The entity responsible for your personal information is Etihad Airways PJSC, of which Etihad
Cargo is a division.
Etihad Airways PJSC is a Public Joint Stock Company established by Emiri Decree and
incorporated in the Emirate of Abu Dhabi, United Arab Emirates. Etihad operates through various
branch offices, departments and operating divisions, including Etihad Airways, Etihad Holidays
and Etihad Cargo. Etihad Airways PJSC forms part of the Etihad Aviation Group. If you would like
to review the Etihad Aviation Group Privacy Statement, please visit
www.theetihadaviationgroup.com or write to the Ethics and Compliance Office, Etihad Aviation
Group, Head Quarters, Khalifa City A, PO Box 35566, Abu Dhabi, UAE.
At Etihad Airways PJSC, and our affiliates and branch offices (collectively referred to as "Etihad
Airways", "we", "us"), we take our data protection and privacy responsibilities seriously. This
statement describes how we collect, process, use, disclose and transfer your personal information
as a data controller. It covers instances when you contact us, use our services or interact with our
websites, such as www.etihad.com, and Etihad mobile apps (together "Etihad Websites").
Terms of Use
Use of the Etihad Websites is subject to our terms of acceptable use, found in our Terms and
Conditions. Any products and services supplied are subject to our Terms and Conditions,
Customer Care Policy and General Conditions of Carriage.
Updates
We may amend this statement from time to time to keep it up to date with legal requirements and
the way we operate our business. Please regularly check these pages for the latest version of this
statement. If we make material changes to this privacy statement, we will seek to inform you by
notice on our website or email ("Notice of Change").
Third Party Websites
Etihad Websites may link you to other websites. We are not responsible for the way in which third
party websites operate or the way in which they may process any personal information, which you
provide to them. It is important that you understand this and check their respective privacy policies
and terms of use.
Please note that all products and services are supplied subject to our Terms and Conditions and
General Conditions of Carriage.
WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT
2.1.1. When you use services provided on the Etihad Cargo Website, you will be asked to provide
certain information such as your name and contact details. We will hold, store and use personal
information (which will be processed with/by electronic and non-electronic means) in order to:
2.1.2. Register you with the Etihad Cargo Website and administer our Website services, such as
requests for shipping cargo;
2.1.3. Fulfil any agreement we have with you;
2.1.4. Provide you with our services, including personal cargo services;
2.1.5. Enable you submit a purchase order;
2.1.6. Administer our Cargo Loyalty Program policy when it is implemented;
2.1.7. Answer any queries, including feedback, claims, complaints which you may send us;
2.1.8. Allow you to contact us in the different ways set out on the Etihad Cargo Website; and
2.1.9. Achieve any other purpose notified on the Etihad Cargo Website.
LEGAL BASIS FOR USING YOUR DATA
3.1. We will only collect, use and share your personal information where we have an
appropriate legal basis to do so.
3.1.1. Where we need to use your personal information to perform a contract or take steps to enter
into a contract with you, for example to take payment for and complete an cargo shipment you
place with us
3.1.2. Our legitimate interests as a commercial organisation, for example we may record calls to
our customer service centre so that we can review our call handling processes and ensure we
provide a continuously high standard of customer service; we may use customer contact
information to keep our customers informed about their shipment and to provide other important
service messages; we may also let you know about our new routes and special offers that may be
of interest to you - in these cases we will respect your privacy rights and ensure you may object to
processing as explained in the "Your Rights" section below; and
3.1.3. Where we need to use your personal information to comply with a relevant legal or
regulatory obligation that we have, for example in some countries we are required to share Airway
Bill information with law enforcement officials in destination airports which will contain information
about the shipper and consignee.
3.2. If you would like to find out more about the legal bases upon which we process
personal information please check the below table:
Further details
Legal basis for using personal information
1
In order to register you on the Etihad Cargo Website, we will need to process personal information
about you such as your:
name
date of birth
address
email address
telephone number
To perform our contract with you.
In order to take steps, at your request, to register
with the Etihad Cargo Website.
2
In order to adminster our services via the Etihad Cargo website, such as requests for shipping
cargo, we will need to process personal information about you such as your:
job title
Etihad Guest number
online website tracking (cookies)
3
In order to fulfil any agreement we have with you such as processing a purchase order we
will need to process personal information about you such as your:
4
In order to administer the Cargo Loyalty Program we will need to process personal
information about you such as your:
To enter into a contract with you.
In order to take steps, at your request, to enroll you
on the Cargo Loyalty Program.
5
In order to provide you with customer support including for inbound calls relating to
purchase orders, personal cargo services,and to answer any queries, we will need to process
personal information about you such as your:
It is in our legitimate interests to ensure that our
business runs smoothly and that we provide you
with timely customer support without undue delay
or complication. It is unlikely that doing this will
override your interests or fundamental rights and
freedoms which require protection of your
personal data.
If you are a data subject protected by the GDPR,
you have rights to restrict or object to this
processing however, please note that this may
adversely affect our ability to provide you with
effective customer support.
6
In order to handle complaints made by you we will need to process your personal
information such as your:
your name
date of birth
address
email address
telephone number
Our Legitimate Interests.
It is in our legitimate interests to ensure that we
handle your complaints in an efficient manner
without undue delay or complication. It is unlikely
that doing this will override your interests or
fundamental rights and freedoms which require
protection of your personal data.
effective complaints handling.
10
In order to provide specific information to law enforcement or similar bodies upon request,
or to help detect and prevent criminal activity,we will need to process your personal
information such as your:
Processing is necessary for compliance with a legal
obligation to which we are subject.
employer
11
In order for us to comply with a request by law enforcement or similar bodies to share
information with them,we may need to process your personal information such as your:
name
employer
Our Legitimate Interests
It is in our legitimate interests to be able to share
information with law enforcement or similar
bodies from time to time, subject to their
legitimate requests. We will need to be able to
process this information in order for us to comply
with legitimate requests including, in cases where
we determine that we are not compelled to do so
by applicable laws.
Prior to doing so, we will ensure that by properly
exercising our right to act in our legitimate interest
to share the requested data, we will not be
overriding your interests or fundamental rights and
12
In order for us to defend the claim brought by you or a third party, we may need to process
your personal information such as your:
elephone number
Etihad guest number
It is in our legitimate interests to be able to
commence or defend legal claims as and when we
consider it necessary for the protection of our
business. We will need to be able to process this
information in order for us to instruct our legal
counsel and fully defend ourselves against the
claim you may bring.
It is unlikely that by properly exercising our rights
to commence or defend claims, we will override
your interests or fundamental rights and freedoms
which require protection of your personal data.
the claim you may bring.
13
In the event that we wish to commence a claim against you, we may need to process your
personal information such as your:
3.3. HOW WE SHARE INFORMATION WITH OTHERS
3.3.1.. We work closely with a number of trusted partners with whom we need to share information
to help us provide our services:
3.3.1.(a). Our group or affiliate companies around the world including other Etihad brands such as
Etihad Cargo Etihad Holidays and Etihad Guest – see the table below [A1] for a list of Etihad
Airways affiliates;
Etihad Airways Affiliates
Country
Operating Affiliate
Entity Name & Address
United Arab Emirates
Etihad Guest LLC
New Airport Road
Khalifa City 'A',
PO Box 35566
Abu Dhabi
Etihad Airport Services Ground LLC
Global Business Service Solutions LLC
A Wing 2nd Floor Times Square Andheri Kurla Road,
Andheri East, Mumbai – 400059.
3.3.1.(b). Partner airlines where your shipment involves a codeshare;
3.1.1.(c). Frequent flyer and other reward and partner programmes where required to enable you
to earn or utilize frequent flyer miles by virtue of your membership of the Cargo Loyalty Program or
Etihad Guest;
3.3.1.(d). Banks and payment providers to authorise and complete payments;
3.3.2. Other third parties who help manage our business and deliver services. For example
3.3.2.(a). These may include IT service providers who help manage our IT and back office
systems or third party booking agents; and
3.3.2.(b). With customs and / or immigration departments or other regulatory authorities or
government entities to comply with legal obligations and ensure the safety of all our passengers
and customers.
3.3.3. From time to time we may share information about you with government organizations and
agencies and international organisations to comply with applicable laws regulations and rules and
legitimate requests from law enforcement regulatory and other governmental or international
agencies or when to do so is in our legitimate interests even if we are not compelled to share that
information by applicable law. Further information about when we do this can be found in the
table above on legal bases for using your information.
3.3.4. If in the future we sell or transfer some or all of our business or assets to a third party we
may disclose or transfer information to a potential or actual third party purchaser of our business
or assets.
MORE ABOUT DIRECT MARKETING PROFILING AND AUTOMATED DECISION MAKING
4.1. Direct marketing
4.1.1. We are committed to keeping you informed about our products and services in line with your
personal preferences.
4.1.2. We will usually send this by email but we may choose to contact you in other ways for
example by phone post SMS and/or other electronic means if that is more appropriate.
You can ask us to stop sending you marketing material at any time by contacting us.
4.2. Managing your marketing preferences
4.2.1. To protect privacy rights and to ensure you have control over how we manage marketing
with you:
4.2.1.(a). We will take steps to limit direct marketing to a reasonable and proportionate level and
only send you communications which we believe may be of interest or relevance to you
4.2.1.(b). You can also ask us to remove you from our mailing list by sending us an email ).
4.2.1.(c). You can change the way your browser or device manages cookies which may be used
to deliver online advertising by following the settings on your browser as explained below in the
section on cookies.
4.2.2. We recommend you routinely review the privacy statements and preference settings that
are available to you on any social media platforms.
4.3. More about profiling and analytics
4.3.1. We may use some of the information you provide to us in order to perform profiling and
analytics with the data. We will do this either with your consent or where it is in our legitimate
interests.
4.3.2. One of the methods by which we do this is by installing and using Cookies on your browser
or device. You can learn more about how to adjust settings relating to Cookies on your browser
and device and about our Cookie Policy in the section titled Cookies and Mobile below.
4.3.3. Some of the legitimate purposes we profile and analyse data include:
4.3.3.(a). To allow us to enhance our provision of services to you;
4.3.3.(b). To provide you with tailored content online and optimise your experience of our
websites;
4.3.3.(c). To offer personalised products when you ship with us or use our other services;
4.3.3.(d). To obtain a better understanding of our customers
4.3.3.(e). What you would like to see from us
4.3.3.(f). And how we can improve our services for you;
4.3.3.(g). To share advertising material we believe may be of interest to you
4.3.3.(h). To help us operate our services more efficiently
4.3.3.(i). Including to ensure that our most loyal customers obtain the best services.
4.3.4. If you are a Data Subject with rights under the GDPR then we will take steps to ensure that
prior to profiling your information for a legitimate interest that our legitimate interest is not
overridden by your own interests or fundamental rights and freedoms. If you are a Data Subject
with rights under the GDPR you may have rights to object to us profiling your personal information.
You can learn more about profiling and analytics under the GDPR here.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
5.1. We operate our business on a global basis. The countries to which we commonly disclose
your personal information include the United Arab Emirates ("UAE"), where we have our head
offices, the United States of America ("USA"), United Kingdom ("UK") and the countries where you
are flying to and from. Some of these countries for example the UAE and the USA have laws
which do not offer in the opinion of the European Commission or other supervisory authorities an
adequate level of data protection.
5.2. We will always strive to adopt appropriate standards of privacy protection wherever your
personal information is located and adopt appropriate measures (consistent with locally applicable
laws) to secure an adequate level of privacy protection. We will take appropriate steps to ensure
that transfers of personal information are in accordance with applicable laws and carefully
managed to protect your privacy rights and interests. Transfers will be limited to countries which
are recognized as providing an adequate level of legal protection or where we can be satisfied that
alternative arrangements are in place to protect your privacy rights. To this end:
52.1. We ensure transfers within Etihad Group will be covered by an agreement entered into by
members of Etihad Group (called an "intra-group agreement") which contractually obliges each
member of the Etihad Group to ensure that personal information receives an adequate and
consistent level of protection wherever it is transferred within Etihad Group;
5.2.2. Where we transfer your personal information outside Etihad Airways or to third parties who
help provide our products and services we obtain contractual commitments from them to protect
your personal information. Some of these assurances are well recognized certification schemes
like the "EU - US Privacy Shield" for the protection of personal information transferred from within
the European Union ("EU") to the USA; or
5.2.3. Where we receive requests for information from government entities international
organisations or regulators we carefully validate these requests to ensure that it is legally
appropriate to share the requested personal information.
5.3. You have a right to contact us for more information about the safeguards we have put in place
(including a copy of relevant contractual commitments) to ensure the adequate protection of your
personal information when this is transferred as mentioned above. See also the section titled
"Your Rights" below.
HOW WE PROTECT AND STORE YOUR INFORMATION
COOKIES AND MOBILE
YOUR RIGHTS - LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
8.1. You may have certain legal rights regarding your personal information depending upon
the country you are in or how we interact with you. You can learn more about this in this
section.
8.2. Subject to the terms of this Privacy Statement we guarantee that you have following key rights
wherever you are:
8.2.1. To access your personal information. We will tell you what personal information we hold
about you and can provide you with a copy of this.
8.2.2. To seek rectification of that personal information. Where the personal information we
hold about you is inaccurate we will rectify this, upon your request. Note that this right may be
limited in terms of the scope of detail that we will or can rectify.
8.2.3. To lodge a complaint to us. We will receive and handle your complaints in accordance
with best practice and depending upon where you are and whether we are subject to it, any
applicable law.
8.3. If you benefit from rights as a data subject under the EU General Data Protection
Regulation ("GDPR"), you will have certain additional rights in relation to our handling of
your personal information.
8.3.1. To access your personal information
8.3.1.(a). You have a right to request that we provide you with a copy of your personal information
that we hold and you have the right to be informed of; (a) the source of your personal information;
(b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d)
the entities or categories of entities to whom your personal information may be transferred.
8.3.2. To seek rectification of that personal information
8.3.2.(a). You have a right to request that we rectify inaccurate personal information. We may
seek to verify the accuracy of the personal information before rectifying it.
8.3.2.(b). We are not required to comply with your request to erase personal information if the
processing of your personal information is necessary:
for compliance with a legal obligation; or
for the establishment, exercise or defence of legal claims.
8.3.3. To erase personal information;
8.3.3.(a). You can also request that we erase your personal information in limited circumstances
where:
8.3.3.(b). It is no longer needed for the purposes for which it was collected; or
8.3.3.(c). You have withdrawn your consent (where the data processing was based on consent);
or
8.3.3.(d). Following a successful exercise of the right to object (see right to object); or
8.3.3.(e). It has been processed unlawfully; or
8.3.3.(f). To comply with a legal obligation to which Etihad is subject.
8.3.4. To restrict the processing of your personal information;
8.3.4.(a). You can ask us to restrict the processing of your personal information, but only where:
Its accuracy is contested, to allow us to verify its accuracy; or
The processing is unlawful, but you do not want it erased; or
It is no longer needed for the purposes for which it was collected, but we still need it to
establish, exercise or defend legal claims; or
You have exercised the right to object, and verification of overriding grounds is pending.
8.3.4.(b). We can continue to use your personal information following a request for restriction,
we have your consent; or
to establish, exercise or defend legal claims; or
to protect the rights of another natural or legal person.
8.3.5. To transfer your personal information;
8.3.5.(a). You can ask us to provide your personal information to you in a structured, commonly
used, machine-readable format, or you can ask to have it transferred directly to another data
controller, but in each case only where:
the processing is based on your consent or on the performance of a contract with you;
and
the processing is carried out by automated means.
8.3.6. To object to the processing of personal information;
8.3.6.(a). You can ask us to stop processing your data where our legitimate interest is our legal
basis for doing so unless we can show compelling legitimate grounds for continuing to process
your data which override your own interests, or where we need to do so in order to defend legal
claims against Etihad Group;
8.3.7. To obtain a copy of personal information safeguards used for transfers outside your
jurisdiction;
8.3.7.(a). You can ask to obtain a copy of, or reference to, the safeguards under which your
personal information is transferred outside of the European Union. We may redact data transfer
agreements to protect commercial terms; and
8.3.8. To lodge a complaint with your local supervisory authority.
8.3.8.(a). You have a right to lodge a complaint with your local supervisory authority if you have
concerns about how we are processing your personal information.
8.3.8.(b). We ask that you please attempt to resolve any issues with us first, although you have a
right to contact your supervisory authority at any time.
8.4. A further explanation of these general key rights and the GDPR specific rights is outlined
under each heading. Please click on these for further details.
8.5. You may have other rights depending upon the country you are in. You may therefore have
rights to lodge a complaint to a local privacy authority.
8.6. If you wish to access any of these rights, we may ask you for additional information to confirm
your identity and for security purposes, in particular before disclosing personal information to you.
We reserve the right to refuse to provide this additional information if your request is manifestly
unfounded or excessive.
8.7. You can exercise your rights by contacting us at ethicscompliance@etihad.ae. Subject to
legal and other permissible considerations, we will make every reasonable effort to honour your
request promptly or inform you if we require further information in order to fulfil your request.
8.8. We may not always be able to address your request fully, for example if it would impact the
duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a
different way.
CONTACT US
9.1. The primary point of contact for all issues arising from this privacy statement, is the Etihad
Aviation Group Data Protection Officer. The Data Protection Officer can be contacted in the
following ways:
Please email us at ethicscompliance@etihad.ae or write to the Data Protection Officer,
Etihad Aviation Group, PO Box 35566, Abu Dhabi, United Arab Emirates
9.2. If you have any questions, concerns or complaints regarding our compliance with this
statement and the data protection laws, or if you wish to exercise your rights, we encourage you to
first contact us. We will investigate and attempt to resolve complaints and disputes and will make
every reasonable effort to honour your wish to exercise your rights as quickly as possible and in
any event, within the timescales provided by data protection laws.
9.3. To contact your data protection supervisory authority
9.3.1. In some EU countries, you may have a right to lodge a complaint with your local data
protection supervisory authority. We ask that you please attempt to resolve any issues with us
before your local supervisory authority.
OUR REPRESENTATIVE IN THE EU
10.1. Etihad Aviation Group P.J.S.C. is represented in the European Union by Etihad Airways
P.J.S.C. through its European regional headquarters in London. The group Data Protection Officer
can be contacted either directly by email or post using the details given in the previous section, or
by writing to our London office:
For the Attention of the Etihad Aviation Group Data Protection Officer,
Etihad Airways,
200 Hammersmith Road
London, W6 7DL
United Kingdom
