1. Types of Customer Data
The types of Customer Data that TSAL collects depends 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 TSAL collects:
- Personal Data, which includes but is not limited to –(i) personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;
(ii) contact information e.g., address, phone number, email address;
(iii) payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
(iv) travel information e.g., flight information, dietary and seating or other service preferences;
(v) health information e.g., medical records or requests;
(vi) technical information e.g., IP address; and
- Statistical Data e.g., number of passengers flown, hits to website. This is 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 TSAL's customer profile and improve TSAL's service offering.
For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.
The provision of Customer Data (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for TSAL to carry out its services to you.
The failure to supply such Customer Data may result in (i) TSAL being unable to provide you with the services and/or products requested; (ii) TSAL being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by TSAL.
2. Purposes for Collection, Use and Disclosure
Generally, TSAL collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., your travel agent or our service provider), or from publicly available sources, through our website, mobile services, and other channels including our ticketing counters and airport operations, in order to fulfil the following purposes, which include but are not limited to:
- Providing services to you such as processing a transaction (e.g., making a booking), providing technical assistance, assisting you in the transaction, providing flight alert messages through TSAL’s mobile services facility, facilitating internet check-in and registering for TSAL’s club Vistara programme;
- Providing in-flight catering and other services that best meet your preferences and needs (which we may collect during our interactions with you);
- Marketing and communicating with you in relation to products and services offered by TSAL, TSAL’s airline and service partners, as well as TSAL’s appointed agents;
- Contacting you for product or customer satisfaction surveys and market research; and
- Safety, security and legal compliance.
TSAL may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above.
In connection with the above, we may disclose your Customer Data to third parties, such as our travel and freight service providers or travel-related businesses, partner airlines, airport management, security personnel, and other carriers.
TSAL may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.
TSAL may disclose your Customer Data to law enforcement agencies and government for security, customs and immigration purposes. Accordingly, relevant Customer Data (known as Passenger Name Record (PNR) or Advance Passenger Information (API)) may be disclosed to the appropriate customs and immigration authorities as required by law. Please be informed that the initial recipients of such information may share your PNR and API data with other government agencies or enforcement authorities.
In addition, TSAL may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. TSAL 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 entities such as TSAL. Further, TSAL may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
3. Transfer of information overseas
The TSAL Head Office is based in New Delhi. Customer Data may be transmitted to data storage facilities where TSAL keeps its central records. Customer Data may be transferred to TSAL’s offices and appointed agents in India or other countries in connection with TSAL’s performance of the contract with you.
You may submit a request to withdraw your consent at any time by contacting TSAL (see Section 10) or by logging on to your website account with TSAL (if you are a Club Vistara member or a non-Club Vistara member registered as a user of TSAL’s websites).
Statistical Data is not linked to a customer record and TSAL does not need to seek consent for the collection, use or disclosure of Statistical Data. For more information on the collection and usage of Customer Data obtained from TSAL’s websites and through TSAL’s mobile services facility, please refer to Part B.
TSAL will, upon your written request to our Customer Relations Department (see Section 10), allow you to view your stored Personal Data. Where permitted by law, TSAL reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, TSAL reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include where:
- An investigating authority or government institution objects to TSAL complying with a customer’s request,
- The information may, in the exercise of TSAL’s reasonable discretion and/or assessment, affect the life or security of an individual, and
- Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
TSAL will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of TSAL, or as required by relevant laws.
When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.
TSAL needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform TSAL of changes to your Personal Data by contacting TSAL and submitting your updated particulars to TSAL in writing (see Section 10). If you are a Club Vistara member or a registered website user, you may update your Personal Data at any time by logging on to your website account with TSAL.
TSAL may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Purposes for Collection, Use and Disclosure” sub-section, your booking information or flight itinerary may be disclosed to the appropriate customs and immigration authorities as required by law. As such, it is important to ensure that the Personal Data contained in your booking information or flight itinerary is current, complete and accurate.
8. Security safeguards
TSAL takes the security and protection of your Customer Data very seriously. As such, TSAL makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure.
As an example of a procedural safeguard, TSAL has implemented various authentication procedures internally and with our external service providers that may involve TSAL requesting various personal particulars from you in order to verify your identity (or that of your duly authorised agent) before TSAL processes your request for a particular service, product or transaction.
Examples of technical safeguards include encryption, “firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through TSAL’s websites and TSAL’s mobile services facility are set out at Part B below.
If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, TSAL will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact TSAL (see Section 10).
10. Contact us
Customer Relationship Manager
Jeevan Bharti Tower-1, 10th floor
124 Connaught Circus
New Delhi 110001
Alternatively for queries specific to Club Vistara, you may contact:
Club Vistara Membership Services
Jeevan Bharti Tower-1, 10th floor
124 Connaught Circus
New Delhi 110001
1. Security safeguards
TSAL takes the protection of your Customer Data collected on TSAL’s websites and through TSAL’s mobile services facility very seriously. All Customer Data collected through TSAL’s websites, e.g., http://www.airvistara.com and through TSAL’s mobile services facility are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems.
For example, when you transmit sensitive information such as credit card details through TSAL’s websites, such information will be encrypted before being dispatched over the internet.
To further strengthen the integrity of your internet transactions on our websites, TSAL also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies without notice to you.
To give you secure access to our online services, arising from your utilisation of TSAL’s mobile services facility, and your Club Vistara account, you can register with us, and we will give you a membership number/ User ID with a PIN that is unique and personal to you. You should not share your membership number/User ID or PIN, and should always ‘log off' once you have finished your session on the websites as well as take the recommended precautions that ensure the safe and secure provision of TSAL’s mobile services facility.
As an additional security feature, TSAL has implemented a time stamp showing the time you have been on TSAL’s websites and the last time you logged out. If you detect any anomalies you should inform TSAL immediately (see Section 10 of Part A). TSAL has also provided a lock out feature in the event you fail to log in successfully after a number of attempts. Also, if you leave TSAL’s website idle for a period of time, we may give you a ‘warning' dialogue box giving you the option to end your session.
Information and procedures regarding cookie handling are provided by the respective browsers documentation within the browser itself by clicking on ‘help' and performing a search on ‘cookies'.
3. Clickstream data
In order to improve your online experience, TSAL may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.
4. Links to other websites
TSAL cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided TSAL with Customer Data without parental or guardian consent, the parent or guardian should contact TSAL (see Section 10 of Part A) to remove the relevant Customer Data and unsubscribe the minor.
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