General Customer Data Privacy Policy Statement

1. THE TYPES OF CUSTOMER DATA WE COLLECT:

The types of Customer Data that GO FIRST collect depend on the circumstances of collection and on the nature of the service requested or transaction undertaken.

There are two broad categories of Customer Data that GO FIRST collects:

A.  Personal Data. The data we collect includes but is not limited to:

1. Personal information that can be used to identify an individual, such as name, gender, date of birth, passport, or other personal identification numbers;
2. Contact information, such as mailing address, phone number, and email address;
3. Payment information, such as credit or debit card information, including the name of the cardholder, card number, billing address, and expiry date subject to the regularity authorities.
4. Travel information, such as ticket numbers, destinations, and flight information;
5. Information on your other purchases made through GO FIRST, such as tracking your purchases of chargeable seats, excess baggage, seat upgrades, etc. through the Website (as defined below), other linked travel arrangements;
6. Your customer preferences, such as dietary, seating, places that you would like to visit, or other service preferences;
7. Information about your interactions with our ground staff, such as the details of any complaint, incidences of lost / damaged baggage, call details, email communication, and other information relevant to assist our ground staff to service you;
8. Health information, such as doctors’ notes, medical certificates,
9. and letters and requests related to medical conditions;
10. Information we receive from  you on official social media channels and Website;
11. Information we receive from flight bookings made via our online booking platform;
12. Information we receive from other sources e.g. our official page and social media, mobile applications, chats, conversation, Websites; and
13. Business contact information, such as the contact details of the employees of our vendors and corporate customers, as well as the contact details collected by our divisions including the Cargo Division and Engineering Division. 

B. Technical Data. This includes device and technical information you give us when using our Website or mobile application (“Website”) such as IP addresses or other unique identifiers, like mobile carrier, time zone setting, operating system, platform, etc.

For purposes of this Privacy Policy statement, Customer Data means Personal Data and Technical Data.
We also use Customer Data to derive statistical data, such as the number of passengers. This is processed and stored purely for analytical purposes and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand GO FIRST's customer profile and improve GO FIRST's service offering.

C. Special categories of information or “sensitive personal data”

Certain categories of Customer Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or “sensitive personal data” under the General Data Protection Regulation (“GDPR”). Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your travel arrangements that reveal or suggest something about you that could be considered “sensitive personal data”, or if you otherwise choose to provide such information to us (or a third party such as the travel agent through which you made your booking). 

For example:

1. if you request a particular type of meal, e.g. halal or kosher meals, this may imply or suggest that you are a member of a particular religion; or
2. if you request specific medical assistance from us and/or an airport operator, e.g. the provision of a wheelchair, this may reveal that you have a particular medical condition.

D. How do we collect data from you?

GO FIRST collects Customer Data, either directly from you or from your authorized representatives (i.e. persons whom you have authorized and/or persons who have been validly identified as being your authorized representative (e.g. your organization’s corporate travel manager/agent) pursuant to our then-current security procedures). GO FIRST also collects Customer Data from third parties which are located in various countries. This includes, but is not limited to, travel agents (including, airlines and non-airlines), our service providers, or through our Website, inflight services, customer survey, any posts on GO FIRST specific pages on social media websites and other channels including our ticketing counters and airport operations.

Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to GO FIRST has authorized the disclosure, is informed of, and agrees to the provisions of this Privacy Policy.

2. IS THE PROVISION OF CUSTOMER DATA REQUIRED?

The collection of the following types of Customer Data is mandatory to enable GO FIRST to fulfill our contract of carriage with you. These types of Customer Data are marked as mandatory on our booking form. If you do not provide this information, we will not be able to provide you with our services and/or products required.

1. Passenger details, e.g. title, first/given name, last/family name, date of birth, meal type, nationality, and whether you are an EU resident.
2. Contact details, e.g. email address, mobile phone number, home number, or business number.
3. Payment details, e.g. the name on the credit or debit card, the credit or debit card number, expiry date, and card verification value on the credit or debit card and billing address will be transmitted to our payments processors subject to the regularity authorities.

Additional information may be mandatory if you are flying to a specific country, or if you are flying on behalf of a business registered in a specific country, e.g. your gender, nationality, passport number, the country of issue of your passport, the name, GST registration number and address of the business you are flying on behalf of, and your business email address and phone number. These mandatory fields will be clear when you make a booking.

These types of Customer Data are marked as mandatory on our sign up / enrolment form. If you do not provide this information, you will not be able to benefit from points accruals and membership tier benefits and we will not be able to provide you with our services and/or products required.

The failure to supply the following types of Customer Data will result in (i) GO FIRST being unable to update you on our latest products and/or launches; and/or (ii) your inability to enter or participate in contests, promotions, or redemption activities organized by GO FIRST.

1. Contact Information e.g. email address, telephone number; and
2. Country of residence.

3. HOW DO WE USE YOUR CUSTOMER DATA?

If you are an EU resident, we are required to disclose the legal basis for processing your data under the GDPR. We will use the Customer Data in the following ways:

A. In accordance with our contract of carriage with you, we will use the Customer Data to:

1. process and assist you with any transactions related to your booking (e.g., making a booking, providing services related to the booking (e.g., seat selection, accommodation, etc.), fulfilling such booking and investigating potential fraudulent transactions);
2. notify you about changes to our services, including through flight alert messages via GO FIRST’s mobile services facility;
3. facilitate airport, internet check-in, and self-check-in;
4. provide airport services such as processing information relating to connecting flights, arrangements at airports, and customs and immigration facilities;
5. provide baggage-related services such as processing of any baggage-related queries, including mishandled or missing baggage claims;
6. provide in-flight catering and other services (e.g. to provide you with a personalised inflight experience);

B. As it is in our legitimate interests to be responsive to you, to provide customized services and marketing, and to ensure the proper functioning of our products, services, and organisation, we will use your Customer Data to:

1. improve the Website and to ensure content from the Website is presented in the most effective manner for you and your device;
2. administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3. monitor and record calls for quality, training, legal compliance, analysis, and other related purposes in order to pursue our legitimate interest to improve service delivery;
4. send you surveys by post or email. You can opt out of receiving these surveys at any time by contacting us;
5. send you service emails, SMS, and WhatsApp message such as reminders when you have not checked out your purchases on our Website. You can opt out of receiving service emails at any time by contacting us;
6. respond to your inquiries, requests, or feedback;
7. enforce our terms, conditions, and policies;
8. allow you to participate in interactive features of the Website when you choose to do so;
9. customize our products and services to you, including by responding to and catering to your customer preferences;
10. personalize the content you see on our Website, by enabling you to save your preferences and suggesting content for your next flight;
11. keep the Website safe and secure;
12. aggregate Customer Data into anonymized statistical data (such as the number of passengers flown on a particular journey), which we will use for statistical analysis so that we can better understand GO FIRST's customer profile and improve GO FIRST's service offering;
13. to customize our marketing e.g. send you targeted marketing on places you would like to visit, based on your responses to optional questions on our Website and your prior travels. If you are an EU resident, you can object to this profiling and opt out of receiving such targeting marketing. For more information on this right, please refer to the para with the heading “Objection” under Section 7 below.
14. if you are an employee of an entity with a contractual relationship with us:

a. to contact you to perform our services, and in particular, to monitor and record calls for quality, training, legal compliance, analysis, and other related purposes in order to pursue our legitimate interest to improve service delivery;

b. enforce our terms and conditions against your employer; and

c. communicate with you about products, services, promotions, events, and other news and information we think will be of interest to you.

If you are an EU resident, you can object to this profiling and opt out of receiving such targeted marketing. For more information on this right, please refer to the para with the heading “Objection” under Section 7 below; and

15. With your consent where required by applicable laws, we will use your Customer Data to:

a. send you marketing and promotional materials in relation to products and services offered by GO FIRST, GO FIRST’s partner airlines and service partners, as well as GO FIRST’s appointed.

b. You have the right to withdraw your consent at any time by contacting us at nodalofficer@flygofirst.com

4. DISCLOSURE OF YOUR CUSTOMER DATA:

A. GO FIRST will share your Customer Data with selected third parties in the situations set out below:

1. our travel and freight service providers or travel-related businesses and service providers (including ground personnel and security personnel, partner airlines, airport management, airport operators;
2. our strategic alliance partners so that they can fulfill their contract of carriage for the flights you booked through GO FIRST. Where Customer Data is shared with such partners, the Customer Data will be used by that partner in accordance with their respective privacy policy;
3. advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
4. analytics and search engine providers that assist us in the improvement and optimization of the Website.

B. GO FIRST will share the Customer Data with its stations in order to better customise your preferences when you travel with GO FIRST:

For the purposes of our contract with you, i.e. to:

1. Fulfill bookings and facilitate flight transfers of passengers;
2. Manage passengers who travel on flights operated by our strategic alliance partners;
3. Manage passengers during flight disruptions and provide necessary assistance and services;

C. As it is in our legitimate interests to be responsive to you, to provide customized services and marketing, to:

1. Respond to complaints or compliments received by GO FIRST from passengers who are sharing their flight experience on our flights;
2. Providing an enhanced customer experience and personalizing offers to passengers;
3. Anticipating the servicing needs of passengers on flights with us;
4. Understanding customers better through analytics and research (including marketing research) to support personalization.

D. For the purposes of undertaking targeted direct marketing and other forms of marketing or advertisement, provided we have the consent of the recipient and/or have provided the opportunity to opt-out, in each case where required by applicable law.

E. GO FIRST will also use and disclose your Customer Data to persons who have been validly identified as being you or your authorized representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or inquiry. In particular, each of the passengers who are grouped under the same Passenger Name Record (“PNR”) number shall be deemed to be authorized representatives of each of the other passengers under the same PNR number.

F. GO FIRST will disclose your Customer Data to law enforcement or Government agencies, public, regulatory authorities, border control agencies, or other organisations for security, customs and immigration purposes, if legally required to do so, or if we have good faith belief that such use is reasonably necessary to:

1. comply with a legal obligation, process or request for verification of identity, or prevention, detection, investigation including cyber incidents, prosecution, and punishment of offenses;
2. enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
3. detect, prevent, or otherwise address security, fraud, or technical issues; or
4. protect the rights, property, health, or safety of us, our users, a third party, or the public as required or permitted by law (including exchanging Customer Data with other companies and organizations for the purposes of fraud protection and credit risk reduction).
5. Any sensitive personal data or information shall be disclosed to any third party by an order under the law for time being in force.

G. We will also disclose your Customer Data to third parties:

1. in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
2. if we or substantially all of our assets are acquired by a third party, in which case Customer Data held by us about our customers will be one of the transferred assets; or
3. to comply with legal obligations, processes, or requests (such as disclosing Customer Data to executors in response to court orders).

In addition, GO FIRST may disclose Customer Data to our legal advisors for establishing, exercising, or defending our legal rights, to our other professional advisors, or as otherwise authorized or required by law. GO FIRST also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health, or security of an individual or corporate entity such as GO FIRST. Further, GO FIRST will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement, or privacy.

5. TRANSFER OF INFORMATION OVERSEAS:

GO FIRST Corporate Office is based in Mumbai, India. GO FIRST’s infrastructure is primarily based on Cloud and its Core Systems are Software as Service (SaaS) in nature where its Customer Data is stored and accessed. Customer Data will be accessible to GO FIRST’s offices and appointed agents, including ground handling agents, sales agents, and contact centre agents, in India and around the world in connection with GO FIRST’s performance of the contract with you. This means that Customer Data will be transferred to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA"). We will transfer Customer Data to airports and ground crew in destinations that you are flying to and where we operate. The Customer Data is transferred outside the EEA on the basis that it is necessary for the performance of the contract of carriage between you and GO FIRST. If you are an EU resident, where we transfer Customer Data outside the EEA, this is done on the basis that it is necessary for the performance of the contract of carriage between you and GO FIRST. The Customer Data will also be processed by staff operating outside the EEA who work for us, for our suppliers, or our business partners. Such staff is engaged in, among other things, the fulfillment of your order, the processing of your payment details, and the provision of support services.

6. NON-EU DATA SUBJECT RIGHTS:

If you are not a resident in the EU, you may have certain rights in relation to the Customer Data we hold about you, which we detail below.

A. Access

You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with.

Where permitted by law, GO FIRST, reserves the right to charge a reasonable administrative fee for this service. GO FIRST reserves the right to deny you access to your Customer Data and may provide an explanation as required by applicable laws.

B. Correction

You have the right to seek corrections of any Customer Data held about you that is inaccurate. GO FIRST reserves the right to charge a reasonable administrative fee for this service.

C. Feedback and Complaints

If you have any concerns, feedback, or complaints about the use and/or sharing of your Customer Data, we are open to receiving your feedback or complaints.  

D. Exercise of Rights

To exercise any of your rights, please contact us at nodalofficer@flygofirst.com.

7. EU DATA SUBJECT RIGHTS:

If you are a resident in the EU, you may have certain rights in relation to the Customer Data we hold about you, which we detail below. Some of these only apply in certain circumstances where GO FIRST is holding authority of the data and legally/contractually allowed as per the local laws as set out in more detail below. We also set out how to exercise those rights.

These rights include:

1. The right of access.
2. The right of data portability.
3. The right of rectification.
4. The right of erasure.
5. The right to restrict processing.
6. The right to object.

Please note that we will require you to provide us with proof of identity and address before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one (1) month (although this may be extended by a further two (2) months in certain circumstances). To exercise any of your rights, please contact us at  nodalofficer@flygofirst.com.

Complaints.
In the event that you wish to make a complaint about how we process your Customer Data, please contact us and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.

A. Access

You have the right to know whether we process Customer Data about you, and if we do, to access Customer Data we hold about you and certain information about how we use it and who we share it with. If you require more than one copy of the Customer Data we hold about you, we may charge an administration fee. We may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person) or where another exemption applies.

B. Portability

You have the right to receive a subset of the Customer Data we collect from you in a structured, commonly used, and machine-readable format and a right to request that we transfer such Customer Data to another party. The relevant subset of Customer Data is data that you provide us with your consent or for the purposes of performing our contract with you. If you wish for us to transfer the Customer Data to another party, please ensure you detail that party and note that we can only do so where it is legally, contractually, and technically feasible. We are not responsible for the security of the Customer Data, its transmission, or its processing once received by the third party. We also may not provide you with certain Customer Data if providing it would interfere with another’s rights (e.g. where providing the Customer Data we hold about you would reveal information about another person).

C. Correction

You have the right to correct any Customer Data held about you that is inaccurate. GO FIRST reserves the right to charge a reasonable administrative fee for this service. Please note that whilst we assess whether the Customer Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below. To exercise any of your rights, please contact us at nodalofficer@flygofirst.com.

D. Erasure

You may request that we erase the Customer Data we hold about you in the following circumstances:

1. you believe that it is no longer necessary for us to hold the Customer Data we hold about you;
2. we are processing the Customer Data we hold about you on the basis of your consent you wish to withdraw your consent and there is no other ground under which we can process the Customer Data;
3. we are processing the Customer Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Customer Data;
4. you no longer wish us to use the Customer Data we hold about you in order to send you promotions, special offers, marketing, and lucky draws; or
5. you believe the Customer Data we hold about you is being unlawfully processed by us.

Also, note that you may exercise your right to restrict our processing of the Customer Data whilst we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Customer Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.  Please note that after deleting the Customer Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.

Where you have requested that we erase Customer Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Customer Data or providing links to the Customer Data to erase the Customer Data too. To exercise any of your rights, please contact us at nodalofficer@flygofirst.com

E. Restriction of Processing to Storage Only

You have a right to require us to stop processing the Customer Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Customer Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

You may request we stop processing and just store the Customer Data we hold about you where:

1. you believe the Customer Data is not accurate, for the period it takes for us to verify whether the Customer Data is accurate;
2. we wish to erase the Customer Data as the processing we are doing is unlawful but you want us to just store it instead;
3. we wish to erase the Customer Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise, or defence of legal claims; or
4. you have objected to us processing Customer Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Customer Data whilst we determine whether there is an overriding interest in us retaining such Customer Data.

F. Objection

At any time you have the right to object to our processing of Customer Data about you in order to send you promotions, special offers, and marketing messages, including where we build profiles for such purposes and we will stop processing the Customer Data for that purpose.

You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below by contacting nodalofficer@flygofirst.com referencing: Data Subject Rights.

You may object to where we are processing the Customer Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing.

Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or if we need to process it in relation to legal claims. Also, note that you may exercise your right to request that we stop processing the Customer Data whilst we make the assessment on an overriding interest. Please refer to the para with the heading “Restriction of Processing to Storage Only” under Section 7.

8. RETENTION

GO FIRST will retain Customer Data for as long as it is necessary to fulfill the purpose for which it was collected, and for satisfying any legal, business, accounting, or reporting requirements or as required by relevant laws.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you withdraw your consent to marketing, we will remove you from our marketing database.

9. ACCURACY:

GO FIRST needs your assistance to ensure that your Customer Data is current, complete, and accurate. As such, please inform GO FIRST of changes to your Customer Data by contacting GO FIRST and submitting your updated particulars to GO FIRST in writing (see Section 14). GO FIRST reserves the right to charge a reasonable administrative fee for this service.

GO FIRST will also request Customer Data updates from you from time to time. As detailed above, your booking information or flight itinerary will be disclosed to the appropriate security, customs, and immigration authorities as required by law. As such, it is important to ensure that the Customer Data contained in your booking information or flight itinerary is current, complete, and accurate.

10. SECURITY SAFEGUARDS:

GO FIRST takes the protection of your Customer Data seriously but, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Customer Data, we cannot guarantee its absolute security and shall not be liable for any breach of security by an outside party, including where unauthorized access, modification, destruction or disclosure of your personal information or data is attributable to any acts of an outside party, or any breach of security, virus and data protection protocols at your end or on the computer/mobile system that you use to access our Website.

11. LINKS TO OTHER WEBSITES:

GO FIRST May, from time to time, provide you with links to other websites for your convenience and information. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You access these websites at your own risk and GO FIRST is not responsible for these websites. Whilst GO FIRST will protect your Customer Data on our Website, GO FIRST cannot control or be responsible for the policies of other sites we may link to, or the use of any Customer Data you may share with them.  Please note that the GO FIRST Privacy Policy does not cover these other websites, and GO FIRST would recommend that you are apprised of their specific policies.

12. MINORS:

GO FIRST's Website is not directed at children under the age of 18 and GO FIRST cannot distinguish the age of persons who access and use our Website. If a minor (according to applicable laws) has provided GO FIRST with Customer Data without parental or guardian consent, the parent or guardian should contact GO FIRST (see Section 14) to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account.

13. UPDATES TO THE PRIVACY POLICY:

GO FIRST will amend this Privacy Policy from time to time, and the updated versions will be posted on GO FIRST’s Website. Please check back frequently to see any updates or changes to this Privacy Policy. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language.

14. CONTACT US:

If you have comments, questions, or complaints/grievances about or requests relating to this Privacy Policy statement, please contact GO FIRST in writing at the address below referencing ‘Privacy Policy:
nodalofficer@flygofirst.com

15. SEVERABILITY

If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.