Privacy Policy

Privacy Statement (dnata - DLA Piper review 08-03-16)

About Us

This www.transguard.ae website and our mobile applications and mobile websites (where applicable) (“the Platforms”) are owned and operated by dnata, a Dubai corporation, trading as “Transguard” established by Decree No. 1 of 1987 (as amended), whose principal office is at Emirates Group Headquarters, PO Box 686, Dubai, United Arab Emirates. This Privacy Statement covers the www.transguard.ae website and our other Platforms, the operations and our loyalty programmes (where available and applicable), and explains how we use personal information that we may obtain about you.

We are part of a wider group called the Emirates Group ("Emirates Group"), which includes any and all of the following entities and/or divisions: Emirates, dnata, dnata World Travel, Transguard, Emirates Skycargo, Emirates Skywards, Emirates Business Rewards, Emirates Holidays, dnata Travel Arabian Adventures, Wolgan Valley Resort & Spa and their associated brands and/or companies from time to time. A list is available here, and a list of our controlled subsidiaries in our Annual Report here.

How this Privacy Statement applies

By visiting our Platforms or using any of our products or services, you agree and consent to your personal information being used and disclosed in the manner set out in this Privacy Statement. In certain countries, we will not collect personal information from you unless you have specifically agreed or consented to us doing so (for example through your acceptance of this Privacy Statement or via an electronic tick-box or other similar measures as required by local privacy and data protection laws).

You do not have to provide your personal information to us, but if you do not provide certain information we will only be able to provide limited products and services to you.

This Privacy Statement applies even if you have booked your cargo or other products or services via a third party (such as a freight forwarder), as this Privacy Statement forms part of your contract with us for the cargo and/or those products or services.

The personal information that we collect

When you use our Platforms, certain information is collected by us automatically such as your browser type and IP address (which is a series of numbers identifying your internet connection). These may be through the use of analytics services (see "Aggregate data, data analytics and social media functionality" below).

We may collect personal data directly from you when you use our Platforms, contact us by telephone, by email or in person when you travel (such as your image).

We may also collect personal information from third parties who you have authorised to provide your personal information to us (e.g., your freight forwarder or Customs House Agent).

We will combine the information that we collect automatically from you with any other information that we collect directly from you or about you.

We also collect and store certain personal information as set out below.

Using the Platforms

When you register with us for promotions, competitions, corporate accounts, loyalty programs, marketing lists or similar services we may collect – title, first name, other names, surname, date of birth, phone number, email address, organisation name and contact details and other information relevant to the service you are signing up for;
When you book a product or service with us we will collect personal information from you which may include - title, first name, other names, surname, date of birth, username and password (if applicable), passport details, phone number, email address, country of residence, emergency contact, destination address where required (e.g. the US) and details of next of kin. In some countries we also need to collect your nationality and other information for tax purposes;
When you are making payment we will collect different information depending on the payment method. For example for credit card payments we will collect - credit cardholder name, address, card number, expiry date and CVC code. You may also choose to store your credit card details with us for future use. However, we do not store your CVC/CVV code (the security code on the back of a credit card); and
For adding new information and preferences to your personal or loyalty profile. From time to time we may update the methods of collection and data fields above. Where there are significant changes we will find a way to notify you, in accordance with the section "Notification of changes to this Privacy Statement" below.

Information about others

You may provide us with information about others, for example:

If you ask us to provide them with information or allow them to manage your booking on your behalf;
or
If you make or manage a booking for or on behalf of another person who has allowed you to do so.

We need to know full details of the cargo booked for travel. If you are booking cargo on behalf of someone else, you must obtain their consent to use their personal information, including their sensitive personal data as described below. We proceed on the basis that you have obtained these consents. Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this policy. This is especially the case if you provide us with sensitive information about them (e.g. a reference to shipment details or sharing legalized documents).

You may also provide information about others for purposes such as referring a friend to us so we can offer them our products or services. You must only contact individuals via our Platforms who you know would be happy to hear from you and you must not use our products or services to send unsolicited 'spam' messages.

How we use personal information?

We use the information provided in the following ways:

registering you with our website and administering our website services to you and your business;
processing legitimate cargo consignment bookings for you or for another person for whom you are legally authorised to act;
To fulfil our agreement with you and/or dealing with your booking or intended booking, including processing your booking, sending you your itinerary or other details relating to your booking, or contacting you if there is a problem with your booking (for example by sending you a service message to inform you when your booking has not been completed);
Managing your cargo and products or services requirements, for example liaising with and transferring your data to other travel providers, freight forwarders, customs house agents, airlines, service providers and/or logistics facilitators so that they can facilitate your cargo movements so any disruption can be minimised;
Personalisation of the service you receive, for example being aware of previous cargo handling experiences or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile;
Providing Advanced Cargo Information for cargo landing in certain countries. If you do not provide this information our service providers may not be able to provide services and may not be able to provide a refund or re-booking;
Screening, inspection and other scanning technologies for identification purposes may be used by ourselves, our service providers, police, customs authorities and the airports we fly to;
Sharing data with loyalty schemes and operators, where you have those accounts;
The provision of access to inspection areas, and other airport or cargo products or services;
Interaction with you at different touch points throughout your journey (for example we may inform you that your cargo booking has changed);
We may use location data for our mobile website and mobile app (where applicable) to enable us to provide the most helpful format and content (for example pre-populating the departure airport, airport codes and payment country) providing that you have agreed to the use of your location data;
To register you with our Platforms and administer our Platforms’ products or services where you have registered to receive these. You can unsubscribe from these Platform products or services at any time (see Choice/Opt-out below);
To administer any contest, competition, prize draw or your acceptance of any other promotional offer you may enter, and notify winners, as more fully set out in the applicable terms and conditions;
To personalise the look and feel of our Platforms and our communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Platforms, market research and, (where you have agreed to this) via social media and networks;
To answer any queries which you may send to us by email or other forms of communication, and we may keep a record of these contacts including call recordings (to the extent permitted by applicable law);
In order to conduct customer satisfaction surveys and improve the products and services we offer or create new products and services;
To meet our legal compliance obligations or for accounting or audit purposes, including the prevention of fraud for online payments and use of loyalty schemes;
To protect our property, rights, and interests as well as the property, rights, and interests of other persons;
For legal purposes, such as to respond to a valid legal subpoena or regulatory order;
For credit checking and credit scoring purposes;
For crime prevention and detection;
For direct marketing purposes, as set out in detail below in the section "How do we use your personal information for marketing purposes?”; and
As you may authorise or consent to additionally from time to time.

What sensitive personal data might you require or hold?

Sensitive personal data includes data about an shipment’s value, contents, country of origin and other categories of personal data which are closely protected. We do not generally collect this information from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it.

In each case, you specifically consent (on your behalf and on behalf of those you are booking for) that we can use and transfer outside your local country to anywhere in the world where the shipment is sent or will be sent from or where we provide products or services from (or the Emirates Group or our service providers do or your freight forwarder does) (see "To whom do we disclose your personal information" below).

How do we use your personal information for marketing purposes?

Where you have indicated you would like to receive updates from us:

We may send marketing to you to tell you about developments in the products and services available through our Platforms and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
Where we are able to determine or you have indicated to us that you would like to receive it, other entities in the Emirates Group and/or other third parties may also send you marketing or updates relating to their products or services; and
We will use your personal preferences which you have told us about and/or which we have inferred from your service usage (see Aggregate data, data analytics and social media functionality below) or market research. We will use this information to tailor the advertising and communications that you receive to be those of the most relevance and interest to you.

You can also unsubscribe from receiving certain electronic messages (see "Withdrawing your consent" below).

To whom do we disclose your personal information?

We may disclose information about you as follows:

To other entities within the Emirates Group (as defined above) for fulfilment of the purposes listed above;
To governments, border control agencies, regulators and others as permitted or required by law, in relation to Advance Cargo Information or such other legal requirements as apply from time to time when transporting to or from a particular country;
To third parties that we use for the provision of certain services, such as ground handling and logistical services related to the transportation of goods;
To third parties whose products or services you are purchasing such as airlines, freight forwarders, customs house agents, if there is a problem with your booking so that they can resolve it with you, and you acknowledge and consent that this may also be sensitive personal data;
To our third party service providers and processors, as set out below;
To third party advertising and social media platforms to provide advertising and the information requested by social media platforms to deliver the user's requested functionality;
In operating our loyalty schemes and referrals to other loyalty schemes, as set out in their terms;
We may also disclose your personal information as permitted or required by law. For example, we will disclose personal information to those governmental bodies who have authority to obtain it, in order to comply with a warrant or subpoena issued by a court of competent jurisdiction, and to comply with record production requirements;
In the event of a sale of all or substantially all of the assets of Transguard or an Emirates Group member, sale or transfer of the business, such Emirates Group member may transfer personal information in its control to a third party purchaser that agrees to use personal information for the same reasons identified in this Privacy Statement;
To anyone to whom we transfer or may transfer our rights and duties under our agreement with you;
Where you have authorised someone else to manage your booking;
To customs and/or other regulatory authorities in your country of departure and/or destination (or countries the cargo may transit through or overfly during the entirety of the journey) in order to comply with the law in those countries;
If we have a duty to do so or if the law allows us to do so; and
To our employees and agents to do any of the above on our behalf, now or in the future.

Working with other service providers and Emirates Group companies

For operational reasons, we transfer personal information to service providers and Emirates Group companies who help us manage our systems and processes, and to deliver our products or services to users. These may include: banks and payment card verification providers, our data warehouse and customer relationship management centre, marketing organisations (who may provide support for marketing and promotional communications); internet service providers who administer our Platforms and provide internet services and host our facilities; secured logistics teams, chauffeurs, airport ground handling and assistance teams, car services agencies, IT service providers, and consumer research companies that assist us with understanding consumer interests by conducting surveys. We have implemented safeguards to ensure that our service providers treat personal information in a way that is consistent with the terms of this Privacy Statement and applicable laws, and that it is not used except to fulfil products or services to us or where we believe it is necessary for a legitimate reason connected with the products or services we offer, or as set out in the "What sensitive personal data might you require or hold?" section above.

These service providers and group companies may be located in your country, countries in the European Economic Area, in the United Arab Emirates or elsewhere in the world. Different privacy laws may apply in these countries See further detail in our "Transfer of Personal Information" section below.

For people resident in Australia, your data may be transferred to the UAE, and the UK and where our servers are located from time to time, along with where you are travelling to or from or as required by law.

Retention

We keep records for as long as required to manage bookings and provide the other relevant products or services anticipated by this Privacy Policy, including keeping you up-to-date with our marketing, and where we are required to by law or for records purposes. We also retain your information to make your future interactions with us convenient and to personalise the products, services and communications with you.

Consent

By choosing to provide us with your personal information you are consenting to its use in accordance with the principles outlined in this Privacy Statement and as outlined at the time you are asked to provide any personal information. We and other members of the Emirates Group may contact you by phone, email, SMS and mobile device messages or notifications (and gaining your consent where we are required to do so) in order to provide you with updates pertaining to our products or services as well as information about additional offers, products, services or events that we believe may be of interest to you.

Withdrawing your consent

You do not have to provide us with your personal information. However, if you choose not to provide certain personal information we request and/or require or consent to its use and disclosure, you will still be able to visit our Platforms but you may be unable to access certain options, products or services, and in some cases we may not be able to fulfil your booking.

All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out of receiving these by contacting us.

To opt out of mobile device messages or notifications from our applications go into “settings” on your device and turn off notifications for the relevant application.

Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs.

Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding your booking and responses to your enquiries made to us, and that we may hold your details on a suppression list so we don't send you marketing communications in the future.

Security

We will take appropriate steps to protect the personal information you share with us. We have implemented technology and security features to safeguard the privacy of your personal information. We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Protecting your details and protecting yourself against internet fraud

Here are some simple steps you can take to ensure your information is kept securely:

Keep your booking reference confidential - upon making a booking a unique booking reference will appear on the email confirmation or on the airway bill in your booking. It is important that you keep your booking reference confidential at all times. Other persons may be able to access your booking details through our system if you disclose your booking reference to them.
Keep your loyalty ID number/ Customer log-in details confidential. You should not share your log in details with anyone else. You should also log out when you finish using our Platforms. This is especially important if you are using a publicly accessible computer.
Be aware of "Phishing", which is where someone tries to represent themselves as someone else to gain information from you - always check whether emails from any sender are actually from them, and if in doubt, go directly to their website and do not click on links in emails, as these may take you to "clone" websites which use your information illegally.

Aggregate data, data analytics and social media functionality

We may aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and product offerings, and to customize our Platforms’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.

We gather certain usage information like the number and frequency of visitors to our Platforms. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you. If you use buttons on our Platforms linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Platforms may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).

California Shine the Light Disclosure

We may share your information with carefully selected third parties for the third party’s own marketing purposes. If you are a California resident, you may contact us once per year to request the name of that third party(ies) and the categories of information shared about you. To do so, please send a request to us as set out below with valid proof of California residency. Please note that it may take up to 30 days to process your request.

Links

Our Platforms may contain links to other web sites. Please be aware that we are not responsible for the privacy practices of web sites not operated by us or an entity in the "Emirates Group". We encourage you to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by our Platforms.

Correction / updating of personal information

If your personally identifiable information changes or is inaccurate, or if you no longer desire our service, we will provide a way to correct, update or suppress your personal information provided to us. If you are concerned that any of the information we hold about you is incorrect please contact us. These rights are without prejudice to any legal rights you may have in applicable laws, including your right to object to certain processing of data.

Access to your personal information

You may have the right to receive a copy of personal information we keep about you, including the sources of the data, the purposes and methods of processing, any electronic decision-making and the entities with whom we share your data. We will endeavour to provide the information you require within a reasonable time. There may be a small monetary charge for some requests, depending on the information requested, to the extent permitted by applicable laws.

Transfer of your personal information

Some parties that process or store personal information in accordance with this Privacy Statement may be located in jurisdictions outside your country of residence or our country of incorporation. Therefore, you understand and unambiguously agree that your information may be processed and stored in these jurisdictions and that different privacy laws may apply in these countries which may not ensure the same level of data protection as granted in your country of residence. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.

Notification of changes to this Privacy Statement

If we decide to change our Privacy Statement, we will post those changes on our Platforms. If at any point we decide to use personally identifiable information in a manner materially different from that stated at the time it was collected (and/or where we are required under applicable law), we will notify you. You will have a choice as to whether or not we use your information in this different manner. We will use information in accordance with the Privacy Statement under which the information was collected until you agree otherwise, but if you do not accept the amended Privacy Statement, please stop using our Platforms. Each version has a version number and date so you can check this easily.

Our Contact Details

If you have a query regarding your online booking, encountered any problems whilst making your booking, have queries, concerns or compliants regarding your privacy or queries regarding this privacy statement please contact us.