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    TAP Air Portugal Privacy Policy

    Your privacy is important to us. As part of the services we provide you, we at TAP Air Portugal need to collect some of your personal data. When interacting with you through our websites, apps, products and digital services (hereinafter collectively referred to as "Platforms") in some cases we also record:
    • Personal information, so you can enjoy the services provided by TAP Air Portugal;
    • Data from your device, through files called "cookies", to improve the performance of the Platforms.

    By means of this Privacy Policy we intend to answer as many of your questions as possible, as a part of the universe of Clients and Users of TAP Platforms (hereinafter collectively referred to as “Clients", or "your” or "their"), regarding:
    • The personal data we collect;
    • How and why we use it;
    • With whom we share it;
    • How we protect your privacy when you use our services or visit our platforms.

    Why a privacy policy?

    At TAP Air Portugal we are committed to protecting the security and privacy of the Clients who use the various websites and apps we make available and which are owned by the various Group Companies. For this reason, we have prepared this Privacy Policy to affirm our commitment to and respect for the rules of privacy and protection of personal data. 

    This Privacy Policy applies even if you booked your flight through a third party, such as a travel agent, and it is included in the Terms, Policies and General Conditions of Use

    It is important to us that you are aware of the general privacy rules and the terms of processing and collecting your data, operations we carry out in accordance with the applicable legislation in this field, particularly Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation").

    At TAP Air Portugal we respect and engage in best practices in terms of the security and protection of personal data, promoting actions and improving systems to effectively protect all data the Client makes available to us.

    Using our Platforms, completing our forms and providing your data, whether directly or indirectly, implies knowledge and acceptance of the terms of this Policy, the Terms, Policies and General Conditions of Use and any other specific terms, policies and conditions relating to the subscribed services. Read the respective terms and conditions carefully when you subscribe to any of our services. 

    Don’t forget: when you make your personal data available, you are authorising the collection, processing, use and disclosure of that data in accordance with the rules defined herein.

    Who is responsible for processing your personal data?

    Under this Privacy Policy, those responsible for processing your personal data are:

    • Transportes Aéreos Portugueses, S.A. - registered in Portugal, with its registered office at Edifício TAP 25, Lisbon Airport, taxpayer number 500 278 725;
    • Any other TAP Group company providing a service and which, in the appropriate context, determines the final purposes and means of processing the data and which is therefore considered the entity responsible under the General Data Protection Regulation.

     
    Those entities are referred to in this Privacy Policy as "TAP Air Portugal", "TAP", "we", “us” or "our".

    What is personal data?

    "Personal data" means any information of any nature and regardless of its media (including sounds and images) relating to an identified or identifiable natural person (data subject).

    An identifiable person is one that can be recognised either directly or indirectly, including by reference to an identification number or other specific elements of their physical, physiological, mental, economic, cultural or social identity.

    What personal data do we collect?

    TAP Air Portugal collects and handles the personal data required to provide its services and/or subscriptions to features, products and services. In particular:

    • When booking a flight or travelling with us;
    • When using our Platforms;
    • When contacting us, particularly through our Contact Center, or our services dealing with complaints, suggestions or praise.


    We may also receive your personal data through other entities, such as:

    • From our suppliers who provide services in our name;
    • From our partners
    • From travel agents or other operators who book a flight for you.


    For more information about the sharing of your data with other entities, see Point “12. Under what circumstances will we share data with other entities?

    Your personal data may include:

    • Your name;
    • Your identification and contact details;
    • Information about your travel itinerary (for example, your booking number);
    • Information about how you use our Platforms or how you interact with us (see Point “8. TAP Platform Users”).


    We also collect location data, with the Client’s prior consent, and without prejudice to compliance with applicable laws.

    Rights of minors

    We are particularly concerned with protecting the rights of minors. The collection of personal information from people under the age of 18 requires the consent of their parents or guardians.

    When we collect data about minors we always ask for the e-mail address of their parents or guardians to obtain confirmation that they consent to our processing of the data about the minors in question. 

    Categories of personal data we collect

    1. When you book a flight, create a TAP Account, sign up to the Victoria Programme or make a purchase at the TAP Store
    We require your name, date of birth, contact details (e-mail address, telephone number and postal address) and preferred language.
    Provision of this data is mandatory, without which TAP Air Portugal will not be able to provide the requested product or service. In such cases, the Client will always be told that this information is mandatory for the process to continue.
     
    2. When you book or manage your flight booking
    You will be asked for information about your bookings and trip itinerary should you require assistance, or whether you have dietary requirements or specific baggage requirements. This information can also include any changes to your booking and travel products related to it (for example, if you would like to take additional luggage). 
     
    3. When you give us certain information before flying:
    This will normally be information about your health should you have a medical condition that may affect your flight (for more information see “Special personal data categories” below). 
     
    4. When you use the flight search/booking services on our Platforms:
    In order to streamline the flight search and booking process, you will be asked for data about your geographical location, but only if you have this feature active on your devices and only with your consent.

    5. When you make a booking on behalf of other passengers:1
    You must provide information about the other passengers when booking, in particular, you must provide the age of any children travelling with you. 

    6. When you purchase TAP products or services:
    You will be asked for information about the respective transactions, including the details of the credit card you use to make payment.

    7. When you make a booking or check-in on several specific travel routes:
    The information requested will include your full name, nationality, date of birth, gender and number and type of travel document – passport or identity document – as well as the date of validity and country of issue. 

    8. When you travel with TAP or use our airport services: 
    You must provide information about your flights (such as connecting flight) and related services (should you need to report missing luggage).
     
    9. When you use our in-flight sales service:
    This point refers to information about the purchase of products available in-flight. 

    10. When you contact TAP or are contacted by TAP:
    All communications exchanged with us (e-mails, letters or phone calls to the TAP Contact Center).
     
    11. When you interact with us on social networks: 
    All publications and messages on social networks that are sent to TAP. 
     
    12. When you respond to one of our satisfaction surveys/questionnaires:
    Information gathered when you share your opinion of us by these methods.
     
    13. When you use our Platforms, pursuant to our Cookies and other Tracking Technologies Policy
    Information about how you use our Platforms, such as your flight searches.
     
    14. When you choose to provide this information to create an account or through the management of your preferences, as well as when you register or cancel your TAP subscriptions:
    Information related to your TAP subscriptions (if you have a TAP Account or if you are a member of the Victoria Programme), as well as other information related to your preferences.
     
    Special personal data categories 

    When we provide our service, we may need to collect information that could reveal your racial or ethnic origin, data relating to your health, your religious beliefs or even criminal record. Under the terms of the General Data Protection Regulation, this information is considered “special data categories” and may only be collected under the following conditions:

    • With your explicit consent;
    • When it is required to collect it because of a legal obligation imposed upon TAP Air Portugal;
    • When it is has been made openly public.


    This information will be collected when: 

    • There is a specific medical condition of which we require knowledge, or which requires special assistance during a flight (if, for example, you request a wheelchair, this may reveal information about your health);
    • If you inform us of specific dietary requirements (which may be related to your religious beliefs);
    • When you provide details about your travel document (your nationality may indicate your racial or ethnic origin).


    1 If you book a flight in someone else’s name, you must have their permission to provide their personal data.

    What do we do with the personal data we collect?

    The Client’s personal data is generally used to provide and manage the services contracted, subscribed or booked, as well as for the study, improvement and adaptation of services to their interests and requirements and to streamline the flight booking processes.

    You may provide us with your personal data for other purposes, however, such as to receive institutional information about the TAP Group, to take part in competitions and market surveys, to receive marketing communications (in particular, campaigns and promotions for our services and products) and when making complaints or suggestions.

    We will use this personal data for the following reasons:

    1. To manage your flight bookings and to provide our services.

    When you travel with us, we will use your personal data to provide services relating to the flight. For example, to issue tickets, complete check-in, issue your boarding card, accept you on board and safely take you to your destination. We will also use your data to change your flight bookings, should you require.

    Additionally, we will use your information when you use our airport services (for example, when you check-in at the desk or use our lounge, under the terms and conditions of Victoria Programme membership). 

    2. To communicate and manage our relationship with you.

    We may occasionally contact you by e-mail or text message for administrative or operational reasons. For example, we may contact you to confirm your booking and payment, to inform you about your travel itinerary or any potential disturbances or changes to your flights. If you use our mobile app, we may also send you notifications for the same reasons.

    Since these communications are operational in nature and are not conducted for marketing purposes, you will continue to receive them even if you have opted out of receiving marketing communications.

    We will also use your personal data to respond to your requests, suggestions or contacts and also to improve our services and your experience as a TAP Client. 

    3. To inform you of news and offers that may interest you.

    Would you like to receive our marketing communications? Find out how. 

    When you create a TAP Account or make a booking, let us know if you would like to receive this kind of communication. If you prefer, you can also request in your preferences in the Client Area that we send this information. 

    When you subscribe to our marketing communications you will begin receiving newsletters with information about the world of TAP, ranging from information about routes that may interest you to the best offers we have for you – from information about our flights to other associated travel products. For more information, see the Newsletters Subscription Terms and Conditions.

    Important note: Your personal data will never be shared with other companies for marketing purposes without your consent.

    Do you not want to receive our marketing communications? Find out how.

    Should you not wish to receive this kind of communication just click on the cancel subscription link at the bottom of any TAP marketing communication. 

    If you have a TAP or Victoria account, you can also cancel subscriptions in your Client Area at any time. Just go to “My profile” and click on the “Manage privacy” section to manage your account’s communications. 

    4. Personalise and improve your experience as a TAP Client

    By using your personal data, we can more effectively adapt our services to your needs and preferences, to ensure you have the best personalised experience with us. 

    Your profile data 

    If you agree to TAP using your TAP Account or Victoria Programme consumption and usage data – data that will not be shared with third parties – it will allow us to get to know you better and present you with campaigns, promotional coupons, benefits and products that are relevant to you. Your profile will be created and used for each promotional activity, taking into account your use of our Platforms and the frequency with which you use them. What is the objective? Meeting your interests.

    Your profile is defined based on the automatic processing of your personal data (without human intervention), a decision that may have legal repercussions, particularly in respect of the delivery of benefits or promotional campaigns. TAP Air Portugal is committed to implementing appropriate measure to protect your rights, freedoms and legitimate interests, particularly the right to obtain human intervention from TAP, to express your point of view and to contest any decision.

    We may also collect information about how you use our website, your flight searches and what products you normally purchase, in order to understand your likes and preferences. This way we can use this information to show you content and offers that match your preferences when you visit our website and/or when you have agreed to receive marketing communications, to send you those messages we believe are most relevant to you.

    When you make a booking in your account and leave our site for any reason during the process and before completing your request, we will be able to contact you to help you complete your booking, under the terms of our Cookies and other Tracking Technologies Policy.

    5. To improve our services and meet our administrative and commercial goals. 

    The business goals for which we use your information, include accounting, billing and auditing, credit card or other payment card verification, fraud analysis, security, legal and procedural purposes, statistical studies and system development and maintenance.

    6. To comply with our legal obligations.

    In particular, the obligation to provide your personal data to customs and immigration authorities.

     

    How long will we keep your data?

    Personal data is processed in accordance with applicable legislation and is stored in databases specially created for the purpose.

    Where there is no specific legal requirement, the length of time this data is stored varies, depending on the purpose for which it was collected. However, there are legal requirements that state the data must be retained for a specific amount of time. 

    What are your rights as a data subject?

    The data subject can, under the terms of the law and at any time, request access to any personal information, and to correct, delete or limit the treatment and portability of the data, or refuse permission for it to be processed (with the exception of data that is strictly necessary for the provision of a service), directly through the Client Area, or by sending a request for such by registered letter to: 
     
    Data Protection Officer 
    TAP Air Portugal, Lisbon Airport
    1704-801 Lisbon, Portugal
     
    You can receive confirmation of which of your personal data is processed, as well as obtain access to it. A copy of the data processed by TAP Air Portugal can be made available to you, should you require.
     
    By law you are guaranteed the right, through the methods outlined above, to withdraw your permission for the processing of data, for which your consent was required to make its treatment legitimate. You may withdraw your consent at any time, although this will not invalidate the processing of data conducted up to that date based on your previous consent. 
     
    Under the terms of the law, the Client or User may also, at any time, request that their personal data be deleted, including the deletion of their TAP or Victoria accounts.
     
    They are also entitled to, pursuant to the applicable legislation, to request a limitation on the processing or portability of their data, when the legally envisaged conditions are complied with. To do so, they must submit a request through the channels outlined above. 
     
    Without prejudice to any other administrative or judicial remedy, the data subject has the right to submit a complaint to the National Data Protection Authority (CNPD), or to any other legally competent authority, should they consider their data is not being processed in a legitimate manner by TAP, in accordance with the terms of the applicable legislation and this Privacy Policy. 

     

    TAP Platform Users

    This Privacy Policy applies to all TAP Platform Users. However, given the inherent specificity of the use of these digital Platforms (TAP Air Portugal websites and apps), it is important that some particularly important questions are duly regulated.

    1. TAP Air Portugal is aware that the sending of personal information is a major concern for the Client when using the Internet. On all our websites and apps, personal data collection forms require encrypted browser sessions.

    2. All personal data made available to us is securely stored in our systems. Once stored, best technical and procedural security practices are implemented to ensure they are protected.

    3. Notwithstanding the security measures adopted by TAP Air Portugal, we advise you that when you access the Internet you should regularly take precautions and additional security measures, in particular by using an updated computer and browser. You must exercise caution when using shared computers to access your personal Client accounts, taking care not to share your access data with third parties.

    4. We provide links on our Platforms to third party websites that are subject to independent Privacy Policies Please note that this Privacy Policy does not apply to these websites and that TAP Air Portugal is not responsible for collecting your information from the websites referred to.

    5.
    For your protection, access to some of the features available on our Platforms is password protected, and that the password must not be shared with third parties. For reasons of security, we recommend that you memorise your password and change it frequently.

    6.
    We only ask for your credit/debit card details when you want to make a booking or pay for a TAP product or service. Our Platforms are secured using SSL (Secure Socket Layer) technology, which encrypts the communications between your personal computer and the server, to ensure these communications cannot be intercepted.

    Cookies and other tracking technologies.

    For more information about cookies and how TAP Air Portugal uses them on its websites and apps, please consult the Cookies and Other Tracking Technologies Policy.

    What security measures do we implement?

    TAP Air Portugal is committed to ensuring the confidentiality, protection and security of your personal data through the implementation of the appropriate technical and organisational measures to protect them from any form of undue or unlawful treatment and from any accidental loss or destruction. To this end, we have systems and teams that guarantee data security, creating and updating procedures that prevent unauthorised access to and accidental loss and/or destruction of personal data. 
     
    Committed to complying completely with legislation concerning the protection of the personal data of Clients, TAP Air Portugal will ensure that this data is used only for the purposes for which it was collected, with the guarantee that they will be processed with the appropriate levels of security and confidentiality.
     
    Because we recognise the sensitivity of this information, all our employees are aware of our Personal Data Protection Policy, so they are fully aware of their obligations in this respect. 
    To ensure our employees are permanently aware of their responsibilities, we have also developed a series of training activities in which they make the commitment not to reveal to third parties or to use for illegal purposes, any of the personal information about TAP Air Portugal Clients that they come across in the course of their duties.
     
    To this end, TAP Air Portugal has also appointed a Data Protection Officer (DPO – contact details are contained in Point 14 of this Privacy Policy), who will ensure the company complies with all policies and regulations applicable to the protection of personal data.
     
    As stated in this Privacy Policy (see Point “11. Under what circumstances will we share data with other entities?”) there may be times when your data may be disclosed to third parties. TAP Air Portugal has defined clear regulations for contracting the processing of personal data with its subcontractors and insists that they adopt the technical and organisational measures required to protect such data. However, in some situations, we may be legally required to disclose your personal data to third parties, such as control authorities, with which we have limited control over the protection of personal data.

    Under what circumstances will we share data with other entities?

    Your personal data may be disclosed to third parties in the following situations:

    1. When TAP Air Portugal resorts to other entities for the provision of certain services, which may possibly involve these entities having access to your personal data. However, we ensure that all subcontractors will treat your data in our name, on our behalf and with the strict requirement to follow our instructions. The same subcontractors offer guarantees that they employ sufficient technical and organisational measures to ensure the data is processed in accordance with the requirements of the applicable law and that the safety and rights of the data subjects are protected, in accordance with the subcontracting agreement. 

    2. TAP Air Portugal may also disclose your personal data to third parties when part of your itinerary involves a flight with another airline or when it believes the communication of such data is necessary or appropriate (1) according to the applicable laws, (2) in complying with legal obligations/judicial instructions or (3) to respond to requests from public or governmental authorities.

    In this sense, TAP Air Portugal may disclose your personal data to airports, governmental and regulatory authorities (in particular, the National Civil Aviation Authority), when notified to do such or when it is necessary for transporting you to your destination, according to the legal provisions. 

    On some routes, for example, we are obliged by law to provide the customs and immigration authorities with information relating to your travel documents and itinerary. For more information, see Point “12. Under what circumstances will we transfer data internationally?

    In any of the circumstances mentioned above, TAP Air Portugal is committed to taking all reasonable measures to ensure the effective protection of the personal data it processes.

     

    Under what circumstances will we transfer data internationally?

    The provision of certain services by TAP Air Portugal may involve the transfer of your personal data to third countries (that do not belong to the European Union or the European Economic Area).

    In such cases, TAP Air Portugal will take the necessary and appropriate steps, according to the applicable laws, to ensure the protection of all personal data that is subject to such international transfer.

    All airlines are legally obliged to provide the customs and immigration authorities of certain countries with all the data on passengers and the flights they take to destinations such as the United States, Canada, the United Kingdom, Russia and Brazil. This data is only used for security purposes. 

    Whenever you make a booking for a destination/country that requires the provision of your data, TAP Air Portugal will inform you at the time of booking.

     

    How can you find out about changes to our privacy policy?

    TAP Air Portugal reserves the right at any time to make any modifications or updates to this Privacy Policy, alterations that will be duly updated on our Platforms. We suggest that you check them regularly to be made aware of any changes.

    How can you contact TAP to obtain information about your data?

    You can contact the TAP Air Portugal Data Protection Officer (“DPO”) for more information about how your personal data is used, as well as for any other matters connected with the exercise of your rights under the applicable legislation and, particularly, those contained in this Policy by completing the "Exercise of Rights under the General Data Protection Regulations” form (PDF, 0.1MB) and sending it by e-mail to dpo@tap.pt. If you have questions about how to complete this form, please  follow these instructions (PDF, 0.1MB).