At PassionAir, we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how Pisces Aviation Limited d.b.a PassionAir (“we,” “us,” “our,” “PassionAir”) collects, uses, shares, and protects information in connection with PassionAir’s online and offline services, systems, websites, and apps that refer or link to this Privacy Policy (our “Services”), including without limitation, the collection and processing of personal information in connection with bookings and travel on PassionAir flights, as well as loyalty data collected and processed in connection with our loyalty program. This Privacy Policy applies regardless of the way you interact with our Services or the type of device or other means you use to access our Services.

This Privacy Policy is not a contract and does not create any contractual rights or obligations.

Our full contact details are:

Full Legal Name: Pisces Aviation Limited d.b.a. PassionAir
Email address: concerns@flypassionair.com
Postal Address: P.O. Box CT 920, Cantonments, Accra – Ghana
Head Office Address: 1 Duchessville, 2nd Circular Road, Cantonments, Accra, Ghana.

You have the right to make a complaint at any time using the contact details above.

This version replaces all previous versions with effect from the effective date of this privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data means details which identity or could be used to identify a natural person, such as a name, an identification number, location data, an online identifier or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Sensitive personal data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual.

Data processing/processing is any activity, operation or set of operations performed on personal data or sets thereof, irrespective of the procedure and the means (automated or not) applied, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, revision, disclosure by transmission, dissemination or otherwise making available, alignment or combination, interconnection, blocking (locking), erasure archiving, viewing and destruction of personal data.

Data file means any structured set of personal data which is accessible in such a way as to make it possible to deduce the person in question from the data.

Disclosure means making personal data accessible.

Data Protection Impact Assessment is a systematic process for identifying, evaluating and documenting the risks and impact of personal data processing activities to the rights of individuals.

Data controller is the legal person who decides and determines the purpose and means of processing personal data.

Data processor is the physical or legal person that processes personal data on behalf of the Data controller.

App means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).

Our website (www.flypassionair.com) may include links to third-party websites, plug-ins and applications. 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 thus PassionAir shall not be responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and communication preferences.

To the extent that the personal information we collect constitutes sensitive personal information under applicable law, PassionAir will collect and process this sensitive personal information within the limits provided by applicable law.
Personal information provided in situations where:

• You make a specific request for medical assistance, such as the provision of wheelchair assistance or oxygen;
• You have sought clearance to fly with a medical condition or because you are more than 28 weeks pregnant;
• You have chosen to provide such information to us or it has been passed to us by a third party such as the travel agent through which you made your booking;
• Biometric information (e.g. facial recognition information) may be collected during the security clearance process prior to, and after flying with us; and
• You have requested services which may imply or suggest your religion, health or other information (e.g. when you disclose your dietary requirements to us).

PassionAir does not consider such data to reliably imply or suggest sensitive personal information.

We collect personal data about you whenever and wherever you use our services (whether services provided directly by us or by other companies or agents acting on our behalf), when you travel with us, when you use our websites, or when you use our call centres or mobile applications.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Our Services
We use personal information to complete transactions and fulfil requests for our products and services. For example, we require you to provide personal information when making a reservation to purchase airline tickets or related products and services through a PassionAir Reservations Agent, travel agent, the flypassionair.com website, mobile app or another travel-related website, or enrolling in the PassionAir loyalty program. We may also use personal information to verify your identity, including for security purposes.

In the event of a flight delay, cancellation, or other service disruption, we may use the contact information provided in your booking to notify you, and the individuals travelling on the same booking, about the disruption.

Administrative, marketing, and analytical purposes
In addition to processing, confirming and fulfilling the travel or other services or products you request, PassionAir may use personal information for administrative, analytical, and marketing purposes such as employee training, information systems management, accounting, billing and audits, credit card processing and verification, customer-relations correspondence, and/or operation of the loyalty programs. PassionAir also uses personal information to identify, develop and market products and services that we believe you will value, including across browsers and devices, in accordance with applicable laws. Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes. More specifically, we may use your personal information for the following purposes:

• Business purposes and communication: To provide flight services or information you requested, to communicate with you for business or customer service reasons (such as sending messages related to flight tracking or delays), or for other such reasons such as changes to our policies or in response to your inquiry.
• Personalized airport service: To provide personalized services, such as wheelchair assistance or access to our lounges; to check whether you have passed through airport security, whether you are on a connecting flight, and to contact you about boarding a flight, if you have not arrived at the gate; and to monitor where you are in the airport to assist you with flight connections and boarding our aircraft.
• Financial transaction management: To facilitate payment for services or provide refunds.
• Legal and regulatory obligations: To comply with legal, regulatory, or fiscal obligations, or in connection with litigation or an internal investigation or audit.
• Tailored web experience: To personalize your advertising experience when visiting our sites or using our mobile app, and to manage details about your accounts, including when security updates are available, or when an action is required to keep the account active.
• Improve our operations: To improve our routes and service offerings as an airline operator, including reviewing our travel destinations, fare classes, loyalty program offerings, and operations more generally, as well as compiling statistics on international air traffic and statistics to improve products and services.
• Marketing and analytics: To perform data analysis and other processing for marketing purposes, including offering you specific services, applications, events, sweepstakes, and special campaigns.
• Site maintenance: To improve the content, functionality, and usability of our sites and to offer opportunities to participate in surveys and provide feedback to us.
• Security management: To secure PassionAir’s premises, assets, and information, and to test and evaluate the effectiveness of PassionAir’s security.
• Third-party requests: To respond to and comply with outside requests initiated by you, as well as in response to legal requests.
• Audit and controls: To evaluate internal controls and audits for compliance (including those conducted by PassionAir’s internal and external audit service providers).

There are Closed Circuit Television (CCTV) cameras in operation within and around our stations and other premises, which are used for these purposes:

• to prevent and detect criminal, malicious, or fraudulent activity;
• to protect the health and safety of PassionAir’s customers and employees;
• to manage and protect PassionAir’s property and the property of PassionAir’s guests and other visitors; and
• for quality assurance purposes

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 and we will explain the legal basis which allows us to do so. 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.

When you visit a Site or use an App we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use cookies to distinguish you from other visitors, track your IP address and usage of our site, and indemnify the name of the website from which you linked to our website. This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our website design, as well as our products, services and promotions. We do not otherwise track any information about your use of other websites.

You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to track your purchases or enable you to make a purchase from our website. In addition, we will not be able to recognise you as a registered user to allow you access to your account information.

To best serve you, we may share your personal data with service providers that provide support services to us or that help us market our products and services. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from PassionAir.

In particular and in order to facilitate your travel arrangements, we will often need to share your personal data with third parties such as airlines, airport operators, customs, immigration authorities and travel agents involved in making your travel arrangements. We also share your personal data with third parties who deliver services either to you or to us, such as companies that provide airport assistance.

We may disclose your personal data to a third party to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We may also disclose your personal data to a third party when you ask us to do so or when we believe it is required by law.

We take reasonable measures to protect the personal information you provide to us. PassionAir 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.

Please note, however, that while PassionAir attempts to safeguard your personal information, no method of transmitting or storing electronic information is ever completely secure, and thus we make no warranty, express, implied, or otherwise, that your information will never be accessed, used or released in a manner that is inconsistent with this Privacy Policy.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

You have the right to:

• Refuse to provide your Personal Information to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services if you do not provide us with your Personal Information – e.g., we might not be able to process your
• Requests without the necessary details and you may not be able to fly with us without providing the necessary information);
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
• Request correction of the personal data that we hold about you.
• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Lodge a complaint regarding the processing of your personal information with the Data Protection Commission of Ghana.
• Object, on grounds relating to your particular situation, to the processing of your relevant personal information by us or on our behalf. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time when we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using our contact details.

This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.