Effective Date: 01 Sept 2024

Introduction
Fly Fairly PTE. LTD. ("Fly Fairly," "we," "us," or "our"), located at 160 Robinson Road #14-04, Singapore (068914), is dedicated to safeguarding your personal data. We process your personal data in accordance with the General Data Protection Regulation (GDPR), the Singapore Personal Data Protection Act (PDPA), and other applicable data protection laws. This Privacy Policy outlines what information we collect, how we use it, and your rights regarding this data. This policy applies to all personal data collected and used by Fly Fairly.
Data We Collect and How We Use It
Fly Fairly collects your personal data directly from you to provide the services and products you request.
This includes:
  • Identifying Information: Name, surname, date of birth, passport details.
  • Contact Information: Email address, telephone number.
  • Payment Information: Credit card details, including cardholder name, card number, and expiration date.
  • Travel Information: Special assistance needs, dietary requirements, booking changes, and sensitive information like medical conditions.
  • Communication Data: Emails, recorded calls, messages on online services, social media posts, feedback reviews.
We use this data for:
  • Processing your travel bookings and managing your account.
  • Communicating with you about your bookings and travel inquiries.
  • Providing travel confirmations and updates.
  • Enhancing and personalizing your customer experience.
  • Ensuring safety and compliance with regulatory requirements, including sharing necessary information with airport security and border control.
Legal Basis for Processing
We collect and process your personal data based on the following legal grounds:
  • Performance of a Contract: To fulfill our obligations when you make a booking with us.
  • Legal Obligation: To comply with legal requirements, such as immigration and customs regulations.
  • Legitimate Interests: For improving our services, fraud prevention, and ensuring security.
  • Consent: For marketing communications and processing sensitive personal data (e.g., medical conditions) when you have given explicit consent.
Sensitive Personal Data
When we collect sensitive personal data, such as medical conditions requiring special assistance, we do so only with your explicit consent and solely for the purpose of facilitating your travel needs.
Children's Privacy
Our services allow for the booking of tickets for minors and infants when made by an adult over the age of 18. However, our website and services are not directed at individuals under the age of 18, and we do not knowingly collect personal data directly from children under 18 without parental consent.
When booking tickets for minors or infants, we collect only the necessary information required for travel arrangements, and this information must be provided by an adult over 18 years of age. This adult is responsible for ensuring they have the right to provide this information on behalf of the minor or infant.
If we become aware that we have inadvertently collected personal data directly from a child under 18 without parental consent, we will promptly delete it. If you believe that we have collected personal information from a child under 18 without appropriate consent, please contact us immediately at [your contact information].
Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience on our website. Before placing non-essential cookies on your device, we will obtain your consent through a cookie consent banner. You can manage your cookie preferences at any time through your browser settings.
Our website employs Google Analytics with IP anonymization enabled to understand visitor behavior and optimize our services. No personally identifiable information is collected through this method. You can opt-out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
Third-Party Data Sharing
We may share your data with third-party suppliers who assist in operating our business and improving your customer experience. We ensure that these third parties comply with applicable data protection laws and have entered into Data Processing Agreements with us to safeguard your data.
International Data Transfers
Your personal data may be transferred to countries outside the European Economic Area (EEA) or your country of residence, which may have different data protection laws. When we transfer your data internationally, we use legally-provided mechanisms to safeguard data transfers, such as entering into Standard Contractual Clauses approved by the European Commission or ensuring the recipient is certified under the EU-U.S. Data Privacy Framework.
Joint Controllers
In certain instances, we may act as joint controllers with our partners or service providers for the processing of your personal data. We have agreements in place to determine our respective responsibilities for compliance with applicable data protection laws.
Marketing and Communication
Fly Fairly may send you marketing communications, including special offers, ticket sales, airline news, and promotional material from our partners. If you prefer not to receive such communications, you can opt out at any time by clicking the "unsubscribe" link in any marketing email. For more information, please view our Terms of Service.
Your Rights and Access to Information
You have the following rights regarding your personal data:
  • Right of Access: Obtain confirmation about whether your data is being processed and access your personal data.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure (Right to be Forgotten): Request deletion of your personal data under certain conditions.
  • Right to Restrict Processing: Request limitation of data processing under certain circumstances.
  • Right to Data Portability: Receive your personal data in a structured, commonly used format and transmit it to another controller.
  • Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
  • Right to Withdraw Consent: Withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to Lodge a Complaint: File a complaint with a supervisory authority if you believe your rights have been violated.
To exercise any of these rights, please contact our Customer Service Team via our contact page. We will respond to your request within the time frame required by applicable law.
Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, firewalls, and access controls. While we strive to protect your data, we cannot guarantee absolute security due to inherent risks associated with internet communications.
Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The retention period may vary depending on the type of data and legal requirements.
Data Controller Information
Fly Fairly PTE. LTD. is the data controller responsible for processing your personal data as described in this Privacy Policy.
Data Protection Officer (DPO)
If you have any questions or concerns about our data protection practices, you can contact our Data Protection Officer at:
  • Email: help@flyfairly.com
  • Address: 160 Robinson Road #14-04, Singapore (068914)
Legal Disclosures
We may disclose your personal data when required to do so by law or in response to valid requests by public authorities (e.g., court orders, government regulations).
Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any external sites you visit.
Changes to This Policy
We may update this Privacy Policy from time to time. For significant changes that affect your rights, we will notify you via email or a prominent notice on our website before the changes take effect. Where required by law, we will obtain your consent for material changes. The updated effective date will be posted at the top of the policy.
Data Breach Notification
In the unlikely event of a data breach that may compromise your personal data, we will notify you and the relevant supervisory authorities promptly, as required by applicable law.
Consent Withdrawal
You may withdraw your consent for processing activities where consent is the legal basis at any time by contacting us via our contact page.
Rights to Lodge a Complaint
If you believe that we have violated your data protection rights, you have the right to lodge a complaint with a supervisory authority in your country of residence or where the alleged infringement occurred.
Purpose Limitation and Data Minimization
We collect and process personal data solely for the purposes stated in this Privacy Policy. We adhere to the principles of data minimization, ensuring that we only collect data that is necessary for these purposes.
ATOL Disclaimer
Please note that Fly Fairly is not ATOL protected. This means that any bookings made through our platform are not covered by the ATOL scheme, and you will not receive the financial protection that the scheme provides. We advise customers to ensure they have adequate travel insurance and understand the terms and conditions of their bookings.
If you have any questions or concerns about your booking, please contact our customer support team for assistance.
Microsoft
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement
Contact Us
If you have any questions about our privacy policy, practices, or your interactions with Fly Fairly, please contact us via our contact page.
Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on our website with the updated effective date. We encourage you to review this policy periodically to stay informed about how we are protecting your data.