigration and police authorities of any country in your itinerary, and possibly on occasions, to countries not in your itinerary.
We Process Personal Information for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:
LOGIC OF THE PROFILING ACTIVITY
CONSEQUENCES FOR YOU
Where we engage a third party (e.g., a credit reference agency) to provide us with information about your credit score and/or credit history. This information is analyzed to determine the most appropriate terms on which to offer you credit, where applicable.
This Profiling activity may affect whether you are able to obtain credit, and the interest rates applicable to any such credit.
Where we analyze your purchasing activity and your interests. This information is analyzed to determine the most appropriate promotions and discounts to offer you.
This Profiling activity may mean that you receive discounts that are not available to others, and that others receive discounts that are not available to you.
Previous/current travel travels/itinerary
Where we analyze your past travel activity and your interests. This information is analyzed to determine the most appropriate promotions and products to offer you.
This Profiling activity may mean that you receive new product launches, new destinations or similar options that are not available to others, and receive promotional offers that are not available to you.
Previous purchases/special request
Where we analyze your purchasing activity and your requests. This information is analyzed to determine and customize service offering tailored to your unique and appropriate past history with us.
This Profiling activity may mean that you receive offers to past choice for example meal, seating, drink and that you would be addressed by name and receive special occasions offers and wishes that are not available to others.
International transfer of Personal Information
Because of the international nature of our business, we transfer Personal Information within the Uganda Airlines group, and to third parties, as noted in Section (H) above, in connection with the purposes set out in this Policy. For example, where you are flying, your personal information will be transferred to border control and immigration authorities. For this reason, we transfer Personal Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of [Standard Contractual Clauses]. You are entitled to request a copy of our [Standard Contractual Clauses] using the contact details provided in Section (T) below
Please note that when you transfer any Personal Information directly to a Uganda Airlines entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the information, in accordance with the provisions of this Policy.
We have implemented appropriate technical and organizational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information, we cannot guarantee the security of the information transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.
We take every reasonable step to ensure that:
- Personal Information of yours that we Process is accurate and, where necessary, kept up to date.
- Any Personal Information of yours that we Process that is inaccurate (having regard to the purposes for which they the information is Processed) is erased or rectified without delay.
- From time to time we may ask you to confirm the accuracy of your Personal Information.
We take every reasonable step to ensure that your Personal Information that we Process is limited to the Personal Information reasonably necessary in connection with the purposes set out in this Policy.
We take every reasonable step to ensure that your Personal Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Information is as follows:
we will retain Personal Information in a form that permits identification only for as long as:(a) we maintain an ongoing relationship with you (e.g., where you are a customer, a member of the reward program, or you are lawfully included in our mailing list and have not unsubscribed).
(b) your Personal Information is necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Information is included in a contract between us and your employer, and we have a legitimate interest in processing that information for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Information)
plus: the duration of:(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Information, or to which your Personal Information is relevant);
(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Information that is relevant to that claim),
and: in addition, if any relevant legal claims are brought, we continue to Process Personal Information for such additional periods as is necessary in connection with that claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our processing of your Personal Information to storage of, and maintaining the security of, that information, except to the extent that the information needs to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
permanently delete or destroy the relevant Personal Information; or
anonymize the relevant Personal Information.
Your legal rights
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Information:
The right not to provide your Personal Information to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services, if you do not provide us with your Personal Information – e.g., we might not be able to process your requests without the necessary details and you may not be able to fly with us without providing the necessary information)
The right to request access to, or copies of, your Relevant Personal Information, together with information regarding the nature, Processing, and disclosure of those Relevant Personal Information
The right to request rectification of any inaccuracies in your Relevant Personal Information
The right to request, on legitimate grounds:
o erasure of your Relevant Personal Information; or
o restriction of Processing of your Relevant Personal Information
The right to have certain Relevant Personal Information transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable
Where we Process your Relevant Personal Information on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases)
The right to lodge complaints regarding the Processing of your Relevant Personal Information with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Information:
The right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Information by us or on our behalf; and
The right to object to the Processing of your Relevant Personal Information by us or on our behalf for direct marketing purposes.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Information, please use the contact details provided in Section (T) below. Please note that:
- In some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights
- where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
For example, we may request:
- Your booking reference or flight numbers and dates
- Your frequent flyer number
- Your telephone recording details (identifier number, the number you call from, the number and option you dialed, the date and time of your call(s))
- A photocopy of your passport or a national ID, so that we can verify your identity
- Signed authority from the individual on whose behalf you are acting.
Cookies and similar technologies
Please be aware that we do sometimes send marketing communications that promote a third party’s products and services (for example, those of our business partners) as well as our own. To the extent required under applicable law, we may ask for your consent to receiving marketing communications from other members of our group or from third parties. We will at all times, respect your choice as to what communications you wish to receive and the methods by which these are sent.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances, we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, products, or services you have requested
If you are a registered user of ugandairlines.com, you can change your marketing preferences at any time by amending your profile online.
Details of Controllers
Please send your request to:Manager Commercial Systems & IT
Uganda National Airlines Company Limited.
Entebbe International Airport,
“App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information.
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“Controller” means the entity that decides how and why Personal Information is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
“EEA” means the European Economic Area.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Process”, “Processing” or“Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Information on behalf of the Controller (other than employees of the Controller).
“Profiling” means any form of automated processing of Personal Information consisting of the use of Personal Information to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Relevant Personal Information” means Personal Information in respect of which we are the Controller.
“Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or penalties, national identification number, or any other information that is deemed to be sensitive under applicable law.
“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
“Site” means any website operated, or maintained, by us or on our behalf