Policy & Terms
Terms and Conditions for Booking on Beijing Capital Airlines Global Website
You are welcome to purchase tickets on the website of Beijing Capital Airlines! In order to define the rights and obligations of both parties, please read carefully all of the terms and conditions of this notice. Please do not proceed with the online purchase until you have agreed to all the terms and conditions hereof. Beijing Capital Airlines is not liable for the online behavior and actions outside of these terms and conditions.
This Privacy Policy will help you understand the following:
1. How we collect and use your personal information
2. How we use cookies and similar technologies
3. How we share, transfer, and publicly disclose your personal information
4. How we protect and store your personal information
5. Your rights
6. Protection of minors' information
7. Criminal records information
8. Data protection impact assessments(DPIA)
9. Documentation and records
10. Data breaches
11. How your personal information is transferred globally
12. How we update this policy
13. How to contact us
This Privacy Policy applies to products or services made available to you by Beijing Capital Airlines such as bookings, passenger and baggage transportation, etc. It is important to note that this privacy policy does not extend to products and services offered by third parties.
Before using Beijing Capital Airlines products or services, please ensure you have carefully read and understood this policy. If you have any questions, comments or suggestions on the content of this policy, you may contact us through our customer service hotline, or via email at JD-DPO@jdair.net
Personal information refers to various information recorded electronically or otherwise that can be used alone or in combination with others to identify a natural person or reflect the activity of a natural person.
Sensitive personal information (SPI or PII) refers to the personal information, if breached, illegally provided or abused, may endanger the safety of people and property, and can easily result in damages to personal reputation, physical and/or mental health, or discriminatory treatment.
Personal information deletion refers to the action for deleting personal information from the system that is used for daily business, in order to the information can not be visited and retrieved.
We collect and use your personal information for the purposes described in this policy:
(1) You must authorize us to collect and use your personal information.
Our products and/or services consist of some core features, including those necessary for seat reservation, ticket purchase and passenger transportation, and those necessary to improve our products and/or services and to secure transactions. We may collect, store, and use the following information about you to achieve these features. If you do not provide the relevant information, you will not be able to enjoy the products and/or services we provide. The features include:
1. The booking of reservations and ticketing services
In order to complete your booking, you will need to provide the following information: name, gender, nationality, date of birth, type of valid travel document, ID number, ID expiration date, country of issuance, contact number and email address. If you are booking a flight via/to/from U.S. territory, you will also need to provide your residential address of origin and destination according to local regulatory requirements. In order to complete payment and ticketing, you will need to provide the following payment information: credit/debit card number, expiration date, CVV, billing address, cardholder name, mobile number, ID type, ID number. The above payment information is only used for the transaction in question and will not be stored.
The above information provided by you will continue to be authorized for use during your use of the services above. We will make no further use of the information and delete it, when you cancel your account.
2. Passenger and baggage transportation services
Your journey will be smoother if you allow yourself ample time to comply with Check-in time. When checking in at the airport, we need to check your valid travel documents to confirm that the information you used to purchase the ticket(s) is the same. In some cases, you will also be asked to provide payment information such as the credit card used for ticket purchase as part of verification procedures.
If you choose to use our self-service check-in counters, you will need to log into your account in advance. Otherwise, you will need to use your name, your ticket number or travel document number used to book your flights for self-service check-in. During the check-in process, we may need you to provide or verify your travel document information including: name, gender, nationality, date of birth, ID number, ID expiration date, country of issuance. If you are booking a flight via/to/from the U.S. territory, you will need to verify or provide information on the residential address of origin and destination as per local regulatory requirements.
3. Helping you become our members
In order to join our membership, you will need to provide your first name, last name, gender, phone number, email address, ID type, ID number and password. After such information has been supplied, we will provide you with a JD membership card number. The above-described information is sensitive information, and if you refuse to provide it, you may not be able to use our services normally.
When you cancel your account, we will make it anonymous or delete your personal information as soon as possible in accordance with applicable laws and regulations.
4. Providing additional and special services
If you require assistance for unaccompanied children or use of special services such as stretchers, we may ask you to provide additional personal information according to the type of service required: a disability or medical certificate, name and contact number of the pickup person/deliverer, ID number, etc.
The above information provided by you will continue to be used during your use of the services above. Upon termination of the services, we will delete your information as soon as practicable in accordance with applicable laws and regulations.
5. Customer service and after-sales function
Our customer service and after-sales function use your account and order information.
To ensure your account security, our call center customer service and online customer service center will use your account information to verify your identity. When you need us to provide customer service and after-sales support related to your order information, we will look into your order information. You may also provide additional information to our customer support staff, in situations such as making changes to shipping address, contact person or contact number.
6. Transaction security
To improve your system security when using our products and/or services and to prevent phishing scams and protect account security, we may access your browsing information, order information, commonly used software information and device information for the purpose of risk assessment. We will also determine your account risk by collecting your device information to analyze Beijing Capital Airlines system issues, gather statistical traffic, troubleshoot possible risks and to check when you choose to send us abnormal information.
(2) Exceptions to obtaining authorization for information collection
According to relevant laws and regulations, collecting your personal information in the following situations does not require your authorized consent:
1. Where information is relevant to national security and national defense security;
2. Where information is relevant to public safety, public health, and major public interests;
3. Where information is relevant to criminal investigation, prosecution, trial and execution;
4. When to protect the material and personal rights of another individual and it is difficult to acquire your consent.
5. Where the personal information collected has been disclosed to the public by yourself;
6. Where the personal information is legally and publicly disclosed information, such as news reports, government information disclosures, etc.;
7. When required to sign a contract according to your requirements and specifications
8. Where information is required to maintain safe and stable operation of the products and services provided (e.g., for the purpose of troubleshooting or problem-solving of our products and services)
9. Where the information is necessary for legitimate news reporting.
10.Where it is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and De-identify the personal information contained in the results when providing academic research or descriptive results to the public.
11. Where the information is otherwise required by laws or regulations
Should we stop operating Beijing Capital Airlines’ products or services, we will stop collecting your personal information in a timely manner and notify you of the notice of suspension either one by one or in an announcement, as well as delete or anonymize the personal information held.
(3) Obtaining your information from a third party
We may obtain personal information from a third party that you authorize to share and transfer your personal information (for example, your designated Fortune Wings Club beneficiaries, next-of-kin, traveling companion) to Beijing Capital Airlines for the reservation of ticket or service after you agree to this Privacy Policy. For example, you may book a flight ticket at Beijing Capital Airlines' flagship store or through an online agent on a third-party platform. 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) Rules for the use of your personal information
We use the personal information collected in accordance with the terms of this Privacy Policy and for the purpose of implementing our products and/or services. Please note that all personal information you provide when using our products and/or services, or personally sensitive information collected with your consent, will be continuously used by us during your use of our products and/or services unless you delete your account, revoke your consent or reject our collection through system settings. We will stop using and delete this information when you cancel your consent or your account.
We collect statistics on the use of our products and services and may share this information with the public or third parties to demonstrate the overall usage of our products and services. However, such statistics do not contain identifying information.
We will de-identify any personal information displayed in such manner, including the use of content replacement and anonymity to protect your information.
When we want to use your personal information or collect information for other purposes not specifically covered by this policy, we will ask you for your consent prior to any action.
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Statement.
(1) Sharing
We will not share your personal information with any company, organization or individual other than Beijing Capital Airlines, unless
1. Sharing with explicit consent: Upon your explicit consent, we will share your personal information with other parties. If required by law, we will inform and obtain your explicit consent before sharing your sensitive information.
2. Sharing under statutory circumstances: We may share your personal information in accordance with laws and regulations, litigation dispute resolution needs, or in accordance with the requirements of administrative and judicial authorities.
3. An increasing number of countries require incoming airlines to provide passenger information prior to landing. Generally speaking, such laws and regulations require airlines to provide information including passenger identifications and travel documents (passports and visas). Airlines must collect such data before the aircraft takes off. This collection process is increasingly completed through the technology called machine-readable zone (MRZ) used in new travel documents. Such data is collected solely for the purpose of informing authorities of the destination country, and the airline will not use such data beyond this purpose and will not retain such data after the end of your trip.
4. Sharing with Authorized Partners: For the purposes stated in this Privacy Policy, some of our services will be provided by us and our Authorized Partners. We may share some of your personal information with our partners to provide better customer service and user experience. For example, when you redeem your miles, we must share your personal information with the logistics service provider to arrange delivery or arrange for a partner to provide the service. We will only share your personal information for legitimate, necessary and specific purposes, and will only share the personal information necessary to provide the service. Our partners are not authorized to use shared personal information for other purposes unrelated to the product or service.
We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, and require them to process personal information, including personally sensitive information, in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.
(2) Transfer
We will not transfer your personal information to any company, organization or individual except in the following cases:
1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties. If required by law, we will notify you and obtain your explicit consent before transferring sensitive information.
2. In the event of a merger, acquisition or bankruptcy liquidation of the service provider, or other circumstances involving mergers, acquisitions or bankruptcy liquidation, if a personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Policy, otherwise we will require the company, organization and individual to obtain your consent again.
(3) Public disclosure
We will only publicly disclose your personal information in the following circumstances:
1. We may disclose your personal information publicly, with your explicit consent or based on your active choice;
2. In the case that your personal information must be provided in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information according to the type of personal information required and the method of disclosure. Subject to laws and regulations, when we receive the above request for disclosure, we will require legal documents, such as subpoenas or investigation letters, to be issued. We firmly believe that the information required to be provided should be as transparent as possible to the extent permitted by law. All requests are carefully reviewed to ensure they exposition is limited to data that is required for law enforcement and only that which is necessary for specific investigation purposes.
(4) Exceptions to requiring prior authorization of consent, sharing, transfer, and public disclosure of personal information
In the following cases, sharing, transferring, and publicly disclosing your personal information does not require prior authorization from you:
1. Where the information is relevant to national security and national defense security;
2. Where the information is relevant to public safety, public health and major public interest;
3. Where the information is relevant to criminal investigation, prosecution, trial and execution;
4. When to protect the material and personal rights of another individual and it is difficult to acquire your consent.
5. Where the personal information collected has been disclosed to the public by yourself;
6. Where the personal information is legally and publicly disclosed information, such as news reports, government information disclosures, etc.;
According to the law, the sharing and transfer of personal information that has been de-identified, with the condition that the data recipient cannot recover and re-identity the subject of personal information, do not apply to the sharing, transfer and public disclosure of personal information. Such sharing and transfer do not require additional notice or your consent.
(1) Our technology and measure to protect your personal information
We value personal information security and will take all appropriate and plausible security control measures to protect your personal information:
1. We have used industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and practicable steps to protect your personal information. For example, we use transport layer security protocol encryption technology and use a combination of strong cryptographic algorithms (such as ECDSA key agreement, AES256 channel encryption and other technologies) to ensure security during transaction transmission. For the storage of personal information data, industry-standard encryption technology is used to encrypt and store user personal information securely. Our access to stored data is logged and saved by relevant logs and centralized log collection and integrity monitoring ensures that log files are not tampered with. We also periodically perform internal and external security scans and penetration tests to ensure the safety of the production systems.
2. We have appointed a Data Protection Officer (DPO) to be responsible for and overlook the data protection and compliance operations within the company. We have also established a data security team to promote and protect personal information security. We regulate the collection, transmission, use and storage of personal information through established information security management systems. We signed the Non-disclosure Agreement with all members, requiring all personnel who may be exposed to personal information to perform their respective confidentiality obligations. Furthermore, we regularly train employees on proper information security and privacy protection measures to enhance employees’ awareness of the importance of protecting personal information.
3. The Internet is not an absolutely secure environment, and certain communication methods such as e-mail are not encrypted. We strongly recommend that you do not send personal information using such methods. Please use complex passwords to help us keep your account secure.
4. The Internet environment is not absolutely secure, but we will do our best to ensure the security of any information you send us. If our physical, technical, or administrative protective equipment is destroyed resulting in unauthorized access, public disclosure, alteration, or destruction of information, that result in damage to your legal rights, we will bear the corresponding legal responsibilities.
5. In response to possible risks such as leakage, damage and loss of personal information, we have formulated emergency measures. In the event of classified and categorized leakage of personal information, event reporting and disposal procedures are in place which a dedicated emergency response team. In the unfortunate event of personal information being at risk, we will promptly inform you in accordance with the requirements of laws and regulations: the current situation, the possible impact of the security incident, the disposal measures we have taken or will take, and how you can prevent and mitigate the risks autonomously, and any possible suggestions, remedies for you, etc. We will promptly inform you of the relevant circumstances of the incident by mail, letter, telephone, push notification, etc. When it is difficult to inform the affected parties individually, we will issue a notice in a reasonable and effective manner. If you find that your personal information has been leaked, please contact our customer service immediately so that we can take appropriate measures.
At the same time, we will also report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.
(2) Preservation of your personal information
We will take all reasonable and practicable steps to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period of time required to achieve the purposes stated in this Policy, unless an extension of the retention period is required or permitted by law. Your personal information will be deleted or anonymized after the retention period.
If we terminate service or operation, we will notify you at least 30 days in advance and delete or anonymize your personal information after termination of such service or operation.
1. Access and correct your personal information
In addition to laws and regulations, you have the right to access and correct your personal information at any time, including:
(1) Your browsing information:
You can access or clear your search history, view and edit interests, and manage other data. When using a computer, please clear your history through the browser you use.
(2) Please contact us if you need to access or correct other personal information that you may have provided us during the use of our products and / or services. We will respond to your request within the time period set forth in this Privacy Policy.
(3) Personal information that you cannot access and correct: There are some types of personal information that we are unable to provide you with access to for correction purposes. This is to enhance your own user experience and guarantee transactions. Such information includes your device information as collected by security and the personal information you filled out when you booked an additional service. The above information will be used with your authorization and you will not be able to access and correct it, but you can contact us to delete or de-identify it.
If you are unable to access this personal information via the above methods, you can always send an email to:
JD-DPO@jdair.net
We will respond to your request within 30 days.
2. Delete your personal information
Information that you can directly remove and delete from our product and service pages
In the following situations, you may ask us to delete your personal information:
(1) If we deal with personal information in violation of laws and regulations;
(2) If we collect and use your personal information without your consent;
(3) If our handling of personal information violates the agreement between us;
(4) If you cancel your Beijing Capital Airlines account;
(5) If we terminate the service and operation.
If we decide to respond to your removal request, we will also notify the entity from which we obtained your personal information and request that it be removed in a timely manner, unless otherwise required by laws and regulations, or if these entities obtain your independent authorization. When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but will delete it when the backup is updated.
3. Cancel the account
You can apply to cancel your account directly by calling our ticketing and service hotline +86 898 95375. After you cancel your account, we will stop providing you with products and / or services and delete your personal information as you request, unless otherwise stipulated by laws and regulations.
4. If you do not want to accept the promotional information we send you, you can cancel at any time by:
(1) Please inform us if you wish to not receive promotional information, send an email to JD-DPO@jdair.net at any time thereafter to prevent data processing activities.
(2) We will work with third-party platforms or media ("platforms") to recommend personalized products based on your personal information. Such personal information includes things such as shopping on this website, access to affiliate websites, and hobbies you filled out in your account settings. The platform only provides us with a window to display merchandise, and the link to the window’s content is Beijing Capital Airlines’ personalized product display information. However, these windows are maintained by Beijing Capital Airlines and we do not provide any personal information to advertisers. If you are unwilling to accept Beijing Capital Airlines' recommended service on a single platform, please contact the platform to close. You know and understand that the platform is an autonomous entity and that Beijing Capital Airlines cannot manage it.
(3) In order to protect your privacy, we will not send you any promotion or product information related to religious beliefs, sexuality, diseases and other sensitive content.
(4) In response to your requests above
For security reasons, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will respond within 30 days. We do not charge a fee for your reasonable request, but we will charge a certain fee for repeated requests that exceed the reasonable limit. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others, or are very unrealistic.
In the following situations, we will not be able to respond to your request as required by law or regulation:
1. Request directly related to national security and national defense security;
2. Request directly related to public safety, public health, and major public interest
3. Requests directly related to criminal investigation, prosecution, trial and judgment execution;
4. There is sufficient evidence that you have subjective malice or abusing rights;
5. Responding to your request will result in serious damage to the legitimate right and interests of you or other individuals or organizations.
6. Requests involving trade secrets.
1. Beijing Capital Airlines considers the protection of personal information of minors to be of great importance and necessity. If you are under the age of 18, you should obtain an explicit consent from your parent or legal guardians before using our products and/or services. Beijing Capital Airlines protects the personal information of minors in accordance with relevant local laws and regulations.
2. For the collection of personal information of a minor with the consent of the parent or legal guardian, we will only use or publicly disclose such information if it is permitted by law, the parent or guardian expressly agrees, or for the purpose of protecting the minor.
3. If a minor has provided us with personal information without the consent of the parent or guardian, the parent or guardian may send an email to JD-DPO@jdair.net to remove this information.
We do not process criminal records information unless required to do so by relevant government authorities (for example, for immigration and security purposes) and under the control of the relevant official authority or authorities.
Where processing is likely to result in a high risk to an individual’s data protection rights, we will, before commencing the processing, carry out a DPIA to assess:
1. whether the processing is necessary and proportionate in relation to its purpose.
2. the risks to individuals.
3. what measures can be put in place to address those risks and protect personal information.
We will keep written records of processing activities which are high risk (for example, which may result in a risk to individuals’ rights and freedoms or involve sensitive personal information or criminal records information), including:
(1) the name and details of the employer’s organization (and where applicable, of other controllers, the employer's representative and DPO);
(2) the purposes of the processing;
(3) a description of the categories of individuals and categories of personal data;
(4) categories of recipients of personal data;
(5) details of cross-border transfers, including documentation of the transfer mechanism safeguards in place;
(6) where possible, retention schedules; and
(7) where possible, a description of technical and organizational security measures.
As part of our record of processing activities we document, or link to documentation, on:
(1) information required for privacy notices;
(2) records of consent;
(3) controller-processor contracts;
(4) the location of personal information;
(5) DPIAs;
(6) records of data breaches.
If we process sensitive personal information or criminal records information, we will keep written records of:
(1) the relevant purpose(s) for which the processing takes place, including (where required) why it is necessary for that purpose;
(2) the lawful basis for our processing; and
(3) whether we retain and erase the personal information in accordance with our policy documents (including this Policy) and, if not, the reasons for not following our policy.
We will conduct regular reviews of the personal information we process and update our documentation accordingly. This may include:
(1) carrying out information audits to find out what personal information the Company holds;
(2) distributing questionnaires and talking to staff across the Company to get a more complete picture of our processing activities; and
(3) reviewing our policies, procedures, contracts and agreements to address areas such as retention, security and data sharing.
1. A data breach may take many different forms, for example:
(1) loss or theft of data or equipment on which personal information is stored;
(2) unauthorized access to or use of personal information either by a member of staff or third party;
(3) loss of data resulting from an equipment or systems (including hardware and software) failure;
(4) human error, such as accidental deletion or alteration of data;
(5) unforeseen circumstances, such as a fire or flood;
(6) deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and
(7) ‘blagging’ offences, where information is obtained by deceiving the organization which holds it.
2. In the event of a data breach, the Company will act in accordance with its Data Breach Disclosure Plan without undue delay.
Generally, the personal information we collected is done so and stored within the territory of the People’s Republic of China.
Your personal information may be transferred outside of your country for the purposes of supporting your booking, payment, and other services related to our core business. The purpose of processing such personal information is detailed in “1. How we collect and use your personal information” as described in the first clause of this Policy. Additionally, your information may be processed by Beijing Capital Airlines employees working outside of your country. Our service providers are also involved in the processing of such information. Together with Beijing Capital Airlines, our service providers provide network reservation engine services, computer reservation system services, online payment management services and email services.
Beijing Capital Airlines will take all necessary and reasonable measures to ensure that your personal information is always safe. We will transfer your personal information in accordance with all relevant legal requirements. For example, we will seek your consent when necessary to transfer personal information across borders or implement security measures such as data de-identification prior to cross-border data transfer.
The transfer of personal data from EU/EEA to third countries without an adequacy decision by European Commission requires the standard contractual clauses approved by the European Commission, mechanisms such as appropriate privacy protection certificates, or binding company rules.
Our Privacy Policy is subject to change. We will post any changes to this policy on this page.
For significant changes, we also provide more prominent notices (including for certain services, we will send an email notifying the specific changes to the privacy policy).
Significant changes to our Privacy Policy include, but are not limited to, the following:
1. Our service model significantly changes in relation to the purposes of processing personal information, the types of personal information being processed, the ways in which personal information are used, etc.;
2. We have undergone major changes in the ownership structure and organizational structure, including changes of ownership caused by business adjustments, bankruptcy, insolvency, mergers, etc.;
3. If our main objective for personal information sharing, transfer or public disclosure have changed;
4. If there have been significant changes in your rights to participate in the processing of personal information, and how it is exercised;
5. When our department responsible for personal information security, and the contact information and complaint channels change;
6. The personal information security impact assessment report indicates that there is a high risk.
Please contact us if you have any issues regarding our Privacy Policy, including questions on exercising your rights, any enquiries or complaints, opting-out of direct marketing information, or have any questions about the processing of your personal information. Please do so by contacting our Personal Information Protection professional and we will respond to your request within 1 month.
Data Protection Officer
Email: JD-DPO@jdair.net
Address:Capital Airlines Building, NO.3, North Cargo Road, Beijing Capital International Airport, 100621
EU Representative
Email: JD-DPO@jdair.net
Beijing Capital Airline General Conditions of
International Carriage for Passengers and Baggage
Article 1 Definitions
Article 2 Scope of Use
Article 3 Tickets
Article 4 Fares and Fees
Article 5 Reservations
Article 6 Check-in and Boarding
Article 7 Carriage Refusals and Restrictions
Article 8 Baggage
Article 9 Schedule, Delays, Cancellation of Flights
Article 10 Ticket Changes
Article 11 Refund
Article 12 Conduct aboard Aircraft
Article 13 Common service
Article 14 Additional Service Arrangements
Article 15 Administrative Formalities
Article 16 Liabilities and Limitations
Article 17 Other Provisions
Cookies: Personalized surfing
To ensure that our service is as
userfriendly as possible we use so-called cookies and web beacons.
A “cookie” is a small text file which a webserver (for example the http://intl.jdair.net/ webserver) sends to your browser when you visit a
website. So-called “session cookies” expire at the end of the browser session
and can capture your activities during the browser session. In contrast to
these, there are “permanent cookies” which are saved on your terminal and these
are able to capture your settings or activities on multiple websites.
Web beacons are small graphic data (also known as ‘Pixel Tags’ or ‘Clear
GIFs’), which can be included in our websites, apps, applications and
newsletters and are usually used in combination with cookies to identify users
and user behavior. The above mentioned statements about cookies apply
accordingly for web beacons; web beacons will in particular not be used in case
you objected to the use of the relevant cookie.
Cookies pose no risk to your computer, as they are simply text files and not
executable programs.
The cookies on the Beijing Capital Airlines website (http://intl.jdair.net/ ) are used both to ensure convenient
browsing and for market research and advertising purposes, as well as to
collect statistics on use. We also use cookies for the purpose of web tracking,
and they form the basis of your personalized content.
Besides so-called “session cookies” which are deleted when you end your browser
session, we put in place permanent cookies. Cookies are stored until deleted by
the user. No personal data is stored in the cookies used by us.
It depends on your browser’s settings as to whether the cookie file is stored
or deleted. If the file is stored, our webserver can recognize your terminal.
Next time you visit the site or when you switch between functions requiring you
to enter a pass-word, the cookie can save you re-entering information. This is
how cookies make it easier for you to use websites requiring user input.
Additionally, cookies can help us offer you the most personalized, optimized
surfing experience, as long as you give us permission to do so.
That is unless you explicitly reject cookies and deactivate them as set out
below:
You can set your browser either to receive our cookies or use our website
without cookie functionality. In the latter case however your text entries in
our form fields cannot be saved for future searches, and you will have to input
your data again when you next visit our website. In this case we will also
unfortunately not be able to present personally tailored content to you.
Your browser may already be set to display a warning whenever it receives a
cookie. As the identification cookie must be resent every time an individual
page on our website is opened, this warning can be very disruptive. We
therefore recommend that you set your browser to always accept cookies from http://intl.jdair.net/ . You can change this setting for individual websites.
You can find more information on the use of cookies and on how to deactivate
cookies at www.meine-cookies.org or www.youronlinechoices.com
Irrespective of saved cookies, for security reasons you must still log in each
time you access areas of our site that require registration.
Beijing Capital Airlines also includes the data contents of third parties at http://intl.jdair.net/ . These third party providers can set cookies, while you
visit http://intl.jdair.net/ and in doing so can, for example, get the
information that you called up on http://intl.jdair.net/ . Please visit the websites of third
party providers, to get further information on their use of cookies. If you
have decided fundamentally not to provide or to revoke your consent
(deactivation of cookies) for the use of cookies, which are subject to
approval; you will only be able to use those features on our website that are
guaranteed not to use cookies.
BEIJING CAPITAL AIRLINES COMPANY LIMITED
DATA PROTECTION POLICY /
(FOR COMPLIANCE WITH THE GDPR)
As of 15 June 2018
|
1. Introduction
1.1 This Policy gives important information about:
1.1.1 the data protection principles with which Beijing Capital Airlines 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 the requirements of other relevant laws and regulations of other countries and regions; 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. This Policy may be provided to you using a number of methods, including through the use of any of our websites, through the use of any of our mobile applications, through the use of telephone, or in-person at any of our retail locations.
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.
1.7 The Company’s Data Protection Officer has overall responsibility for addressing all issues relating to the protection of your personal information, and is responsible for assisting us in monitoring internal compliance, informing and advising on our data protection obligations and acting as a contact point for you and any supervisory authority. If you have any questions or comments about the content of this Policy or if you need further information, you can contact the following persons:
1.7.1 The Company's Data Protection Officer: [ JD-DPO@jdair.net]; or
1.7.2 The Company's EU representative: [JD-DPO@jdair.net].
2. Definitions
"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. PRIVACY NOTICE
4.1 The Company may supplement this Policy by issuing 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 booking tickets, redeeming points for tickets, purchasing points, or 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.
4.3.3 We do not collect personal information from persons under the age of 16 without prior permission from a parent or a guardian. If you believe that we have accidentally collected personal information from a person under the age of 16 without the prior permission of a parent or guardian, please contact our Data Protection Officer at once under paragraph REF _Ref514850248 \r \h \* MERGEFORMAT 1.7 of this Policy in order to have the relevant personal information erased. If you are under the age of 16, please do not proceed to provide us with any of your personal information through any means whatsoever unless you have first procured permission from your parent or your guardian.
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, delivery addresses and usernames;
(b) billing information such as billing address, bank card information and credit card information;
(c) unique information such as nationality and identity document information (including but not limited to identity card numbers, passport numbers, photographs and date of birth), occupational duties, health status and meal preferences;
(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 designated Fortune Wings Club beneficiaries, next-of-kin, traveling 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; including but not limited to:
l selling flight tickets, flight ticket and hotel packages, in-flight merchandise, etc.
l sending you product or service booking confirmations
l providing you with flight-related services, such as check-in, meals, seat selection, luggage services, transit accommodation, irregular flight guarantees and special passenger services
l providing notifications and instructions related to products or services during your journey, such as instructions about boarding gates and baggage collection
(b) to provide you with any assistance that you have requested; including but not limited to:
l related enquiries or information confirmation operations that you have authorized us to carry out
l responding to your enquiries
l assisting you with transaction operations
l providing you with technical assistance
(c) to maintain and improve our customer relationship with you; including but not limited to:
l inviting you to join the Fortune Wings Club
l inviting you to participate in various satisfaction surveys
(d) to establish your identity; including but not limited to:
l requesting that you present the relevant documents during check-in, boarding, baggage inspection and other procedures
l informing you about login activity on your online account
l requesting that you present the relevant documents when proceed with membership affair
(e) to administer and process any payments (including refunds) related to products, services and/or facilities or other commercial transactions requested by you; including but not limited to:
l making order payments
l handling your refund requests
l fulfilling our compensation obligations
(f) to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings between us;
(g) 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; including but not limited to
l sending you event invitations
l delivering or distributing prizes to you
(h) 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;
(i) to administer our loyalty or rewards programmes, including the use of airport lounges and the administration of the Fortune Wings Club;
(j) to engage in codesharing or similar business arrangements with other airlines;
(k) to cater to your dietary requirements when using our products, services and/or facilities;
(l) for internal administrative purposes and record-keeping;
(m) to send you seasonal greetings messages from time to time;
(n) to send you service or account change notifications and information when necessary;
(o) to monitor, review and improve our products, services, facilities, promotions and/or events; including but not limited to:
l cookies used by our websites and apps
l traffic analysis and performance monitoring tools used by our websites and apps
(p) 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;
(q) to process, combine and/or analyse your personal information for the above purposes;
(r) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(s) for our audit, risk management and security purposes;
(t) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(u) to transfer or assign our rights, interests and obligations under any agreements entered into with us;
(v) 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");
(w) 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.
4.5.3 Please note that you have the right to object to the processing of your personal data for direct marketing purposes and the right to opt-out of any direct marketing from us and to unsubscribe from any SMS, phone, email, fax, mail, instant messaging, social media and/or other communication channels we use to engage in direct marketing with you. We will endeavour to provide instructions in all such communications on how to opt-out, but you may also contact our Data Protection Officer under paragraph REF _Ref514850248 \r \h \* MERGEFORMAT 1.7 of this Policy if you wish to exercise your right to opt-out and are not clear how to exercise such right accordingly.
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 REF _Ref515050598 \r \h \* MERGEFORMAT 4.5 of this Policy. Examples of third parties to whom we may disclose your personal information include:
(a) other companies in our group, such as our sister airlines, for the purposes of paragraphs REF _Ref515632747 \r \h \* MERGEFORMAT 4.5.1(a), REF _Ref515632749 \r \h \* MERGEFORMAT 4.5.1(b), REF _Ref515632754 \r \h \* MERGEFORMAT 4.5.1(i), REF _Ref515632976 \r \h \* MERGEFORMAT 4.5.1(j) and REF _Ref516504741 \r \h \* MERGEFORMAT 4.5.1(k).
(b) 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, catering, delivery, assembly, installation, printing and postal services, credit checks, credit facilities or services relating to marketing and promotional activity; including but not limited to:
l providers of related supplementary services, such as hotels, insurance companies, logistics companies, food supply companies and sales product suppliers
l other airlines, such as codesharing partners and mutual sales partners. Please note: Other airlines have their own privacy policies. If your travel plan includes traveling with other airlines, we recommend that you check the other policies, as they may differ from this Privacy Policy
l information technology providers, such as TravelSky, Amadeus and Google
(c) our professional advisors, consultants and/or auditors; and
(d) relevant government regulators or authorities (in accordance with any Applicable Law). Including but not limited to:
l public security agencies (such as the National Civil Aviation Public Security Big Data Operation & Training Center) to which we submit personal information for screening in the interests of public safety and anti-terrorism
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.
4.7 Transfer of personal information of EEA data subjects out of the EEA
4.7.1 Due to the global nature of the services that we provide, it is sometimes necessary for us to share the personal information of data subjects in the EEA with parties outside the EEA, for example:
(a) with our offices outside the EEA;
(b) with our service providers located outside the EEA;
(c) if the data subject is based outside the EEA; or
(d) where there is an international dimension to the services we are providing to the data subject.
4.7.2 These transfers are subject to special rules under European data protection law.
4.7.3 The Company may transfer personal information outside the EEA to:
(a) a country, territory or organisation that is designated as having an adequate level of protection; or
(b) an organisation receiving the information that has provided adequate safeguards by way of binding corporate rules, standard data protection clauses or compliance with an approved code of conduct.
4.7.4 In the absence of a European Commission adequacy decision, or of appropriate safeguards, we may need to transfer personal information of an EEA data subject to non-EEA countries where this is necessary for the performance of a contract or the implementation of pre-contractual measures.
4.7.5 There may also be circumstances where we ask for the explicit consent of an EEA data subject to the transfer of personal information to a non-EEA country for purposes other than the performance of a contract or the implementation of pre-contractual measures. In such circumstances, we will inform the data subject of the increased risks of such transfer due to the absence of safeguards and the fact that these non-EEA countries (for example, the People's Republic of China) do not have the same data protection laws as the EEA.
4.7.6 We will, however, ensure that all transfers of personal information of EEA data subjects out of the EEA comply with the GDPR. Our practice is, wherever possible and applicable, to use standard data protection contract clauses that have been approved by the European Commission. Those clauses are available on the following website of the European Commission:
4.7.7 If you would like further information please contact the Data Protection Officer as shown at paragraph REF _Ref515052361 \r \h \* MERGEFORMAT 1.7 of this Policy.
5. Basis for processing personal information
5.1 In relation to any processing activity we will, before the processing starts for the first time, and then regularly while it continues:
5.1.1 review the purposes of the particular processing activity, and select the most appropriate lawful basis (or bases) for that processing, i.e.:
(a) that the data subject has consented to the processing;
(b) that the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
(c) that the processing is necessary for compliance with a legal obligation to which the Company is subject;
(d) that the processing is necessary for the protection of the vital interests of the data subject or another natural person; or
(e) that the processing is necessary for the purposes of legitimate interests of the Company or a third party, except where those interests are overridden by the interests of fundamental rights and freedoms of the data subject – see paragraph REF _0d4b6653-f507-44fe-8d13-efc1afb19aa4 \d " " \h \n \* MERGEFORMAT 5.2 of this Policy.
5.1.2 except where the processing is based on consent, satisfy ourselves that the processing is necessary for the purpose of the relevant lawful basis (i.e. that there is no other reasonable way to achieve that purpose);
5.1.3 document our decision as to which lawful basis applies, to help demonstrate our compliance with the data protection principles;
5.1.4 include information about both the purposes of the processing and the lawful basis for it in our relevant privacy notice(s);
5.1.5 where sensitive personal information is processed, also identify a lawful special condition for processing that information (see paragraph REF _95b75374-01d5-4ee4-9718-756282ae9668 \d " " \h \n \* MERGEFORMAT 6.2.2 of this Policy), and document it; and
where criminal offence information is processed, also identify a lawful condition for processing that information, and document it.
5.2 When determining whether the Company’s legitimate interests are the most appropriate basis for lawful processing, we will:
5.2.1 conduct a legitimate interests assessment ("LIA") and keep a record of it, to ensure that we can justify our decision;
5.2.2 if the LIA identifies a significant privacy impact, consider whether we also need to conduct a data protection impact assessment ("DPIA");
5.2.3 keep the LIA under review, and repeat it if circumstances change; and
5.2.4 include information about our legitimate interests in our relevant privacy notice(s).
6. Sensitive personal information
6.1 Sensitive personal information is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal data’ (e.g. information about your health status).
6.2 The Company may from time to time need to process sensitive personal information. We will only process sensitive personal information if:
6.2.1 we have a lawful basis for doing so as set out in paragraph REF _867f06a5-8e14-44da-b591-08c13febe99b \d " " \h \n \* MERGEFORMAT 5.1.1 above, for example, it is necessary to comply with the Company’s legal obligations or for the purposes of the Company’s legitimate interests; and
6.2.2 one of the special conditions for processing sensitive personal information applies, for example:
(a) the data subject has given explicit consent; including but not limited to:
l when you request special passenger services from us, such as for passengers with wheelchairs or passengers requiring a stretcher
l when you request refunds from us
(b) the processing is necessary for the purposes of exercising the employment law rights or obligations of the Company or the data subject;
(c) the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent;
(d) processing relates to personal data which are manifestly made public by the data subject;
(e) the processing is necessary for the establishment, exercise or defence of legal claims; or
(f) the processing is necessary for reasons of substantial public interest.
6.3 Before processing any sensitive personal information, our staff shall notify the Data Protection Officer of the proposed processing, in order that the Data Protection Officer may assess whether the processing complies with the criteria noted above.
6.4 Sensitive personal information will not be processed until:
6.4.1 the assessment referred to in paragraph REF _bbb8b8ef-d1e8-4949-8fc2-8ef2623b34c9 \d " " \h \n \* MERGEFORMAT 6.3 has taken place; and
6.4.2 the individual has been properly informed (by way of a privacy notice or otherwise) of the nature of the processing, the purposes for which it is being carried out and the legal basis for it.
6.5 During the recruitment process: the HR department, with guidance from the Data Protection Officer as necessary, will ensure that (except where the law permits otherwise):
6.5.1 during the short-listing, interview and decision-making stages, no questions are asked relating to sensitive personal information, such as race or ethnic origin, trade union membership or health;
6.5.2 if sensitive personal information is received, for example, the applicant provides it without being asked for it within his or her resume or during the interview, no record is kept of it and any reference to it is immediately deleted or redacted;
6.5.3 any completed equal opportunities monitoring form is kept separate from the individual’s application form, and not be seen by the person shortlisting, interviewing or making the recruitment decision;
6.5.4 ‘right to work’ checks are carried out before an offer of employment is made unconditional, and not during the earlier short-listing, interview or decision-making stages;
6.5.5 we will only ask health questions once an offer of employment has been made.
7. Criminal records information
7.1 We do not process criminal records information unless required to do so by relevant government authorities (for example, for immigration and security purposes) and under the control of the relevant official authority or authorities.
8. Data protection impact assessments (DPIA)
8.1 Where processing is likely to result in a high risk to an individual’s data protection rights, we will, before commencing the processing, carry out a DPIA to assess:
8.1.1 whether the processing is necessary and proportionate in relation to its purpose;
8.1.2 the risks to individuals; and
8.1.3 what measures can be put in place to address those risks and protect personal information.
9. Documentation and records
9.1 We will keep written records of processing activities which are high risk (for example, which may result in a risk to individuals’ rights and freedoms or involve sensitive personal information or criminal records information), including:
9.1.1 the name and details of the employer’s organisation (and where applicable, of other controllers, the employer's representative and Data Protection Officer);
9.1.2 the purposes of the processing;
9.1.3 a description of the categories of individuals and categories of personal data;
9.1.4 categories of recipients of personal data;
9.1.5 details of cross-border transfers, including documentation of the transfer mechanism safeguards in place;
9.1.6 where possible, retention schedules; and
9.1.7 where possible, a description of technical and organisational security measures.
9.2 As part of our record of processing activities we document, or link to documentation, on:
9.2.1 information required for privacy notices;
9.2.2 records of consent;
9.2.3 controller-processor contracts;
9.2.4 the location of personal information;
9.2.5 DPIAs; and
9.2.6 records of data breaches.
9.3 If we process sensitive personal information or criminal records information, we will keep written records of:
9.3.1 the relevant purpose(s) for which the processing takes place, including (where required) why it is necessary for that purpose;
9.3.2 the lawful basis for our processing; and
9.3.3 whether we retain and erase the personal information in accordance with our policy documents (including this Policy) and, if not, the reasons for not following our policy.
9.4 We will conduct regular reviews of the personal information we process and update our documentation accordingly. This may include:
9.4.1 carrying out information audits to find out what personal information the Company holds;
9.4.2 distributing questionnaires and talking to staff across the Company to get a more complete picture of our processing activities; and
9.4.3 reviewing our policies, procedures, contracts and agreements to address areas such as retention, security and data sharing.
10. Rights in Relation to Personal Information
10.1 All data subjects have the following rights in relation to their personal information:
10.1.1 to be informed about how, why and on what basis that information is processed – see paragraph REF _Ref515052146 \r \h \* MERGEFORMAT 4 of this Policy regarding the Company’s privacy notices;
10.1.2 to obtain confirmation that your information is being processed and to obtain access to it and certain other information, by making a subject access request – see paragraph REF _Ref515052400 \r \h \* MERGEFORMAT 10.3 below;
10.1.3 to have data corrected if it is inaccurate or incomplete;
10.1.4 to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
10.1.5 to restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but the data subject does not want the data to be erased); and
10.1.6 to restrict the processing of personal information temporarily where you do not think it is accurate, or where you have objected to the processing.
10.2 If you wish to exercise any of the rights in paragraph REF _Ref515052287 \r \h \* MERGEFORMAT 10.1 above, please contact the Data Protection Officer as shown at paragraph REF _Ref515052361 \r \h \* MERGEFORMAT 1.7 of this Policy.
10.3.1 The Company will seek to comply with subject access requests and to provide the appropriate data within one month of a request being made. Where this isn't possible, the data subject will be kept informed. The Company may take professional advice about how to comply with any request, to ensure that appropriate information is provided. Usually there will be no charge for providing the information.
10.3.2 In the unlikely event of manifestly unfounded or repetitive requests, the Company may decide not to provide information. However professional advice will be taken in those circumstances.
11. Information security
11.1 The Company will use appropriate technical and organisational measures to keep personal information secure, and in particular to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. These may include:
11.1.1 making sure that, where possible, personal information is pseudonymised or encrypted;
11.1.2 ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
11.1.3 ensuring that, in the event of a physical or technical incident, availability and access to personal information can be restored in a timely manner; and
11.1.4 a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
11.2 Where the Company uses external organisations to process personal information on its behalf, additional security arrangements will need to be implemented in contracts with those organisations to safeguard the security of personal information. In particular, contracts with external organisations will provide that:
11.2.1 the organisation may act only on the written instructions of the Company;
11.2.2 those processing the data are subject to a duty of confidence;
11.2.3 appropriate measures are taken to ensure the security of processing
11.2.4 sub-contractors are only engaged with the prior consent of the Company and under a written contract;
11.2.5 the organisation will assist the Company in providing subject access and allowing individuals to exercise their rights in relation to data protection;
11.2.6 the organisation will assist the Company in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments;
11.2.7 the organisation will delete or return all personal information to the Company as requested at the end of the contract; and
11.2.8 the organisation will submit to audits and inspections, provide the Company with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell the Company immediately if it is asked to do something infringing data protection law.
12.retention of personal information
12.1 Personal information (and sensitive personal information) should not be retained for any longer than necessary. The length of time over which data should be retained will depend upon the circumstances, including the reasons why the personal information was obtained. In general, personal information will be retained as long as is necessary, or for 7 years after it is no longer in use, whichever is earlier.
12.2 Personal information (and sensitive personal information) that is no longer required will be deleted permanently from our information systems and any hard copies will be destroyed securely.
13. Data breaches
13.1 A data breach may take many different forms, for example:
13.1.1 loss or theft of data or equipment on which personal information is stored;
13.1.2 unauthorised access to or use of personal information either by a member of staff or third party;
13.1.3 loss of data resulting from an equipment or systems (including hardware and software) failure;
13.1.4 human error, such as accidental deletion or alteration of data;
13.1.5 unforeseen circumstances, such as a fire or flood;
13.1.6 deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and
13.1.7 ‘blagging’ offences, where information is obtained by deceiving the organisation which holds it.
13.2 In the event of a data breach, the Company will act in accordance with its Data Breach Notification Plan without undue delay.
14. CONTACT US
14.1 At any time, if you
14.1.1 have any complaints, grievances or comments regarding how we are handling your personal information or about our compliance with the GDPR or any other applicable data protection law; or
14.1.2 wish to revoke any consent you have previously given to us to use your personal information;
we welcome you to contact our Data Protection Officer and/or our EU Representative using the contact details provided under paragraph REF _Ref514850248 \r \h \* MERGEFORMAT 1.7 of this Policy. We will strive to deal with any complaints, grievances or comments that you may have speedily and fairly.
15. Privacy Policy amendment
Beijing Capital Airlines may amend this Privacy Policy from time to time. Use of the website, mobile site and mobile applications after the effective date of the amendments constitutes acceptance of the amended terms and conditions. We reserve the right to apply the amended terms to the information we have already collected, subject to any legal constraints. You should read and review this page regularly to see if there have been any changes.
Last updated: June 2018