Welcome to the Privacy Policy of Gulf Air (GF).
Your privacy is important to us and we want to assure you that the Personal Data we collect about you will be treated with care. This Privacy Policy will inform you about how we look after your Personal Data when you visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This Privacy Policy uses a number of definitions which are set out below:
Supervisory Authority: the public authority responsible for monitoring the application of the applicable data protection law.
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of this website or the Gulf Air mobile application, including any data you may provide through this website when you make or amend a flight booking, join our Falconflyer Program or sign up to our newsletter.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements such other notices and is not intended to override them.
Identity of Data Controller
Gulf Air is the Data Controller of all Personal Data relating to our passengers, employees and third party individual contacts, as well as any other Personal Data used in our business for our own commercial purposes.
This Privacy Policy is issued on behalf of the Gulf Air so when we mention “Gulf Air”, "we", "us" or "our" in this Privacy Policy, we are referring to Gulf Air as being responsible for processing your data. Gulf Air is the Data Controller and responsible for this website.
Data Protection Officer
Gulf Air will appoint a Data Protection Officer (DPO) who will be responsible for overseeing questions in relation to this Privacy Policy. In the meantime, if you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
Telephone number: +973 1733 8727
You have the right to make a complaint at any time to the Personal Data Protection Authority, Kingdom of Bahrain (www.pdp.gov.bh), which is the Supervisory Authority for data protection issues in the Kingdom of Bahrain. If you are located in the United Kingdom, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (www.ico.org.uk), the UK Supervisory Authority for data protection issues. If you are located in the EEA, you have the right to make a complaint at any time to the Supervisory Authority in your country.
We would, however, appreciate the chance to deal with your concerns before you approach the Supervisory Authority so please contact us in the first instance using the contact details above.
Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and up-to-date. It is your obligation to keep us informed if your Personal Data changes during your relationship with us. Please use the following links to update your Personal Data:
Falconflyer members
https://falconflyer.gulfair.com/ffp/user/login
Manage My Online Booking
https://flights.gulfair.com/falcon/cbh/mmb/login
Third-party links
This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by Gulf Air. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you look at other websites, we encourage you to read the Privacy Policy of every website you visit.
Personal Data
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:
Usage Data: includes information about how you use this website and services.
Aggregated Data
When you visit this website or use any Gulf Air mobile applications, we may also collect, use, store and share aggregated, anonymised statistical or demographic data (Aggregated Data). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as it cannot directly or indirectly reveal your identity.
Aggregated Data may include the time and length of your visit to this website, the pages you have visited on this website, as well as details of the website you visited immediately prior to visiting this website. We may also record the name of your internet service provider. We use this information only to measure site activity and to develop ideas for improving our services.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
Sensitive Personal Data
It is a necessary part of our business to collect certain types of Sensitive Personal Data about you. For example, we need to collect data about your state of health if you inform us that you are pregnant, have a medical condition which requires special equipment, or when you make a request for mobility assistance. Making certain meal choices will also involve the collection of data about your religious beliefs or state of health, for example if you inform us that you require a Hindu or diabetic meal.
We treat our obligations to protect Sensitive Personal Data very seriously and we will always ask your express consent to collect, process or transfer such data for specified purposes each time you provide it to us.
Personal Data relating to minor passengers
In certain circumstances, we may need to collect, process or transfer Personal Data relating to minor passengers (i.e. children under the age of 16), for example where a flight booking is made in respect of a minor passenger. This is necessary for us to pursue our legitimate interests in running our business and to perform the contract of carriage.
We will only use Personal Data relating to minor passengers for the specified purposes set out in the “HOW WE USE YOUR PERSONAL DATA” section and with the express consent of the person who has parental responsibility. Minor passengers have the same rights as any other passenger regarding their Personal Data which are set out in the “YOUR LEGAL RIGHTS” section.
Providing Personal Data on behalf of other passengers
By providing us with Personal Data, including Special Categories of Personal Data, relating to other passengers on your booking, you are representing that you have their authority to provide their Personal Data to us and to consent to their Personal Data being collected and processed for the specified purposes. Gulf Air is entitled to rely upon such representations.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept your booking, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
• Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide to us when you:
This website. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the “HOW WE USE YOUR PERSONAL DATA” section and our Cookie Policy for further details
• Our mobile website and mobile applications. Our mobile website and mobile applications have the ability to access mobile device information to better serve passengers in the service that is used. We may use location data for our mobile website and mobile applications to enable us to provide the most helpful format and content (for example pre-populating your departure airport based on current location) providing that you have agreed to the use by Gulf Air of your location data. If you would like to restrict our collection of your location data, please adjust the settings on your device.
• Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
o Data from the following parties:
o Contact, Financial and Transaction Data from providers of technical or payment services.
o Identity and Contact Data from data brokers or aggregators.
We will only use your Personal Data as permitted by law. Most commonly, we will rely on the following types of lawful basis to process your Personal Data:
For example we may collect data on the confirmation of your passage through various checkpoints at the airport, in order to optimize punctuality. Airport management entities may record the time of the pre-screening of boarding passes before passengers’ entry to the security area and provide us with this data at the departure gate shortly before departure to enable us to check for missing or possibly delayed passengers and initiate an early unloading of baggage where appropriate.
We do not use your Personal Data for activities where our interests are overridden by your fundamental rights and freedoms (unless we have your express consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
For example, in accordance with Article L 232-6 of French Internal Security Code, we may transmit reservation, checking or boarding data collected from passengers (API/PNR) to the French national public services and competent authorities for the purposes and under conditions as defined in the Decret N° 2014-1095 dated 26 September 2014.
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of all the ways we will use your Personal Data, and which types of legal basis we rely on to do so.
We have also identified what our legitimate interests are where appropriate. We may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying upon to process your Personal Data where more than one basis has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new online account holder or Falconflyer member |
(a) Identity (b) Contact |
Necessary for our legitimate interests (for running our business) |
To process your flight booking including:
(a) Contacting you regarding your travel arrangements (b) Manage payments, fees and charges (c) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To arrange any special assistance you require or make arrangements for special medical equipment, which may necessitate providing the data to our third party suppliers |
(a) Identity (b) Special Categories of Personal Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to assist you in boarding your flight and travelling safely) (c) Express consent requested during the booking process |
To arrange meal choices which may identify your food preferences, religious beliefs or state of health, which may necessitate providing the data to our third party suppliers |
(a) Identity (b) Profile (c) Special Categories of Personal Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to provide you with a meal which fits your food preferences, religious beliefs or health restrictions) (c) Express consent requested during the booking process |
To manage our relationship with you which will include:
(a) Notifying you about changes to our conditions of carriage, Privacy Policy or any other terms and conditions (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, to study how passengers use our services and to enable us to offer better services to you in the future) |
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how passengers use our services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To optimise punctuality and provide a reliable service | Passenger Boarding Sequence number | Necessary for our legitimate interests (to enable the early detection of passengers’ delayed arrival at the gate during the boarding process, allowing us to check for missing or delayed passengers and to initiate early unloading of baggage. |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how passengers use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve this website, services, marketing, passenger relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of passengers for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our services, grow our business and offer more suitable services to you in the future) |
Cookies
This website makes use of cookies to measure site activity and to customise information to your personal tastes. A cookie is an element of data that a website can send to your browser which may then store the cookie on your hard drive, either temporarily or long term. This means that, when you visit this website in future, we can tailor information to suit your individual preferences which can save you time and provide you with a more personalised visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you to explain the legal basis which allows us to do so or, where required by law, to seek your consent.
We aim to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this “marketing”).
The “soft opt-in”
You will continue to receive marketing communications from us if you have previously booked flights or purchased other services from in the past, or if you have requested information from us in connection with a potential booking or purchase, unless you have opted out of receiving future marketing communications.
Third-party marketing
We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your Personal Data for the purposes set out in the table in the “HOW WE USE YOUR PERSONAL DATA” section with third party service providers.
Disclosure of your Personal Data within Gulf Air
All parts of Gulf Air, including outstations, branches and offices acting as joint controllers or processors and which are based in EEA and non-EEA countries, e.g. the Kingdom of Bahrain, and provide IT and system administration services.
Disclosure of your Personal Data to External Third Parties
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
Internal Transfers
We will share your Personal Data within the Group. As Gulf Air’s head office is based in Bahrain, it may be necessary to transfer Personal Data which was collected in Bahrain outside of it to other parts of the Gulf Air Group. If you are accessing this site from outside Bahrain, you consent to the transfer, storage, and processing of your data in Bahrain or other countries.
We ensure your Personal Data is protected by requiring all of our Group companies, branches, offices and outstations to follow the same rules when processing your Personal Data. These rules are called "Binding Corporate Rules". Gulf Air’s Binding Corporate Rules are found under the Transparency section.
External Transfers
Many of our external third parties are based outside Bahrain so their processing of your Personal Data will involve a transfer of data outside Bahrain.
Whenever we transfer your Personal Data to third parties which are based outside Bahrain, we ensure a similar degree of protection is afforded to the data by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we retain your Personal Data
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised 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.
In some circumstances you can ask us to delete your data: see Request erasure in the "YOUR LEGAL RIGHTS" section for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee (taking into account the administrative costs of providing the information) if we consider your request to be unfounded, repetitive or excessive. Alternatively, in these circumstances, we may refuse to comply with your request but we will provide you with a full explanation of this at the time.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We will respond to all legitimate access requests within fifteen working days and to all other legitimate requests for correction, blocking, and wiping, within 10 business days. If your request is particularly complex, or you have made a number of requests, or there are justifiable reasons, it may take us up to 3 calendar months to respond, but we will notify you of this and keep you updated.
Users in the European Economic Area (“EEA”) and United Kingdom (“UK”)
If you are located in the EEA or UK, you have the right to request access to your data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of your personal data in accordance with the General Data Protection Regulation (GDPR) or the UK GDPR. You also have the right to obtain a free copy of the specific contracts referenced in Section 9. You may use the information in Section 3 to submit your request. Additionally, you also have the right to lodge a complaint with your Supervisory Authority if you are located in the EEA, and with the ICO if you are located in the UK
Personal data is also processed outside of the UK, Switzerland, and the EEA by Gulf Air’s group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 8. We use specific standard clauses to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and Gulf Air Group companies to restrict and regulate their processing of your data. By submitting your data, accessing our site or using our services, you consent to this transfer, storage, and processing by Gulf Air and its processors.
Users in Turkey
If you are in Turkey, the following additional terms apply along with the contents of our Privacy Policy. In the event of any conflict between the following additional terms and the provisions of the main body of our Privacy Policy, the following terms shall prevail.
Data Controller if you are a user in Turkey, you should know that [Gulf Air group company], located at [address] is the controller of your Personal Data.
Data Controller Representative. If you have any questions about this Privacy Policy, including any complaints in connection with the processing of your personal data or requests to exercise your legal rights, please contact the data controller representative in Turkey by email using the details set out below:
Legal bases for the processing your Personal Data. Gulf Air relies on the following legal bases to process your Personal Data:
Personal Data We Collect. For information on Personal Data we collect, please refer to Sections 4 entitled ‘The Data We Collect About You’.
Purpose of Handling Personal Data. For information on how we use your Personal Data, please refer to Section 6 ‘How We Use Your Personal Data’.
International Data Transfers. To provide you with our services, we may collect your Personal Data from, transfer it to and store and process it in the Kingdom of Bahrain and other countries outside where you live. We share information outside of where you live, we ensure that the transfer complies with your local law so that your Personal Data. For information on Personal Data we transfer, please refer to Section 4 of this Privacy Policy entitled ‘The Data We Collect About You’. For information on how we transfer Personal Data, please refer to Section 11 of this Privacy Policy entitled ‘International Transfers’.
Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your Personal Data:
You may exercise your rights listed above by contacting us at: [………………….].
We will respond to all legitimate requests within thirty days at the latest. You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, if your request incurs additiona
We reserve the right to change this Privacy Policy at any time. This version of the Privacy Policy was last updated on February 2022. Historic versions of this Privacy Policy can be obtained by contacting us
[1] The EEA is composed of the 28 EU Member States plus Norway, Iceland and Lichtenstein.
Version: 20-June-2022