TAP Air Portugal Privacy Policy
As part of the services we provide to you or when interacting with you through our websites, applications, social networks, digital products and services (hereinafter jointly referred to as “Platforms”), Transportes Aéreos Portugueses, S.A. ('TAP Air Portugal' or “TAP”), with registered office at Edifício 25, at Lisbon Airport, in Lisbon, Portugal, registered at the Commercial Registry Office of Lisbon under the unique tax identification number 500 278 725, as the controller of personal data, processes some of your personal data, namely:
- Personal information, so that you can enjoy our services and products, and so that TAP Air Portugal can comply with the legal obligations to which it is bound;
- Data from your device, namely through files called cookies, to improve the performance of our Platforms.
TAP Air Portugal is committed to protecting the security and privacy of its Customers, undertaking to comply with applicable legal obligations regarding the protection of personal data in all activities involving the collection and processing of personal data, in addition to implementing the best international practices where the security and confidentiality of the information collected is concerned.
With this Privacy Policy, we intend to inform you, as an integral part of the universe of Customers and Users of TAP Platforms (herein jointly referred to as “Customer” or by "you", "your", "they", "their"), about:
- What personal data we collect;
- How and why we use it;
- To whom we disclose it;
- How you can exercise your rights and how we protect your privacy when you use our services or visit our Platforms.
This Privacy Policy applies even if you have booked your flight through third parties, such as a travel agent, and incorporates the General Terms, Policies and Conditions of Use of TAP's Digital Presence, our Transport Conditions, the TAP account Membership Terms or the TAP Miles&Go Terms and Conditions.
Therefore, when using our Platforms, filling out our forms and providing your data, directly or indirectly, you will have to be aware of the conditions of this Policy, as well as accept the General Terms, Policies and Conditions of Use, as well as any other specific terms, policies and/or conditions related to the subscribed services. Therefore, we recommend that, when contracting or subscribing to any of our services, you read the respective terms and conditions carefully beforehand.
“Personal data” means any information, of any nature and regardless of its medium (including sound and image), relating to a living, identified or identifiable natural person (data subject).
An identifiable person is one who can be recognised directly or indirectly, in particular by reference to an identification number or other specific elements of their physical, physiological, psychological, economic, cultural or social identity.
TAP Air Portugal collects your personal data through different means, directly or through other entities, such as:
- Our suppliers who provide services to you on our behalf;
- Our partners;
- Travel agents or other operators who book a flight for you.
Categories of personal data that we process:
- When you use the flights search/booking services on our Platforms:
To speed up the search and booking of flights, you will be asked for data related to your geographic location (if you have this functionality enabled on your devices) after you have given your express consent to this effect.
- When you book a flight, create a TAP account, join the TAP Miles&Go Program or make a purchase in the TAPStore:
Data such as your first and last name, date of birth, contact details (email address, telephone number and postal address), passport details or other identification document, tax identification number, preferred language, frequent passenger number (if applicable) and details of your credit card or other payment method will be required.
The collection of some of this data is mandatory, therefore, if it is not provided, TAP Air Portugal will not be able to provide the requested service or make the product available. In these cases, the Customer will always be duly informed of the obligation to provide such data in order to continue the process of acquiring services or products.
- When you make a booking for certain specific destinations:
In addition to the data indicated in point 2. above, information may be requested, in accordance with the applicable legislation, which also includes your full name, nationality, number and type of travel document — passport or identification document —, as well as its validity date and country of issue, address at the origin and/or destination as well as emergency contact.
- When managing your flight:
In addition to the data indicated in the points above, you may voluntarily provide us with other relevant information within the scope of your booking and itinerary, including, but not limited to, any assistance needs and/or dietary requirements, purchases of additional services related to the trip, among others.
- When you make a booking on behalf of other passengers:
You will have to provide personal data related to these passengers, you must for this reason ensure that you have their consent or another lawful basis for this purpose.
- When you check in or use our services at the airport:
You will have to provide information about your flights (including connecting flights), about the baggage carried, contact details in the event of any operational disruption, as well as present your passport or other identification document, visas, vaccination certificates and other documents, which may vary depending on the destination or circumstances of your trip.
If you need to declare a baggage irregularity, you may also have to provide contact details and addresses at the destination, as well as the description and value of the respective contents.
- When you use our onboard sales services:
This point refers to information about the purchase of products available on board. Have in mind that the data necessary for the commercial transaction will be collected, namely payment data.
- When you contact TAP or are contacted by TAP:
All communications you exchange with us, namely emails, letters or telephone calls to the TAP Contact Center.
- When you interact with us on social media:
All publications and messages on social media that you voluntarily send to TAP.
- When you participate in our satisfaction surveys/questionnaires:
Information collected when you share your opinion about us through these means.
- When you use our Platforms, in accordance with our Cookies and other Tracking Technologies Policy:
Information about how you use our Platforms, in particular your flights searches.
Special categories of personal data:
When we provide our services, we may collect information that may reveal your racial or ethnic origin, data relating to your health, your religious beliefs or possible criminal offences. Under the applicable law, this information is considered “special categories of data” and may only be collected under the following conditions:
- If you have given your explicit consent;
- If it is necessary to do so due to a legal obligation imposed on TAP Air Portugal;
- If you have made them manifestly public.
This information will be collected and processed by TAP Air Portugal only in the following situations:
- If you have a specific health condition that we need to be aware of in order to provide the transportation service or if you require special assistance for or during a flight;
- If you give us information about specific dietary requirements (requirements that may be related to your religious beliefs);
- When you provide us with your travel document details (your nationality may indicate your racial or ethnic origin).
The Customer's personal data is only used within the scope of the provision and management of the contracted services, as well as for the study, improvement and adaptation of our services to their interests and needs, with their consent.
You may, however, provide us with your personal data for other purposes, such as to receive institutional information from the TAP group, to participate in contests, auctions and market studies, to receive marketing communications from TAP Air Portugal (namely, campaigns and promotions related to our services and products), as well as from partners, whose products or services may contribute to improving your travel experience.
In this sense, we use your personal data for the following purposes and in accordance with the following legal bases:
A. Execution of contract or pre-contractual procedures, namely:
- confirmation or modification of bookings and issuing of tickets;
- sending out information concerning the confirmation and/or changes to bookings;
- sending information related to other contracted services and/or products;
- sending information about payments and billing;
- sending information related to your flights, including operational ones;
- management of the check-in process, including documentation verification, boarding, acceptance and handling of baggage;
- access to fast-track, lounges and on-board services;
- management of operational disruption situations;
- response to requests, claims, suggestions or contacts
B. Legitimate interests of TAP Air Portugal, namely:
- sending you relevant information about your trip;
- evaluating the service we provided to you following a flight;
- for the purposes of preventing, investigating and prosecuting criminal offences, such as fraud, for example credit card or identity fraud, using fraudulent means to obtain special terms or fares;
- to take legal action, including debt collection and defense in the event of legal disputes;
- for audit purposes;
- to ensure the safety of your flight;
- for marketing communications from TAP Air Portugal, provided that you have not objected to the use of your data.
C. Express consent of the data subject, including but not limited to:
- sending newsletters with regular offers from TAP Air Portugal and/or partners;
- receiving specific information and offers from TAP Air Portugal and/or partners;
- for market research and customer surveys;
- for personalized use of the website and personalized offers, including profiling;
- to support processes related to the use of the website, like reminders and live chats;
- for analytical purposes, so that we can optimize the offers made available to you.
Any consent given may be withdrawn at any time. The withdrawal of consent only has effect for the future and does not affect the legality of the data processed until revocation.
D. Compliance with legal obligations, including legal requirements for security, customs and immigration control, and public health
TAP Air Portugal may collect and process personal data in order to comply with national and/or international legislation on immigration, territorial security, prevention, detection, investigation and repression of terrorism and serious and organized crime, in accordance with the legal regulations applicable to each trip, as well as to comply with any requirements established by health authorities, in terms of public health.
E. Defense of the vital interests of the data subject
TAP Air Portugal may also collect personal data if the processing is necessary to protect the vital interests of the data subject, in the event that the data subject is physically or legally incapable of giving consent (for example, due to incapacity resulting from a health problem manifested during a flight).
The period of time during which personal data is stored and retained varies according to the purpose for which the information is processed.
In fact, there are legal requirements that require data to be kept for a minimum period of time. Therefore, and whenever there is no specific legal requirement, the data will be stored and retained only for the minimum period necessary to pursue the purposes that motivated its collection or subsequent processing, under the terms defined by the law.
For example, when you make a booking with us, we will keep the information necessary to provide the contracted travel services and, subsequently, for the time necessary for us to manage or respond to any claim or query related to your booking. We may also retain this information to improve your experience with TAP Air Portugal and ensure that you receive the benefits of our Loyalty Program.
Our databases are reviewed periodically and actively, so personal data will be deleted or anonymized at the end of its retention periods, without prejudice to their maintenance in the event of any disputes.
Under the applicable legislation, the data subject may, at any time, request access to their personal data, as well as its rectification, deletion or limitation of its processing and portability, or oppose its processing (with the exception of data strictly necessary for the provision of the service), directly through the Customer Area or through a request sent by email to the following address: [email protected].
You may obtain confirmation of which of your personal data is being processed, as well as access to it, and, if you request it, you will be provided with a copy of the data being processed by TAP Air Portugal.
Under the terms of the law, you are also guaranteed the right, through the means mentioned above, to withdraw your permission for the processing of data whose consent constitutes the basis for the legitimacy of the respective processing. To this end, you have the right to withdraw your consent at any time, which does not, however, invalidate the processing carried out up to that date based on the consent previously given.
The Customer or User may also, at any time, request the deletion of their personal data, including the deletion of the TAP account or TAP Miles&Go account itself, under the terms provided for by law.
You also have the right, under the applicable legislation, to request the limitation of the processing or portability of your data, provided that the legally provided conditions are met. To this end, you must submit a request using the means mentioned above.
Without prejudice to any other administrative or judicial remedy, if the data subject considers that their data is not being legitimately processed by TAP Air Portugal, the data subject has the right to submit a claim to the National Data Protection Commission (CNPD), located at Avenida Dom Carlos I, 134 - 1 º, 1200-651 Lisbon, Portugal (www.cnpd.pt) or to another competent supervisory authority, under the terms of the applicable legislation and this Privacy Policy.
This Privacy Policy applies to all Users of TAP Platforms. However, given the specific nature of the use of the aforementioned digital platforms (social networks, websites and TAP Air Portugal applications), it is important that some particularly relevant issues are duly regulated.
- TAP Air Portugal is aware that sending personal information is a major concern for the Customer when using the Internet. On all our websites and applications, personal data collection forms require encrypted browser sessions.
- All personal data you voluntarily provide to us is stored securely in our systems. Once stored, the best technical and procedural security practices are implemented to protect the data.
- Notwithstanding the security measures adopted by TAP Air Portugal, we warn that, when accessing the Internet, you should regularly take precautions and adopt additional security measures, namely by using an updated computer and browser. You must take precautions when using shared computers and accessing your personal Customer accounts, avoiding sharing your access data with third parties.
- Through our Platforms, we provide links to third party websites, which are subject to independent Privacy Policies. Please note that this Privacy Policy does not apply to such websites and that TAP Air Portugal is not responsible for the collection of your information by the aforementioned websites.
- For your protection, access to some features available on some of our Platforms is protected by a password, which you should not share with third parties. For security reasons, we recommend that you memorize it and change it frequently.
- We only request your credit/debit card details if you wish to make a booking or payment for a service or TAP product. We offer security in the use of our Platforms through SSL technology – Secure Socket Layer, which encrypts communications produced between your personal computer and the server, so that they cannot be intercepted. TAP does not save or store credit card data in its technological infrastructure, this process is carried out through external partners (PSP - Payment Service Providers), in compliance with international standards defined by the industry (PCI DSS Compliance).
TAP Air Portugal is committed to ensuring the confidentiality, protection and security of your personal data, through the implementation of appropriate technical and organizational measures to protect it against any form of improper or illegitimate processing and against any accidental loss or destruction. To this end, we have systems and teams that guarantee data security, creating and updating procedures that prevent unauthorized access, accidental loss and/or destruction of personal data.
Always committed to complying with legislation regarding the protection of the Customers' personal data, TAP Air Portugal ensures that it processes this data only for the purposes for which it was collected or for which it is legally admissible, with the guarantee that it is processed with the appropriate levels of security and confidentiality.
Because we recognize the sensitivity of this information, our employees receive ongoing training on data protection and undertake not to disclose to third parties or use, for purposes contrary to the law, any personal information of TAP Customers that they become aware of in the course of their duties.
In this context, TAP Air Portugal has also appointed a Data Protection Officer (or “DPO” – find out how to contact him in point 12 of this Privacy Policy), to monitor compliance with the applicable policies and standards regarding the protection of personal data.
As set out in this Privacy Policy (see point 09. “Under what circumstances do we communicate data to other entities?”), we may, in some cases, transmit your personal data to third parties. TAP Air Portugal has defined clear rules for contracting the processing of personal data with its subcontractors and requires them to adopt the necessary technical and organizational measures to protect it. However, in some situations, we may be legally required to disclose your personal data to third parties, such as government authorities, we have limited control over the protection of personal data in these cases.
Your personal data may be communicated to third parties in the following situations:
- TAP Air Portugal may use other entities to provide certain services (such as handling services, information technology service providers, marketing, consulting or auditing services, among others), which may imply access by these entities to your personal data. We ensure, however, that any subcontracting entity will process your data in our name, on our behalf and with the strict obligation to follow our instructions. The same subcontracting entities offer sufficient guarantees for the implementation of technical and organizational measures so that the data processing meets the requirements of the applicable law and ensures the security and protection of the rights of data subjects, under the terms of the signed subcontracting agreements.
- TAP Air Portugal may also transmit your personal data to third parties when part of the itinerary involves a flight operated by another airline, or when it considers such data communications to be necessary or appropriate (1) in light of the applicable law, (2) in compliance with legal obligations/court orders, (3) to respond to requests from public or government authorities or (4) through complementary travel services, including those contracted by you from our partners (such as car rental companies, hotels and other third parties).
- TAP Air Portugal may also transmit your personal data to airports, customs and immigration authorities, police, government and regulatory bodies when notified to do so or when necessary to transport you to your destination, in accordance with the law, and also to credit and debit card companies, credit information agencies and fraud control service providers, law firms and judicial bodies within the scope of legal, administrative, judicial or extrajudicial actions and proceedings and/or insurance companies.
In any of the above-mentioned situations, TAP Air Portugal undertakes to take all reasonable measures to ensure the effective protection of the personal data it processes.
The provision of certain services by TAP Air Portugal may involve the transfer of your personal data to other countries (not belonging to the European Union or the European Economic Area), in order to manage the services contracted by you, comply with the legal obligations to which it is bound and respect the contractual commitments it establishes with third parties established therein.
TAP Air Portugal undertakes to take the necessary and appropriate measures, in light of the applicable law, to ensure the protection of all personal data that is subject to an international transfer.
TAP Air Portugal reserves the right to, at any time, make modifications or updates to this Privacy Policy. The changes will be duly updated on our Platforms. We suggest that you check them regularly to be aware of any changes. When there are materially relevant changes to the Privacy Policy, TAP Air Portugal will notify Customers with an active TAP account.
You may contact the Data Protection Officer (“DPO”) of TAP Air Portugal to obtain further information on the processing of your personal data, as well as for any questions related to the exercise of the rights granted to you by the applicable legislation and, in particular, those referred to in this Policy, by filling in the form "Exercise of Rights under the General Data Protection Regulation" (PDF, 1.2 MB, EN) and sending it to the email [email protected]. If you have any questions when filling out the form, follow the instructions (PDF, 1.2 MB, EN).