PRIVACY POLICY

1.1  Welcome to Ethiopian Airlines (“EA”) privacy notice. We respect your privacy and are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data as an EA customer, potential customer and vendor and provides information about your privacy rights and how the legislation protects you. We are the data controller and responsible for your personal data.

1.2  We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact using the below contact details.

2.1   Our full details are:

            Full name of legal entity:        Ethiopian Airlines Group

            Email address:                        customerrelations@ethiopianairlines.com

            Postal address:                        1755

2.2  You have the right to make a complaint at any time to your country’s supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority, so please contact us in the first instance using the contact details above.

3.1  This version was last updated on May 24, 2018 and historic versions can be obtained by contacting us.  This version replaces all previous versions with effect from the effective date of this privacy policy; namely May 24, 2018.

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

4.1  Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identity has been removed (anonymous data).

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

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

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

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

4.6  Disclosure means making personal data accessible.

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

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

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

5.1  Our website (www.ethiopianairlines.com) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and thus ET shall not be responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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

6.1.1  Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

6.1.2  Contact Data includes billing address, delivery address, email address and telephone numbers.

6.1.3  Financial Data includes bank account and payment card details.

6.1.4  Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

6.1.5  Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

6.1.6   Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

6.1.7  Usage Data includes information about how you use our website, products and services.

6.1.8  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

6.2  We do sometimes collect sensitive personal data about you such as details about your race or ethnicity, religious or philosophical beliefs, information about your health and genetic data as well as criminal convictions and offences.

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

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

8.1.1  Where we need to perform the contract we are about to enter into or have entered into with you and/or in order to take steps at the data subject’s request prior to entering into a contract,

8.1.2  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

8.1.3  Where we need to comply with a legal or regulatory obligation;

8.1.4   In order to protect the vital interests of the data subject or another natural person,

8.1.5  For the performance of a task carried out in the public interest or in the exercise of official authority vested in EA,

8.1.6    For providing to you tailored services;

8.1.7    For management and administrative purposes; 

8.1.8  For carrying out analysis and market research; 

8.1.9  For carrying out marketing and keep you informed of products and services; 

8.1.10  For purposes of website improvement, products and services; 

8.1.11  For commercial purposes; and/or

8.1.12  For detecting suspicious financial transactions.

8.2  Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message, or where we process sensitive personal data as explained at paragraph 6.2 above. You have the right to withdraw consent to marketing at any time by contacting us using the contact details set out at paragraph 2 above.

9.1  We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

9.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to take part in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

10.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

10.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11.1  Our website uses “cookie” and “web beacon” technology.  We use cookies and web beacons to distinguish you from other visitors, track your IP address and usage of our site, and to indemnify the name of the website from which you linked to our website.  This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our website design, as well as our products, services and promotions.  We do not otherwise track any information about your use of other websites.  Non-personal data or anonymised/pseudonymised information obtained through cookies and web beacons may be shared with or obtained by service providers on our behalf.

11.2  A cookie is a small data file that is placed on the hard drive of your computer when you visit a website.  A “session cookie” expires immediately when you end your session (i.e., close your browser).  A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available.   A web beacon is a small string of code that represents a clear graphic image and is used in conjunction with a cookie.

11.3  When you visit our website, we may use both a session and a persistent cookie.  This EA-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and in some cases, your email address.  Your email address is only saved in this EA-placed cookie if you register with us.  The web beacon allows us to capture certain additional types of information about a visit’s actions on a website, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and the details about any items that were purchased.

11.4 If you register with us, this EA-placed cookie allows us to recognise you when you return to our website and provides you with access to your account information.  If you save your information with or purchase flights from us, we may also use cookies to monitor and maintain information about your use of our website.  If you have not saved your information with or ordered from us, we may monitor and maintain information about your use of our website in a manner that does not identify you. 

11.5  We may use Flash Cookie (also known as Local Stored Objects) or other similar technologies.  A Flash cookie is a small data file placed in a computer using Adobe Flash technology that may be built into your computer or downloaded by you to your computer. We use these technologies to personalise and enhance your online experience, facilitate processes, personalise and store your settings.  Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience.  They help us improve our sites by measuring which areas are of greatest interest to customers.  We do not use Flash cookies for marketing or behavioural targeting purposes.  Flash cookies are different from browser cookies and the cookie management tools provided by your browser will not remove Flash cookies.  If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.

11.6 You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to track your purchases or enable you to make a purchase from our Website.  In addition, we will not be able to recognise you as a registered user to allow you access to your account information. You can find out more about cookies by following this link: https://ico.org.uk/for-the-public/online/cookies/.

12.1  We do not knowingly collect any information from anyone under 16 years of age.  Our website, products and services are all directed to people who are at least 16 years old or older.

12.2  If you are under 16, do not use or provide any information on this website or on or through any of its features/register on the website, make any purchases through the website or provide any information about yourself to us, including your name, address, telephone number or email address.

12.3  If we learn we have collected or received personal data from a child under 16, we will delete that information.

12.4  If you believe we might have any information from or about a child under 16, please contact us.

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

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

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

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

14.1  Our servers, storing and keeping your information secure, are located in Ethiopia. However, we have a number of EA staff members and service providers who are located in other countries. Whenever we transfer your personal data out of the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it, by ensuring at least one of the following safeguards is implemented:

Where we transfer your personal data to Ethiopia, we do so under an internal intra-group data transfer agreement which incorporates the standard contract clauses and ensures a level of protection acceptable to the European Commission. For more information, please see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en .

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

14.2  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

15.1  When new data processing systems are introduced, we ensure a high standard of data protection. Particularly, any new systems and processes must comply with the following principles:

Technical and organizational measures must be taken to ensure systematic and secure life cycle management of personal data from collection to processing to deletion,

Data processing systems must be aimed at collecting as few personal data as necessary to fulfil the purpose for which the data was collected,

Where anonymizing the data does not inhibit with the data processing purpose, personal data must be rendered anonymous in a way that the data subject is no longer identifiable,

Where personal data can’t be anonymized, security measures appropriate to the nature of the data must be taken, such as pseudonymization, encryption, or access restriction,

Access to personal data shall be granted according to the “need-to-know” principle, meaning that personal data shall only be made accessible to those persons who require it to perform their assigned roles and responsibilities,

Systematic quality checking of personal data must be part of data life cycle management to ensure high data quality. In particular, processes must be established to detect and correct false or incomplete personal data,

Data processing systems must be adequately protected from unauthorized access through technical and organizational measures,

Data subjects must be provided with transparent, user-friendly and effective means of control concerning their personal data.

16.1  We set up data processing systems in a way that the strictest privacy settings apply automatically.

16.2 We permit more extensive processing of personal data only if the data subject gives its explicit consent to extended processing.

17.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

17.2  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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

18.2  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

18.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

18.4  In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

19.1 You have the right to:

19.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

19.1.2  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

19.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

19.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

19.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

19.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

19.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

19.2 If you wish to exercise any of the rights set out above, please contact us using our contact details and please fill the form found in the link here..

20.1   You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or if additional copies of your personal data are requested. Alternatively, we may refuse to comply with your request in these circumstances.

21.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

22.1 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

23.1   Data controller

EA is responsible for the lawful processing of personal data and compliance with data protection and data security requirements as set out in this policy or pursuant to applicable law. In particular, for:

  1. the observance of the “privacy by design” and “privacy by default” principles when developing new data processing activities,
  2. the effective handling of data subjects’ rights requests,
  3. the conducting of data protection impact assessments for personal data processing with the assistance of the data protection officer,
  4. the appointment of a data processor,
  5. the notification of a personal data breach to the supervisory authority, the data subject and other data controllers in accordance with the Data Breach Notification Policy of EA.
  6. the provision of employee awareness training.

23.2  Data processor

The data processor is responsible for processing personal data according to the instructions received from the data controller. Furthermore, the data processor is responsible for notifying the data controller of a data protection breach without delay and specifically within 24 hours.

Processing by a data processor shall be governed by a contract, that is binding on the processor with regard to EA and that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. That contract covers all the following elements:

  • processing of data can only occur on the basis of the instructions from the controller;
  • the processor must employ staff with confidentiality obligations;
  • the processor must take the required security measures;
  • the conditions for engaging a service provider (sub-processor). Specifically, the data processor must contractually grant that any eventual sub-contractor instructed to perform the data processing, complies with the same instructions received from EA;
  • how to handle data subject requests;
  • reporting and assistance in the event of a personal data breach;
  • the deletion or return of all personal data at end of contract; and
  • the right to obtain information from the processor demonstrating its compliance and allow on-site inspections.

However, EA, as data controller, remains the ultimate responsible party towards the relevant persons, in particular the data subject and the authorities.

 23.3 Executive management

The executive management of EA is responsible for implementing this policy and shall provide the necessary personnel and financial resources. EA’s managers are required to enforce the policy in their area of responsibility and ensure that employees, individuals, and entities for which they are responsible, are aware of, understand, and adhere to the requirements of this policy, and are appropriately trained to fully discharge this responsibility.

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