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Privacy Policy

Privacy Policy

Who we are

Airline GEO SKY LLC is an aircraft operator (an airline) registered in accordance with the legislation of Georgia, the trade name of which is "Georgian Wings" (hereinafter: "Airline", "Georgian Wings", "we", "us", "our").

Our identification number is: 406198485

Legal address: Arboshiki st. N2, Isani district, Tbilisi, Georgia.

Website: https://georgianwings.com 

Tel: +995322502777

 

Introduction

This Privacy Policy (hereinafter referred to as the "Policy") defines how the airline takes care of your personal data and what principles guide its processing. "Policy" provides you with information about data protection rights and their realization.

The policy applies to all the information we process about you as a customer or potential customer.

We promise to take care of the security and protection of your personal data, not to use your data improperly, and to provide you with full and comprehensive information regarding the processing of your personal data upon your request.

The terms used in the "Policy" have the meaning defined by the Law of Georgia "On Personal Data Protection".

 

What does personal data mean?

Personal data is any information related to an identified or identifiable natural person. A natural person is identifiable when he can be identified directly or indirectly, including by name, surname, identification number, geolocation data, identifiable electronic communication data, physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics.

 

What kind of information do we process about you?

When providing the service, depending on the nature of the relationship with the user, the information processed by us may include, but is not limited/not exhaustive to the data of the following categories in proportion to the purpose of their processing:

Identification data

  • Name Surname
  • Date of birth
  • Identification number
  • Passport data
  • Gender
  • Citizenship

Contact details

  • E-mail 
  • Contact number

Additional data

  • Payment details/bank details
  • Reservation number

We ask you to provide us with only such personal data that is necessary to provide the service or services you have chosen, or to respond to a specific request/complaint about you. At the same time, if you decide to provide us with any additional personal data, we will be able to properly protect their security.

 

Special category data:

  • We may process special categories of personal data, such as health-related data (for example, when you request special assistance from us and/or an airport operator, such as oxygen supply and/or first aid), or when you provide us with information related to your tolerance for flying (for example, information about pregnancy or allergies) for safety reasons. If you have a specific health condition or if you require special in-flight services or assistance, you must provide us with a health certificate.
  • In order to process special category of your personal data, we may need your written consent. We are required to obtain this consent from you, and if you refuse or withdraw your consent, we may not be able to provide you with the requested service(s).

 

We respect your rights when processing personal data, therefore personal data is:

  • Processed legally, fairly and transparently to you;
  • Collected only for specific, clearly defined and legitimate purposes and in accordance with these purposes;
  • Processed only to the extent necessary to achieve the relevant legitimate purpose, is proportionate to the purposes for which it is processed;
  • Accurate and, if/when necessary, it is updated;
  • Stored for the period necessary for the purposes of such data processing (based on actual needs and/or obligation(s) determined by the current legislation of Georgia);
  • In order to protect data security, there have been adopted such technical and organizational measures during data processing that properly ensure data protection.

 

Purposes of data processing

We process your data only for lawful purposes and to the extent appropriate for it. Data may be processed by us for various purposes, including:

  • To provide services, to book an airline ticket, to purchase/sell an airline ticket (or other related service), to make a payment, to rebook/change an airline ticket, to manage the reservation;
  • Our Terms & Conditions – to comply with the General Conditions of Transportation (https://georgianwings.com/);
  • To refund the money, to give compensation;
  • To register on our website;
  • To communicate with the passenger, for example, such as sending/delivering flight-related information by a message;
  • To answer any of your questions, to receive your feedback, to process your requests;
  • To comply with obligations under relevant applicable law, such as immigration, public health, consumer protection, audit regulations;
  • To improve user experience;
  • For marketing purposes, which means, with your consent, the periodic offer of various products/services by us, the development/planning of marketing activities;
  • To protect our legitimate interest and/or legal rights.

 

  • Note that we will need your personal data to perform the agreement between you and us or to provide services to you. If you do not provide the requested personal data, we will not be able to provide all or part of the services you have requested.
  • Please note, if you have purchased the ticket(s) for someone else, we may process your billing information, but we may also contact the passenger directly with their flight information.

 

Legal basis for data processing:

In each individual case, the basis for processing of your data by us is (at least one of the following):

  • Your consent to the processing of data;
  • Necessity of data processing for the performance of a contract with you or for the conclusion of a contract at your request;
  • Obligations under the law;
  • Public access to data;
  • Consideration of your application (provision of services);
  • Our legitimate interests;
  • Protection of your vital interests or those of another person;
  • Protection of important public interest;

 

Period of data storage

"Georgian Wings" stores your data:

  • For the time necessary to achieve the specific purpose of the processing;
  • For the entire period of the service;
  • For the time specified by law;
  • For the time necessary to fulfill our legal obligations;
  • For the time necessary to protect our legitimate interests and/or legal rights;

To determine the appropriate storage period, we take into account the amount, type, and category of data, as well as the purpose for which we process the data and whether this purpose can be achieved by other means(s) without processing the data.

 

Who do we share your data with?

Given the category of personal data and the purpose of processing, only our relevant departments/organizational units have access to the data.

In order to fully benefit from our services, we share your personal data with third parties (government authorities, partner airlines, other partners) who are obliged to ensure appropriate data protection, in order to provide services such as:

  • Reservation management;
  • Payment processing;
  • Airport services, such as: ticket sales, baggage services, rebooking/exchange of tickets, changes in tickets, ground handling;
  • Audit, consulting, legal and other professional services;
  • IT services;
  • Marketing services;

 

Government authorities;

  • In cases specified by law, we are required to transfer your data to government agencies and authorities. Such agencies and authorities may include: law enforcement agencies, border police, immigration authorities of the countries you are traveling to. Upon their legal request, if we do not share your personal data with the relevant government agencies and authorities, you may be denied travel to your destination or be denied entry to your destination.

 

Partner airlines;

  • When providing air transportation services, we share your data with our partner airlines only in cases where they are involved in your transportation. In addition, if any partner airline is involved in your transportation, they will be able to share your personal data with third parties in order to provide you with a full range of services.

 

Other partners;

  • You may book tickets on our flights through a network of airline agents that use global distribution systems (GDS). Therefore, the booking systems access your data at the time of booking. This is done solely for the purpose of enabling you to book your flight, order any additional services or make changes to your booking.
  • Our main booking and ticketing system, through which we process your personal data, is "Videcom". This system is committed to the proper processing and protection of your data.
  • We also provide access to your personal data to the developers of our booking and ticketing systems and online check-in systems, who are processors of personal data, in order to operate these systems.

 

Processing of personal data for direct marketing purposes:

  • We use your personal data for marketing purposes only with your consent. We need this in order to provide you with information about products and offers that are suitable for you.
  • We will study your data to understand what you want or need, what would be interesting for you. In this way, we decide which service or offer may be of interest to you.
  • You have the right to withdraw your consent at any time, by contact us and ask us to stop processing your data, including for direct marketing purposes. The request can be submitted at any time via the contact information of "Georgian Wings", including the hotline +995322502777 and/or e-mail – [email protected] and/or directly via the opt-out mechanism offered when conducting direct marketing.
  • We respect your wishes and will stop processing your data for direct marketing purposes within 5-7 days after receiving your request.
  • We may also send you notifications and other SMS texts via other communication systems to inform you about your flight or to receive your feedback regarding the quality of flight service.

 

Confidentiality Guarantees

"Georgian Wings" ensures maximum protection of confidential information provided to us, in accordance with the procedure established by law.

"Georgian Wings" cares about the security and confidentiality of your information, however, it disclaims liability for unauthorized access to information by third parties (including platforms used for remote delivery).

You are responsible for the accuracy of the information you provide to us. In the event of changes to your data, you may contact us and request that the data be corrected, inaccuracies removed, or changes made. We will take appropriate measures to make the requested changes as quickly as possible in our databases valid at that time. If any information provided by you is untrue, inaccurate, out of date or incomplete (or is no longer accurate, inaccurate, out of date or incomplete), and/or the airline has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, we reserve the right to terminate the provision of services to you. 

"Georgian Wings" implements appropriate security measures and procedures to protect the data under its control from unauthorized access, misuse and disclosure, unauthorized modification, and unlawful destruction or accidental loss.

We respect your right to privacy and data protection and, except in cases otherwise provided in this Policy, we will only disclose your personal information if required to do so by law, a regulator or law enforcement agency, and/or if the Company, in its sole discretion, believes it is appropriate to disclose your information to protect its rights or the rights of others, or to prevent or mitigate harm to people or property.

 

You have data protection rights:

  • At any time, you can contact us and request information about the processing of your data and/or copies of the data, which will be provided to you within the time limit provided by law after you have been properly identified.
  • You can request that your personal data be updated, corrected and/or supplemented if it is not correct or complete.
  • You may also request the end of data processing, their deletion and/or destruction; after processing the said request in accordance with the relevant procedures, you will be informed about the status of your request within the period provided for by law. However, please note that we have the right to refuse to fulfill this request if there is another legal basis for processing your data or we process the data for the purpose of substantiating a legal claim or objection, the processing of the data is necessary for the exercise of the right to freedom of expression or information and/or they are processed for archiving purposes in the public interest provided for by law, or for statistical purposes, and fulfilling your request makes it impossible or would significantly impair the achievement of the specified objectives..
  • You can also request the blocking or transfer of data in accordance with the procedure established by the applicable legislation of Georgia.
  • You can withdraw your consent to the processing of data at any time. In such a case, we will stop processing the data and delete the data already processed, unless there is another basis provided for by the legislation on data processing. Please note that the withdrawal of consent may result in a disruption of the service and/or we may not be able to provide you with the full service.
  • Any other rights provided for by the applicable legislation.

Please note that we reserve the right to ask you to confirm/verify your identity before responding to your request.

 

Changes to the Policy

We reserve the right to update this Policy at any time. In the event of a change to the Policy, the updated version will be posted on our website: www.georgianwings.com.

 

How to contact us?

If you have any questions regarding the policy, please contact us at: [email protected].

You can also contact our Personal Data Protection Officer at: [email protected].

We hope we can provide you with comprehensive information.