1. Who We Are
The airlines Aerovías del Continente Americano S.A. Avianca, and Tampa Cargo S.A., organized in the Republic of Colombia, Aerolíneas Galápagos S.A. Aerogal, organized in the Republic of Ecuador, and the airlines comprising Grupo Taca: Taca International Airlines S.A., organized in the Republic of El Salvador, Líneas Aéreas Costarricenses S.A. Lacsa, organized in the Republic of Costa Rica, Trans American Airlines S.A., organized in the Republic of Peru, Aviateca, S.A., organized under Guatemala law, hereinafter called both individually and collectively THE AIRLINES, which includes products and services provided by other companies related to any of the airlines above, who, for the provision and commercialization of air transportation services for passengers and related products and services, such as tourism packages, air or land cargo transportation, express courier services and other courier services, airport services, technical and professional training services, and loyalty programs, may act under the commercial brands AVIANCA, AEROGAL, AVIATECA, LACSA, TACA, TACA PERU, TACA REGIONAL, TACA CARGO, TAMPA CARGO, AVIANCA CARGO, AVIANCA SERVICES, AVIANCA TOURS, AVIANCA EXPRESS, FLYBOX, DEPRISA, LIFEMILES, PREFERENCIA “Programa para viajes empresariales” (“Company Travel Program”) or solely under the commercial brand AVIANCA, all of them being respectively responsible for the handling of personal data.
Avianca Holdings S.A. (formerly Avianca Taca Holding S.A.), is a Panamanian company, organized as an investment firm and as an instrument to perform the shareholders’ agreement that led to THE AIRLINES’ integration process.
2. Purpose of THE AIRLINES’ Personal Information and Data Handling Terms and Conditions
This document contains our personal information and data handling policy; its purpose is to communicate what information we gather when providing our services and for what purpose, how we handle that information, when we share it, and how we protect it, as well as to explain the rights to which the owners of such information are entitled and the procedures for exercising such rights.
We, THE AIRLINES, acknowledge how important it is to keep the personal data furnished by our passengers, customers, and users through our product and service commercialization channels (such as websites, sales offices, and call centers) secure, private, and confidential and we are committed to protecting and properly handling that data, pursuant to applicable personal data protection laws and regulations in each territory where we operate.
This document discusses handling the information that we receive from our passengers, customers, and users at each one of our business units: Deprisa, Avianca Tours, LifeMiles, PREFERENCIA “Programa para viajes empresariales” (“Company Travel Programs”), Avianca Services, Avianca Cargo and Avianca Express, and it constitutes the general reference framework of the specific policies stated in www.avianca.com, www.taca.com, www.deprisa.com, www.lifemiles.com, www.preferenciacorporativo.com, www.aviancaservices.com, www.tampacargo.com, www.aerogal.com.ec, www.tacaregional.com, www.flybox.co, www.aviancaexpress.com, link.avianca.com, www.sociosyamigos.com. Each one of these websites also contains the terms and conditions applicable to the products and services offered therein, which may be consulted for further information at any time.
The above websites may be deactivated or changed to a new domain, after implementing reorganization processes. Such changes will be promptly notified to our passengers, customers, and users
3. Personal Information and Data Obtained
We, THE AIRLINES collect personal information and data from our passengers, customers, and users, which may include the following data among others, in full or in part, according to the requirements of each product and/or service:
In addition, for security reasons, THE AIRLINES may gather, store, keep, share, and check with national or international control and surveillance administration authorities and with police or judicial authorities biometric data regarding our passengers, customers, and users obtained through image, audio or video recording devices, located in our facilities, such as administration offices, sales points, VIP lounges, airport service counters and kiosks, and call centers, among others. We, THE AIRLINES, will notify the above to the public at large by publishing Privacy Notices located in data collection areas.
Personal Information and Data Handling Effective Term
Information furnished by passengers, customers, and users will remain stored for up to ten (10) years as of the last data handling date, to allow THE AIRLINES’ compliance with legal or contractual obligations especially regarding accounting, fiscal and tax matters.
Passengers, customers, and users must furnish true personal information and data to validate their reservation and to enable service provision; they must also do so to receive any other service that they may require, one of the conditions being that they must accept to furnish any required information for the particular service.
We, THE AIRLINES, assume that the information furnished is true. We do not verify it nor do we assume the obligation of verifying the identity of the passengers, customers, and users or the veracity, validity, sufficiency and authenticity of the data that each of them furnishes. Therefore, we will not be held responsible for losses and/or damages of any nature that may stem from the lack of veracity, validity, sufficiency or authenticity of such information, including any losses or damages due to homonymy or identity theft.
Information regarding Children and Underage Adolescents
Boys, girls, and underage adolescents may use the products and services we offer, provided that they are acting through or are properly authorized by their parents or legal guardians.
We, THE AIRLINES, will see to the proper use of personal data regarding children and underage adolescents, ensuring their best interests and their fundamental rights when handling their data, and, whenever possible, taking into account their opinion as they are the owners of their personal data.
4. Purpose of Personal Data Handling
The information gathered is used to process, confirm, conduct, and provide the services and/or products purchased directly and/or with the participation of other airlines or third-party product or service providers, as well as to promote and advertise our activities, products and services, make transactions, report to different national or international control and surveillance administration authorities, police or judicial authorities, banking institutions and/or insurance companies, for internal administrative and/or commercial purposes, such as market research, auditing, accounting reports, statistics analyses, billing, and offering and/or acknowledging loyalty program benefits.
Due to our commercial activity, we, THE AIRLINES, are bound to furnish certain data regarding passengers, cargo, express courier or other courier services to aeronautics authorities, immigration and customs authorities, and to the national and international government authorities that regulate them or security agencies before flight departure or landing in the territory of each destination or at any moment after the transportation contract has been performed. In general, “information” refers to the identity data of the passengers on board, as well as to the contents of their respective travel documentation (passport, visa) or data relating to the merchandize being transported.
We hereby inform that third party providers may be involved in the above-mentioned activities (such as flight reservation system providers, bank transaction security tool providers, call centers, and tourism service operators), banking institutions, insurance companies, our representatives or agents, and that such activities may be supplied in countries other than the country in which the service or the product was purchased, and without prejudice to any other purpose stated herein and under the terms and conditions of each one of the products and services offered by each one of our business units.
5. Cookie and Web Beacon Use
Users may disable and delete the cookies, web beacons and other similar technology at any time. To do so, users may query and/or request help from the Internet navigator he or she uses.
6. Information Protection, Security and Confidentiality
Passenger, customer, and user information is of vital importance to THE AIRLINES. We have established information security policies, procedures, and standards aimed at protecting and preserving information integrity, confidentiality and availability, no matter what the means or format of the information, its temporary or permanent location, or how it may be transmitted. Along those lines, we have the support of security technology tools and we implement acknowledged industry security practices, including sensitive information transmission and storage using secure mechanisms, such as ciphering, security protocol usage, technology component assurance, restriction of information access to authorized personnel only, information backups, and secure software development practices, among others.
Third parties contracted by THE AIRLINES are equally bound to adhere to and comply with information security policies and manuals, as well as with the security protocols we apply in all of our processes.
Every contract between THE AIRLINES and third parties (contractors, external consultants, temporary employee services, etc…) that entails handling personal information and data includes a Confidentiality Clause that states in detail their commitment to the protection, care, security, and preservation of information confidentiality, integrity and privacy.
7. Procedure for the Owners of the Information to Exercise Their Rights
Passengers, customers, and users are entitled to access their personal data under our control and to exercise their rights as owners of the information, under the terms of applicable data protection laws and regulations and pursuant to the provisions herein.
For personal data handled in Colombia, the procedures for exercising information owner rights are set forth in 2012 Law 1581.
Passengers, customers, and users have the right to query and become familiar with the details of our personal data handling process, as well as to rectify the data that is inaccurate or incomplete and to cancel unused data, pursuant to legal or contractual purposes and terms or pursuant to the purposes and terms contemplated herein.
To make their rights effective, passengers, customers, and users may exercise their right to know, update, rectify, and delete their personal data by sending a request to e-mail address firstname.lastname@example.org or by using the Suggestions and Claims service at www.avianca.com or through the Call Center from Bogotá calling 4013434 or from other cities in Colombia calling 018000953434, pursuant to the provisions herein.
The request must include the following data:
Should any passenger, customer, user or third party consider that the content used in any of our contact and commercialization channels, such as websites, Smartphone apps, and service kiosks, violates his or her intellectual property rights, he or she must send a notice containing the information below to the above-mentioned addresses.
This type of claim will be submitted for handling and resolution to applicable judicial procedures, according to their nature and scope.
Such modifications will be made available to the public using the following means: visible notices in airline establishments or customer service centers, our airline websites, Smartphone apps or e- kiosks (Privacy Notice) or a message sent to the last e-mail address provided by our passengers, customers, and users.
Each passenger, customer or user accepts the handling of his or her personal data pursuant to the terms set forth herein, when he or she furnishes data through our service or sales points, including all call centers, or when he or she purchases or uses any of our products and services or when he or she clicks on the button “Aceptar” (“OK”) or navigates through our websites www.avianca.com, www.taca.com, www.deprisa.com, www.lifemiles.com, www.preferenciacorporativo.com, www.aviancaservices.com, www.tampacargo.com, www.aerogal.com.ec, www.tacaregional.com, www.flybox.co, www.aviancaexpress.com, link.avianca.com, www.sociosyamigos.com.
The latest revision was published on April 17, 2013.