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This Privacy Statement sets out what we do with your personal information and how we keep it secure. It explains what personal information we collect, where, why and how we collect it, as well as what your rights are over the personal information we hold about you. We use the terms "personal data" and "personal information" interchangeably in this Statement to mean details which identify you or could be used to identify you, such as your name and contact details, your travel arrangements and purchase history etc. This Privacy Statement gives effect to our commitment to protect your personal information. It applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us as a guest or potential guest, including: when you travel with us or use our other services; when you interact with us on social media or use our websites or mobile applications, through our virtual online "chat" service, contact our service agents or call centres and/or book to use our services through third parties (such as travel agents and other airlines); and/or where you are a member of AerClub (our loyalty, reward & recognition programme). The purpose of this Privacy Statement is to enable you to understand how we process your personal data and to exercise control over it. The principle of "transparency" in data protection law requires that we communicate to you (via this Privacy Statement) about how we process your personal data in an easily accessible and easy to understand format. As a valued Aer Lingus guest, your personal privacy is very important to us. Therefore:

You can access our full Privacy Statement below to help you to understand better how we use your personal information. In it, we explain in more detail the types of personal information we collect, how we collect it, what we use it for and who we share it with. Our "Privacy Essentials" section below summarises the most important parts of our Privacy Statement. In the full Privacy Statement you can also find some specific examples of why and how we use your personal information. If you have further questions please get in touch with us at privacy@aerlingus.com or write to us at Data Protection Officer, Aer Lingus, Dublin Airport, County Dublin, Ireland. Without prejudice to your rights under applicable laws, this Privacy Statement is not contractual and does not form part of your contract with us.

This Privacy Statement is applicable to services provided by Aer Lingus Limited and Aer Lingus (U.K.) Limited. References to "Aer Lingus”, “we", "our" "ourselves" and "us" means Aer Lingus Limited and/or Aer Lingus (UK) Limited, as applicable.

PRIVACY ESSENTIALS

Aer Lingus Limited (Dublin Airport, Co Dublin, Ireland; email address privacy@aerlingus.com) is the data controller of your personal data where you book services that we provide to you. Aer Lingus (U.K.) Limited is the data controller of your personal data where you book services provided by that company (Belfast City Airport, Sydenham Bypass, Belfast, Co Antrim BT3 9JH, Northern Ireland; email address privacy@aerlingus.com). The relevant operator of your flight will be identified in your booking confirmation. If you are a member of AerClub, Avios Group (AGL) Limited will also separately be a "data controller" of your personal information. AGL's address is Astral Towers, Betts Way, Crawley RH10 9XY, UK and email address data.protection@avios.com. We may engage certain third parties (e.g. call centre partners, ground handling agents) to provide services on our behalf, see Section 9 below. However, if you make a booking for services offered by a third party (e.g. a connecting flight with another airline, travel insurance, car hire, a hotel room or a holiday package) then the applicable booking terms and conditions will identify the third party provider (i.e. the other airline, insurance provider, car hire provider or hotel operator) who will also separately be a "data controller" of your personal data for the purpose of providing that third party service. You can access the privacy statements of those providers from them directly. You can access the privacy statements of other airlines via https://www.iatatravelcentre.com/privacy.htm.

We collect the following data: your name, title, date of birth, passport details; contact information including email address and phone number; payment details; travel itinerary, any Aer Lingus or third party services booked or special assistance requested; purchase history; sales channel; social media interactions, information about your searches and web usage, home airport and preferences and interests. If you are an AerClub member we also collect your membership data. A full description of personal data we collect is set out in Section 4 of the Privacy Statement.

We require your information to deliver services to you and to understand your needs and provide you with a better service. From time to time, we may also use your information to contact you for market research purposes. We may use your information to improve our products and services or customize the website/app according to your interests. We may send promotional emails about special offers and deals to the email address you have provided (unless you indicate you don't wish to receive these).

In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.

If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by clicking on the unsubscribe link in each marketing email or via the unsubscribe page. We may use your personal data to send you promotional emails about third parties which we think you may find interesting. We will not sell your personal data to third parties. If you are a "registered user" of our website/app or an AerClub member you can update your account details on a self- service basis. You may request details of personal data which we hold about you (please see Section 12). If data we hold on you is incorrect/ incomplete, please contact us (details here). We will promptly correct any data found to be incorrect.

Cookies help us to keep our website functioning securely and to provide you with a better service. Cookies allow us to recognise your device or computer and to see how you interact with our website, but not to identify you as an individual. You can choose to accept or decline cookies or change your cookie preferences on the website at any time by visiting our cookie policy page and clicking the button to 'Review cookie preferences'. This button will direct you to the cookie consent banner where you can adjust the available sliders to 'On' or 'Off', then click 'Confirm My Choices'. Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set see our Cookie Policy for more details.

Our website contains links to enable you to visit other websites. Once you use those links to leave our service, we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any data which you provide whilst visiting such other websites and such websites are not governed by this Privacy Statement. You can find out how those sites use and protect your data by reading their privacy statements.

When travelling to Ireland or other countries you may be required by local authorities to complete a form and/or provide personal data as part of international Covid 19 containment/contact tracing efforts. Please see the 'Country Information' section of our website for the specific requirements in the country you are travelling to.

For travel to the US, you may be required to complete US Centre for Disease Control ("CDC") Attestation Form and Aer Lingus may be required to retain those for a period of two years and to provide individual forms to the US CDC on request. Alternatively, Aer Lingus may be required to process Proof Data for transmission to U.S. Customs and Border Patrol ("CPB") for onward transfer by CBP to the US CDC. Aer Lingus may retain a record of the transaction date and PNR Reference for audit purposes.

There may also be circumstances where your contact details and/or evidence of your compliance with pre-departure requirements, including for example proof of negative Covid 19 test and/or proof of vaccinations and/or immunity ("Proof Data") are provided by Aer Lingus (or a third party - see below) to authorities including health authorities either in Ireland or in another country to which you are intending to travel or have travelled as part of international Covid 19 containment / contact tracing efforts.

Aer Lingus is not generally the controller of Proof Data where it is provided by you directly to a third party, for example, you are handed a blank paper form to complete by an Aer Lingus staff member and you then provide the completed form directly to authorities at your destination.

You may provide Proof Data directly to a third party that Aer Lingus may partner with from time to time to verify such travel requirements, for example a third party app. Where you submit Proof Data directly to such a third party for verification/authentication, usually that third party will be the data controller of the Proof Data that you submit to them. However, there may be circumstances when Aer Lingus is the data controller of Proof Data and in that event, Aer Lingus will notify you in advance. For example, we may offer you the opportunity to provide Proof Data via a third party portal for validation prior to travel.

Where Proof Data that includes your health data is collected by Aer Lingus or a third party, you will need to provide your explicit consent for the processing of that data. Aer Lingus will require to see evidence (or not) from you that the Proof Data is sufficient to allow Aer Lingus to permit you to board the relevant Aer Lingus flight. Aer Lingus may process Proof Data that you have provided to a third party in order to update your booking on our systems with confirmation of that your Proof Data is sufficient to allow you to travel and to check-in online. You should consult the privacy statement provided by the third party to whom you submit this data for further information.

The basis of this processing being permitted under applicable data protection law because either (a) you have provided your explicit consent to the data controller, which may or may not be Aer Lingus as explained above. If you wish to withdraw your consent to this processing please contact privacy@aerlingus.com. If you withdraw your consent to the processing you will be unable to travel to the US and other countries while this requirement remains in force; (b) it is in the "vital interests" of the passenger. If you were in close contact with a confirmed case we may be required to provide your contact details to the relevant authorities so you can be contacted to be informed of this; or (c) it is justified due to "important reasons of public interest" (for example, proactive collection of Proof Data).

FULL PRIVACY STATEMENT

Any personal information processed by Aer Lingus in connection with this Privacy Statement is controlled by Aer Lingus Limited or Aer Lingus (U.K.) Limited as applicable, which is therefore considered the "data controller" of your personal information under European Union, UK and Irish data protection law. Our head office is at Dublin Airport, County Dublin, Ireland and you can contact us here.

If you have made a flight booking with us but one or more flights are to be provided by other airline(s) then that other airline will also separately be considered a "data controller" under European Union, UK and Irish data protection law. You can access the privacy statements of other airlines via https://www.iatatravelcentre.com/privacy.htm or from them directly.

Any third party provider of services such as insurance provider, third party airport lounge, airport providing car parking, a hotel, a car rental company or a package holiday provider will also separately be a "data controller". The applicable booking terms and conditions will identify the third party provider. Aer Lingus partners with third parties to provide services including car hire (Aer Lingus Cars provided by ABG Avis/Budget), hotels (Aer Lingus Hotels provided by booking.com) and package holidays (Aer Lingus Holidays provided by Click & Go). You can access the privacy statements of those providers from them directly.

If you are a member of AerClub, Avios Group (AGL) Limited and Comarch S.A. will also separately be a "data controller" of your personal information. Avios Group (AGL) Limited's address is Astral Towers, Betts Way, Crawley RH10 9XY; email: data.protection@avios.com. Comarch S.A.'s address is Al. Jana Pawła II 39 A, 31-864 Kraków, Poland, email: gdpr@comarch.com.

If you have made a booking for non- flights services or booked a "package" and the non-flight service or the package booking terms and conditions identify that your contract is also with Aer Lingus Limited then Aer Lingus will also be a "data controller" in this scenario.

Please note that there may be circumstances in the course of transiting through an airport for an Aer Lingus flight where the relevant airport operator and/or border control and immigration will collect personal data from you directly (for example, US Customs and Border control may collect biometric data from your fingerprint and/or biometric facial recognition data from your photograph; you will be made aware of this as you will be asked to press your finger to a scanner and/or approach a camera). In these circumstances Aer Lingus is neither the data controller nor the data processor of this data and you should consult the privacy statement of those third party data controllers (i.e. relevant airport operator and/or border control and immigration) for further information.

This Privacy Statement applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us as a guest or potential guest, including when you travel with us or use our other services, interact with us on social media or use our websites or mobile applications, contact our service agents or call centres, book to use our services through third parties (such as travel agents and other airlines) and/or where you are a member of AerClub (our loyalty, reward & recognition programme). Where we reference that third parties (e.g. insurance provider, car hire provider, hotel operator, package holiday operator, etc.) are also acting as data controller of your personal data (See Section 1 "Who is the Data Controller of Personal Information" and Section 9 "Who do we share your personal information with?") you should consult the privacy statements of those third parties for further information. Additional privacy statements may apply if you elect to take certain additional services from us, such as when using our onboard wifi - if this is the case you will be notified of this prior to use.

We collect personal information about you whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you travel with us, when you use our website or mobile applications, interact with us via email or social media or our online "chat" service on our website and mobile applications or use our contact centres. For additional details about the types of personal data we collect see Section 4 below "What types of Personal Information do we collect and retain?"

In addition, we may receive personal information about you from third parties, such as:

Companies involved in your travel plans, including airlines involved in your prior or onward journey, relevant airport operators and customs and immigration authorities.
Our loyalty scheme partner (Avios Group (AGL) Limited) or other companies that provide services to AerClub members by reason of their AerClub membership including Comarch S.A.
Companies that we partner with to provide other guest services, currently travel insurance providers, ABG Avis/Budget (Aer Lingus Cars), booking.com (Aer Lingus Hotels) and Click & Go (Aer Lingus Holiday)
Companies that provide customer information (like fraud prevention agencies, marketing and research companies).
Companies contracted by us to provide services to you.

If you set up or use an AerClub account or a "Registered User profile" on our website/app we will also collect data from you as part of your AerClub account or Registered User profile. AerClub is our loyalty, reward and recognition programme under which the principal benefits to members are Avios Points (provided by our sister company Avios Group (AGL) Limited ("Avios") and "Tier Benefits" provided by Aer Lingus (these vary according to Tier membership, i.e. Green, Silver, Platinum and Concierge). The "Registered User profile" is an account you can set up on our website or app with some of your personal information pre-populated. When you access and update your Registered User profile you enable us to optimise your time spent on the Aer Lingus website or mobile app.

If you are or become a member of our AerClub programme, you will also be able to check your account balance when you log in and find out additional information about your AerClub membership.

Through the use of profile information provided by you as a Registered User or AerClub member and use of a customer intelligence platform (Boxever) that collects browsing data and enables a guest profile to be created, we are able to personalise your website visit or mobile app experience, and/or ensure that we can communicate details of special offers and other travel information that may interest you. It can also save you time when you book a ticket by pre-filling the online booking section with your personal information. Your travel history may at your option be displayed when you log in.

When you communicate with us (via email, social media or our online chat service, or via our call centre) we collect the information you provide to assist in your query (for example contact information, booking reference, home airport) and the contents of the relevant communication, which we use to resolve your query as well as for training and monitoring purposes.

You may access and update the information which we hold about you as a Registered User of the website/app or as an AerClub member by logging in and accessing the relevant section in the website or mobile app.

Personal information means details which identify you or could be used to identify you, such as your name and contact details, your travel arrangements and purchase history. It may also include information about how you use our websites and mobile applications. When you use our services you will need to provide us with your personal details, or the details of those individual(s) who will be travelling (if you are booking travel for others).

We collect the following categories of personal information:

Information you provide to us in order for Aer Lingus to complete and manage a booking you have made with us or a service you have requested from us.

Examples
Your name, title, address, email, contact details, date of birth, passport number, payment information.

If you buy tickets for someone else we may collect your billing information but may communicate with the passenger directly about their flight.

We will know if you booked your flight on AerLingus.com or used another sales channel such as a travel agent or our Guest Relations contact centre.
Information collected during your travel with us.

Example
We may collect information such as your interactions with staff and cabin crew before and during the flight.
Information about your travel arrangements.

Example
Details of your booking, travel itinerary, details of any additional assistance you require and other information related to your travel with us such as dietary requirements.
Information about the services we have provided to you in the past.

Example
Details of your previous travel arrangements, such as your previous flights and travel-related issues, including upgrades received, your baggage requirements, airport disruption, lost luggage and your customer feedback.
Information about online registration and other interactions.

Example
We will retain your information to ensure we interact with you appropriately if you have registered with us, either through our AerClub programme or as a Registered User of our website and app.

We will process your information if you have entered a competition and retain your information if you have interacted with us via social media (e.g. Twitter).
Information about your use of our websites and mobile applications, subject to our Cookie Policy and your cookie preference settings. For more details of the methods please see our Cookie Policy for details.

Example
To help us to personalise your information and improve our website we may collect information (subject to your cookie preferences) about your searches and the content you have viewed on our website using cookies and similar technologies. We may (subject to your cookie preferences) use previous web usage data stored within the cookie to personalise and understand you as a guest.

We are able (subject to your cookie preferences) to understand from your website usage that you have visited AerLingus.com and searched for a flight but did not complete your booking. We may use this information to contact you to offer more information about the booking and destination (unless you have opted out of receiving marketing materials).
Information related to your use of our contact centres

Example
If you interact with our contact centre a record of the contact is kept in our Guest Relations management system; telephone calls may be recorded for quality and training purposes and the recordings retained for up to six months.
Subject to our Cookie Policy, information about your location from your device if you have been browsing on AerLingus.com or using our mobile app based on your IP address. (An IP address (i.e. Internet Protocol address) is a numeric code that can act as a unique identifier for your computer or other device - this can be turned off from your device).

Example
Identifying the county from which you are accessing the relevant website or application which will enable us to provide more relevant content and use an appropriate language.
Your account login details, including your user name and chosen password

Example
If you are an AerClub member your AerClub username and password and AerClub number.
Your contact details and details of the emails and other electronic communications you receive from us

Example
We may collect information as to whether a communication has been opened and if you have clicked on any links within that communication. We want to make sure that our communications are useful for you, so if you don't open them or don't click on any links in them, we know we need to improve those services;
Your AerClub membership data

Example
Details of the Avios points you have accumulated or redeemed and data concerning your members of other frequent flyer or loyalty programmes.

When and why do we collect "sensitive personal data"?

Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are considered to be "special categories of data" requiring additional protection under European Union, UK and Irish data protection law and are referred to here as "sensitive personal data". Generally, we try to limit the circumstances where we collect and process sensitive personal data. Examples of where we may collect and process "sensitive personal data" include the following:

You have requested specific medical assistance from us and/or an airport operator, such as the provision of wheelchair assistance or oxygen.
You have sought clearance from us to fly with a medical condition or when 28 weeks pregnant or over (up to the applicable limit).
You have otherwise chosen to provide such information to us (such as for compliance with health and travel requirements related to Covid 19 ) or it has been passed onto us by a third party such as the travel agent through which you made your booking.

In addition you may have requested services (such as a meal) which while not considered "sensitive data" but may imply or suggest your religion, health or other information.

The main purposes for which we use your personal information are:

to fulfil your travel arrangements and deliver the services you have asked for

Example
We will need to use your name, title, address, email, contact details, date of birth, passport number, your account details and payment information so that we can process bookings, fulfil your travel arrangements, take payment, provide information to relevant authorities (such as tax, customs and immigration authorities) and so that Aer Lingus agents know who is booked on a flight.
to manage the boarding process and to facilitate flight connections at the airport

Example
If you have not arrived at the gate to board your flight we may need to check whether you have passed through airport security or whether you were on a connecting flight in order to understand how to contact you about boarding the flight.
to send status updates and service communications to you

Example
We may send a communication informing you that check in is open or if your flight has been delayed.

Even if you have opted-out of receiving marketing information from us, we may still send you communications about the services you have booked to use, such as your travel itinerary. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using (e.g. advance seating requests, additional baggage and pre-booked meals).

We may also send you communications about the services you have previously used, for example, where you experienced some form of issue or problem and we wish to contact you about it proactively in order to resolve it successfully.
to help keep you safe when you fly with us and to meet certain legal and regulatory requirements which apply to Aer Lingus as an airline.

Example
As an airline there are regulatory obligations on Aer Lingus to maintain a record of passenger information on our aircraft.

The laws of certain countries, such as the UK and USA, require airlines to provide certain passenger information to the border and immigration authorities. See also the Covid 19 section above.
to provide services tailored to your requirements and to treat you in a more personal way.

Example
If you are a member of AerClub we may personalise the experience you have while flying with us. For example, a member of our cabin crew may welcome you back on board an Aer Lingus flight.

We may update and share non personal information with our media agency, in order to serve tailored and relevant advertising from our partners and third parties on our websites, applications and electronic boarding passes.
to carry out analysis and market research

Example
We will analyse the way in which our sales channels, products and services are being used by Guests so that we can understand how to improve the service we offer and encourage Guests to use the full range of our products and services.
to carry out marketing and keep you informed of Aer Lingus' products and services

Example
We may send you information about our products and services by email (or other electronic communication).

We may tailor the content of our websites, applications, emails and other communications to ensure they are as relevant to you as possible - including previous destinations including offers and/or services relating to that or a similar destination.

To understand your flying preferences and provide information about offers, such as upgrades (unless you have opted out of receiving marketing emails).

If you've searched for flights but not booked we may remind you about our services via social media services (e.g. Twitter) based on the flights you searched for previously.

We may combine/match anonymised customer relationship marketing data with a third party (e.g. Google) so both companies can understand behavioural activities such as knowing other sites visited.
to send you status updates and service communications.

Example
Even if you have opted-out of receiving marketing information from us, we may still send you communications about the services you have booked to use, such as your travel itinerary. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using (e.g. advance seating requests, additional baggage and pre-booked meals).

We may also send you communications about the services you have previously used, for example, where you experienced some form of issue or problem and we wish to contact you about it proactively in order to resolve it successfully.
to improve our websites, products and services.

Example
We may monitor the way that you and other Guests use our website so that we can identify ways to improve the website experience.
to administer your AerClub account

Example
To credit your AerClub account with Avios points after you have flown with us.
for management and administrative purposes.

Example
We may use and retain your personal information, including your purchase history, for administrative purposes, which may include for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud detection / screening (including the use of credit reference agency searches and payment card validation checks) and systems testing, maintenance and development.

When we collect information directly from you we may ask you if you do not want to receive our marketing communications. If you choose to receive email marketing from Aer Lingus, we can let you know about special offers, new routes and when tickets are on sale.

You may receive marketing communications from us if you have you made a booking with us (unless you have indicated that you do not wish to receive marketing communications). We will respect your choice as to what communications you wish to receive and how these are sent. Please be aware that we do sometimes send marketing communications that promote a third party's products and services as well as our own (for example, we may send Aer Lingus communications promoting products or services of our business partners including Aer Lingus Holidays, Aer Lingus Cars or Aer Lingus Hotels, airport car parking, Heathrow Express, and Travel Money, or we may send AerClub communications promoting products or services of our business partner Avios).

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. This enables us to send you only those offers and deals that we think will be of most interest to you.

How can you change what marketing communications you receive and how you receive them?

If you decide you would no longer like to be sent marketing communications you can change your mind at any time. The ways to stop being sent marketing communications are described below. We collect separate permissions for AerClub marketing communications and Aer Lingus marketing communications. The Aer Lingus marketing list is a separate list held and managed separately to the AerClub marketing list and unsubscribing from one list will not automatically unsubscribe you from the other i.e. you can indicate that do not wish to receive Aer Lingus marketing material but you can still opt to receive AerClub offers and deals (and vice versa).

You can change your marketing preferences for Aer Lingus marketing communications at any time at:

https://www.aerlingus.com/html/email-subscription.html to sign up
https://www.aerlingus.com/html/unsubscribeFromEmail.html to unsubscribe

In addition, each marketing communication we send by email will also have an "unsubscribe" option which will allow you to stop you receiving further marketing emails.

If you book a seat in the economy cabin on certain qualifying transatlantic fares we may send an email giving you the opportunity to make us an offer to upgrade to business class; details here: https://www.aerlingus.com/plan-and-book/plan/upgrade-yourself/. We partner with a third party provider to offer this promotion. We will not send you those emails if you have indicated that you do not wish to receive marketing communications from Aer Lingus. Each email will also have an "unsubscribe" option which will allow you to stop you receiving further of these emails.

If you are an AerClub Member you can change your marketing preferences (for AerClub marketing) at any time by logging into your account at https://www.aerlingus.com/aerclub and changing your preferences within the "My Details" tab under "My Email Notifications".

We aim to action requests to stop being sent marketing communications within 24 hours of receiving those requests (but it may take up to 48 hours) and it is possible you will receive some marketing in the period prior to that change being made.

Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications which are necessary, for example, to confirm your booking or to provide you with an update you on its status. If you are an AerClub Member, we will continue to keep you informed about your membership and other important service information relating to AerClub. If you ask us to stop sending AerClub marketing communications please note we will retain your personal information for the purposes of indicating that you do not want to receive AerClub marketing communications. If you ask us to stop sending Aer Lingus marketing communications please note we will retain your personal information for the purposes of indicating that you do not want to receive Aer Lingus marketing communications.

Marketing to Children

We do not knowingly send marketing/promotional emails to children under the age of 16.

Aer Lingus will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons Aer Lingus collected and needs to use your information. Under EU and Irish data protection laws in almost all cases the legal basis will be:

because we need to use your information so that we can process your booking, fulfil your travel arrangements and otherwise perform the contract we have with you; or
because it is in Aer Lingus' legitimate interests as an airline to use your personal information in order to operate and improve our business as an airline and travel provider; or
because Aer Lingus needs to use your personal information in order to comply with a legal obligation; or
to protect the vital interests of you or another person; or
because you have consented to Aer Lingus using your information for a particular purpose.

More information on each legal basis is provided below. In the event that processing of your data is subject to any other laws (other than EU and Irish laws) then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent (as defined according to those laws) in all cases.

Performance of a contract with you

It will be necessary for Aer Lingus to use your personal information in order to complete a booking you have made with us. For example, we will need to use information such as your contact details and payment information in order to provide you with the flight you have requested and paid for. If you are an AerClub member it will be necessary for Aer Lingus to use your personal information in order to manage and administer your AerClub membership and to provide member benefits.

Legitimate Interests

As a commercial airline and travel provider Aer Lingus has a legitimate business interest to use the personal information we collect in order to offer an effective service and carry out our business.

Compliance with legal obligations

There are situations where Aer Lingus is subject to a legal obligation and needs to use your personal information in order to comply with those obligations.

To protect the vital interest of you or another person

There are situations where we may need to use your personal information in order to protect the vital interests of you or another person.

Consent

Alternatively, we may collect and use your personal information where you have given your specific consent to us doing so.

Where the basis of our processing your data is consent, you can withdraw your consent to such processing at any time by contacting Special Assistance at https://www.aerlingus.com/travel-information/special-assistance/disability-assistance/. However if you withdraw this consent it may mean we will not be able to provide all or parts of the services you have requested from us and in some circumstances you may not be able to cancel your booking or obtain a refund of any charges you have paid.

We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you book a flight with us we will keep the information related to your booking so we can fulfil the specific travel arrangements you have made and after that we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you. We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a guest, we will remove or anonymise information kept for that purpose after 7 years. When we have collected the personal information based on your consent and we have no other legal reason for retaining the information, if you then decide to withdraw your consent, we will delete your information as detailed below in Section 11(e).

Your personal information may be shared with the companies within our group, which includes Aer Lingus, International Consolidated Airlines Group S.A (IAG), British Airways, Iberia, Iberia Express, Vueling, Level, British Airways Holidays, Avios, BA CityFlyer, IAG Connect and IAG GBS. For more details about our group please visit the website of our parent company, IAG (www.iairgroup.com). We share information with them so they can assist us in providing services to you and to understand more about you. For example, if you have flown with one of the other airlines in the IAG Group we may use this information to understand more about the sorts of travel services you are likely to be interested in. You will only be sent marketing from other companies within our group where you have agreed to this.

We may also disclose your personal information to the following third parties for the purpose described here:

customs and immigration authorities of any country in your itinerary or to which your flight may fly over. Aer Lingus and other airlines are required by laws in the UK, USA and other countries to give border control agencies and customs authorities access to booking and travel information when you fly to and from countries including stop-overs and where you may overfly countries en route to your destination. Further information about Advanced Passenger Information is available here https://www.aerlingus.com/travel-information/passports-and-visas/travel-to-from-usa/. Under U.S. Law, U.S. Customs and Border Protection (CBP) will receive certain travel and reservation information, known as Passenger Name Record or PNR data, about passengers flying between the European Union and the U.S. CBP has undertaken that it uses this PNR data for the purposes of preventing and combating terrorism and other transnational serious crimes. The PNR may include information provided during the booking process or held by airlines or travel agents. The information will be retained for at least three years and six months and may be shared with other authorities. Further information about these arrangements, including measures to safeguard your personal data, can be obtained on www.dhs.gov and ec.europa.eu. Please also refer to the Covid 19 section above.

Example
Many governments around the world require some passport and travel information (Advanced Passenger Information) from airlines about the people flying into their country. When required, Aer Lingus will provide this information to the relevant customs and immigration authorities. This information includes information held in the machine-readable zone (MRZ) of your passport (passport number, country of issue, passport expiry date, given names, last name, gender and date of birth) together with other information which is not held in the MRZ of your passport (country of residence, citizenship, alien registration card number, destination address in the USA).
Airlines and other service providers needed to deliver the services you have asked for where, for instance, part of your travel itinerary involves a flight operated by a different airline or includes car hire with Aer Lingus Cars provided by ABG Avis/Budget, a hotel booking Aer Lingus Hotels provided by Booking.com or a holiday package with Aer Lingus Holidays provided by Click and Go. Those airlines and other service providers will be identified when you make a booking.

Example
If your destination involves transferring from Aer Lingus onto another airline either within or outside the IAG group.
Our partner airlines and franchisees (for example, Emerald Airlines which operates under the Aer Lingus Regional brand) to facilitate your flight transfers or to administer benefits because of cooperation between loyalty programmes.
Travel agents and other third parties who you book travel through
If you have joined AerClub or another affiliated loyalty program, our partners in AerClub and other loyalty schemes that you have joined so that we can administer the benefits of the loyalty programme to you
Banks, credit and charge card companies, mobile payments providers (such as ApplePay), credit reference agencies and anti-fraud screening service providers in order to process payments and (where necessary) to carry out fraud-screening
In response to a valid, legal request from Government and law enforcement agencies such as customs and immigration authorities
Third party service providers we are using to provide services that involve data processing, for example, to carry out marketing initiatives or run customer surveys on our behalf; to provide flight related SMS confirmation messages to guests; to facilitate delivery of Avios accrual and redemption data to Aer Lingus co-branded credit card holders.
If you book a ticket through our website or app to travel with pre-booked onward transport service (e.g. Heathrow Express) we will provide the transport company with your name and email address so your ticket can be issued and your booking made.
Third parties, such as law firms and law courts, in order to enforce or apply any contract with you
Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our guests, staff and assets.
To third party websites; subject to our Cookie Policy and your cookie preference settings, we may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites (see more "Cookie Policy").
If necessary to comply with a legal or regulatory obligation in any jurisdiction, including where that obligation arises as a result of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision)

We do not sell personal information to third parties. A list of the categories of third parties with whom Aer Lingus may share Guest data is available on request from Privacy@AerLingus.com.

What countries will your personal information be sent to?

Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and in particular outside the European Economic Area ("EEA").

The nature of our business means it is often necessary for us to send your personal information outside the EEA in order to fulfil your travel arrangements. This occurs because our business and the third parties identified in "Who do we share your personal information with?" have operations in countries across the world. For example, where you are flying outside of the European Economic Area, your personal information will be transferred to border control and immigration outside of these territories. In addition we may transfer your data to parties in countries outside the country in which you are located to provide services to us. This may involve sending your data to countries where under their local laws you may have fewer legal rights. However, wherever we store your information we will treat it in accordance with this Privacy Statement and the requirements of European and Irish data protection law which requires adequate safeguards to be put in place for transfers of data outside the EEA, unless a derogation is permitted under the applicable data protection law. If you would like more information on these safeguards please contact the Aer Lingus DPO (contact details below).

Aer Lingus uses Secure Socket Layer (SSL) technology. If your browser supports SSL, and if you entered our website or app via our secure server access or mobile app, then transmission of your personal data will be protected and will be encrypted as it travels from your computer/mobile device to Aer Lingus. That includes credit/debit card information you enter to pay for your flight or ancillaries. When credit card data is received, the information is decrypted and processed in the same way as a normal credit card transaction would be processed by telephone.

If your browser does not support SSL, we recommend that you upgrade to the latest version of any browser to enhance the security of further transactions, otherwise the transmission of your personal data may not be protected and Aer Lingus disclaims any responsibility in this regard.

Take a look through our easy tips to assist you with using aerlingus.com safely and securely. https://www.aerlingus.com/support/technology-suggestions/

Keep your booking reference confidential

When you make a booking you will be given a booking reference (also known as a PNR or "Passenger Name Record"). This will appear on the email confirmation or ticket of each person in your booking (and may appear on your bank statement where you use a credit or debit card for payment). You should keep your booking reference confidential at all times. Giving your booking reference to others may allow them to access your booking details through our system. You should also take care to dispose of any hard copies securely. If you are travelling with others and would not like your individual booking details to be accessible by them, you may prefer to have each person make separate bookings, to be paid for individually.

Under data protection laws in the European Union, the UK and in Ireland, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within 1 month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to two months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.

You may access and update the information which we hold about you as a Registered User of the website/app or an AerClub member by logging in and accessing the relevant section in the website or mobile app.

Your rights include the following:

your right of access to your personal information we hold.
There are some limited exceptions to this right such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged. Please see "Accessing your personal information" below for more details.
your right to ask us to stop sending you direct marketing.
To change your marketing preference please refer to the section "When will we send you marketing communications?" above.
your right to ask us to correct the personal information you have shared with us (the "right of rectification") if that information is inaccurate. You may be able to update much of it yourself through your AerClub and/or aerlingus.com account (should you be a "registered user" of Aerlingus.com) including personal and contact details. If you spot any inaccuracies that you can't fix yourself, please email the details to privacy@aerlingus.com. We are not able to amend any data that has been created as a result of a transaction with us e.g. flight history.
your right to withdraw consent to processing of data where consent is relied upon by us as the basis of processing.
Please note that if you withdraw this consent it may mean we will not be able to provide all or parts of the services you have requested from us and in some circumstances you may not be able to cancel your booking or obtain a refund of any charges you have paid.
your right to ask for personal information which identifies you to be removed (anonymised) (also known as the "right to be forgotten") without undue delay in certain circumstances, for example:
- when you withdraw your consent to processing in circumstances where we have collected the personal information based on your consent and we have no other lawful basis to continue to retain the information
- where you object to the processing and there is no overriding legitimate grounds for us to continue the processing (See point f below);
- where your personal data has been unlawfully processed.

For more information on the basis on which we process your personal information see What is our legal basis for using your personal information?

Please note that in some circumstances if you exercise this right before you travel, it may mean we will not be able to provide all or parts of the services you have requested from us and you will not be able to cancel your booking or obtain a refund of any charges you have paid. Please note while we will endeavour to erase data in circumstances where an individual has exercise this right and we don't need the data anymore some personal data sets are impossible (or infeasible) to edit to remove individual records, e.g. a server backup or a piece of microfiche.

your right to object to the use of your personal information where the basis of our processing the information is our legitimate interests (unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights)
your right to object to the processing of your personal information for direct marketing purposes including profiling for the purposes of direct marketing.
Please note if you exercise this right in relation to all Aer Lingus marketing communications we will no longer send you marketing communications however we will still send you communications about the services you have booked to use, such as your travel itinerary. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using (e.g. advance seating requests, additional baggage and pre-booked meals). In addition, we will also need to retain and process some of your personal information to make sure you are excluded from future marketing communications.

Please note that opting out of Aer Lingus marketing communications will not have the effect of removing you from the AerClub marketing list as these are maintained as two separate marketing lists and Guests opt into each list separately. If you opt out of Aer Lingus marketing communications but have separately opted in to receive AerClub marketing communications you will continue to receive AerClub marketing communication until such time as you indicate you no longer wish to do so. You can do this at any time by logging on and changing your AerClub account settings or by clicking "unsubscribe" in any AerClub marketing email.
your right to object to automated processing which has a legal effect or similarly significant effects.
- Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
- Aer Lingus uses a Robotic Process Automation (RPA) platform to process an Automated Refunds System that is able to process, without human intervention, certain of the refund requests received from our Guests. Aer Lingus also uses an RPA platform to process certain voucher requests that is able to process, without human intervention, many of the voucher (in lieu of refund) requests received from our Guests.
- Data received in the Refund Request Form from you is used by the Automated Refunds System to access booking information, determine refund eligibility, issue refund instruction and send a confirmation letter to you. Similarly, data received in the Voucher Request Form from you is used by the voucher bot to access booking information, determine voucher eligibility, issue a voucher instruction and send a confirmation to you.
- You have certain rights in respect of automated decision making: you can ask not to be subject to a decision which is based solely on automated processing where that decision produces legal effects concerning you (such as the rejection of a claim); or otherwise significantly affects you. In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
- Your right not to be subject to automated decision making does not apply where the decision which is made is: (a)s necessary for entering into or performing a contract with you; (b) authorised by law and there are suitable safeguards for your rights and freedoms; or (c) based on your explicit consent. However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision. A Guest can do this (i.e. obtain human intervention in the processing of their refund claim) either by (i) using this form to update their existing issue that they have already submitted:
  https://www.aerlingus.com/support/forms/case-update/ or (ii) using this form https://www.aerlingus.com/support/forms/post-travel-enquiry/. If you have any questions about the automated decision making please contact the Data Protection Officer for Aer Lingus at privacy@aerlingus.com or in writing to Data Protection Officer, Aer Lingus, Dublin Airport, County Dublin, Ireland.

If you are an AerClub Member or an AerLingus.com registered user and wish to retain your membership or registration you may not be able to exercise some of these rights as we need to process your personal information is required to deliver those services to you.

Please note:

We may need to retain certain elements that relate to a contract between you and Aer Lingus because we need it for our own legal and auditing purposes (for more information on the basis on which we process your personal information see the section 7 above What is our legal basis for using your personal information?.
In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us in relation to previous travel or retain any preferences you have previously shared with us.
We cannot erase your personal information if you are a member of our AerClub as we require this information to deliver our contract with you unless you confirm that you wish to close your AerClub account in which case your account will be closed.
We cannot erase your personal information if you have either flown with us in the past 13 months or you hold a forward booking with us. For Legal reasons, we need to keep information linked to these flights. You may come back to us once this time period has passed and submit a request for personal information which identifies you to be removed. To do this we will remove the information that identifies you from the data we hold in our active systems ("anonymise"). However, a separate and restricted copy of the identifying information will be kept for 7 years to meet the obligations we have to law enforcement, national authorities and legal proceedings.
A record of your individual rights request including the personal information you supplied will be retained for up to 3 years.
We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint.

Accessing your personal information

You can view the following information we hold on you on a self-service basis:

If you are an AerClub member you can view personal information held within your AerClub account by logging into your account.
If you are a "registered user" of the AerLingus.com website you can view personal information held within your registered user account by logging into your account.

Multiple failed attempts to log in to an account will result in the account being locked for a duration and will require sufficient information to verify identity to be unlocked.

Alternatively if you wish to access other personal information we hold about you or exercise any other rights we recommend that you make your request in writing and include the following information with your request:

Your name
The email address used for the relevant booking / processing (if applicable)
Details of your request

We need corroborating information to establish your identity. You must also provide:

In all cases, a photocopy of your passport or driving licence, so that we can verify your identity
proof of address (e.g. utility bill) dated within the last 6 months (if you wish to receive a response in hard copy)
if you are applying on behalf of another person then signed authority (in a form satisfactory to Aer Lingus) from the individual is required

Any details which may help us locate the information which is the subject of your request, for example:

Booking reference or flight numbers and dates
AerClub number
Telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call(s)).

Please send your request to: privacy@aerlingus.com Or alternatively send your request in writing to:

Data Protection Officer
Aer Lingus Limited
Dublin Airport
Co Dublin

If you contact our call centre (see Contact Us) to submit an individual rights request, they may refer you to contact privacy@aerlingus.com.

If you wish the information to be provided to you in a machine-readable format please indicate that at the time of making your request.

If we change this Privacy Statement, we will let you know about the changes by publishing the updated version on AerLingus.com and our mobile app. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Statement.

This Privacy Statement came into effect on 20 May 2021 replacing our previous Privacy Statement. This Privacy Statement applies to all information we process about you in connection with your relationship with us as a guest or potential guest.

Please write to the Data Protection Officer if you would like to find out more about any matters to do with this Privacy Statement.

If you have any questions about this policy or you have any concerns about our handling of your information, please send them to the Data Protection Officer. The Data Protection Officer for Aer Lingus can be contacted at privacy@aerlingus.com or in writing to Data Protection Officer,
Aer Lingus,
Dublin Airport,
County Dublin,
Ireland.
We hope we will be able to resolve any concerns you may have.

You have a right to complain to the Data Protection Commissioner in Ireland at:

Data Protection Commissioner,
Canal House,
Station Road,
Portarlington,
R32 AP23
Co. Laois
https://www.dataprotection.ie/docs/Contact-us/b/11.htm

If your booking was with Aer Lingus (U.K.) Limited, you have a right to complain to the UK's Supervisory Authority for data protection, the Information Commissioner at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Aer Lingus Privacy Statement

Aer Lingus is committed to respecting your privacy and protecting your personal information