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Privacy Policy

Vietnam Airlines’ Customer Privacy Policy


Article 1. General information about Vietnam Airlines

Vietnam Airlines JSC, a national flag carrier, is lawfully incorporated under the law of Vietnam, having its head office at 200 Nguyen Son Street, Bo De Ward, Long Bien District, Hanoi, Vietnam Nam (hereinafter referred to as “Vietnam Airlines”). In year 2016, Vietnam Airlines has been certified as a 4-Star Airlines by the international air transport rating organization SKYTRAX.

Article 2. Vietnam Airlines' commitment regarding the protection of personal data

Given the importance of protecting personal data, Vietnam Airlines is committed to adhere regulations concerning the privacy, especially to the new General Data Protection Regulation (hereinafter the "GDPR"), and take all reasonable measures to ensure that personal data provided to us will remain highly confidential and safely protected. This Privacy Policy published on our website explains why and how we collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose, align or combine, restrict, erase or destroy your personal data when you travel with us, purchase or use our services, visit our website, use our mobile applications or interact with us. This Privacy Policy also instructs you how to exercise your rights relating to your personal data.

As far as GDPR is triggered, Vietnam Airlines is sometimes acting in a joint control relationship with other companies namely when providing air services in cooperation with other airlines (through code-share agreements or interline agreements) or when providing travel arrangements in cooperation with other companies such as hotels. For the processing of your personal data in relation to these activities, Vietnam Airlines and the other companies are jointly responsible. We have determined our respective responsibilities for compliance with the obligations under applicable privacy legislation for processing your personal data in relation to these activities by means of an arrangement between us. In summary, we have arranged that if you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port personal data or to withdraw your consent, or if you have any questions or complaints about the processing of your personal data, you can either contact us or contact the other company. We will assist each other where necessary to ensure that you can exercise your rights and your questions and complaints will be handled.

More specifically, Vietnam Airlines undertakes in particular to respect the following principles:

  1. Your personal data are processed lawfully, fairly, and transparently, in accordance with Article 5.1 a) of the GDPR;
  2. Your personal data are collected for specific, explicit and legitimate purposes and are not further processed in way incompatible with these purposes, in accordance with Article 5.1 b) of the GDPR;
  3. Your personal data are stored in a appropriate and relevant manner and are limited to what is necessary for the purposes for which they are processed, in accordance with Article 5.1 c) of the GDPR;
  4. Your personal data are accurate, kept up to date and all reasonable steps are taken to ensure that inaccurate data, having regard to the purposes for which they are processed, are erased or rectified without delay, in accordance with Article 5.1 d) of the GDPR;
  5. Your personal data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, in accordance with Article 5.1 e) of the GDPR;
  6. In accordance with Article 5.1 f) of the GDPR, Vietnam Airlines implements appropriate technical and organizational measures to ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Furthermore, Vietnam Airlines contractually imposes the same level of personal data protection on its subcontractors (service providers, suppliers, etc.).

Finally, Vietnam Airlines undertakes to comply with all other principles required under the applicable regulations on the protection of personal data, and more specifically concerning the rights conferred on data subjects and the obligations relating to cross-border transfers of personal data.

Article 3. Items of Personal information which may be collected and processed by Vietnam Airlines

1. General

When using its services and in particular the services accessible on its website, its mobile apps, its loyalty program (Lotusmiles) but also its call centres and sales agency, Vietnam Airlines may collect and process the following categories of personal information:

Name, passport number and other identifying information: name, gender, date of birth, passport or other personally identifiable number (date of issuance, place of issuance), nationality, language;
Your contact details and personal account or registration details: contact information, such as, telephone number, mailing address, email address, fax number; home address, mobile number, private email address, hobbies, preferences and information related to Member’s special needs;
Your payment information: payment information of credit or debit card such as name of cardholder, card number, expiry date, verification code;
Information about your reservations, bookings and purchases: information relating to reservation and booking information such as your flight, prices and the date of your reservation or booking;
Your membership of our loyalty programs like Lotusmile: information relating to our loyalty membership Lotusmiles including membership number, your miles or credits balance, awards and benefits, type and level of membership and other information in relation to your membership.
Information we collect when you use our websites, apps and other digital media: personal information that is generated automatically when Customers using Vietnam Airlines Website such as IP information, cookies, website log;
Our communication with you: communication, communication preferences (unsubscription from newsletters, choice to receive your booking related communication,…), registration of your questions, survey, research, complaints or phone calls;
Information in relation to social media: Depending on your social network settings we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may receive your social network profile including your contact details, interests and contacts.

2. Sensitive data

Vietnam Airlines may also collect certain information relating revealing racial or ethnic origin, political opinions, religious or philosophical beliefs which can be considered as ''sensitive personal data" pursuant to Article 9 of the GDPR, the law of Vietnam and under other applicable jurisdiction. Subject to your express consent, Vietnam Airlines may collect, use and share your special categories of data with third parties for the purposes as described in Article 5 below such as for providing you with assistance during your travel (medical needs and Persons with Reduced Mobility).

3. Cookies and similar technologies

When you use our website or mobile apps we collect information via cookies and similar technologies. For more information please read our cookie policy on the website or mobile app you use.

Article 4. Methods of personal data collection

Vietnam Airlines may collect the personal information or data set forth in Article 3 of this Privacy Policy through our Website and sales offices, namely when you book a flight, register for Lotusmiles program, use one of our apps and communicate with us via social media, when you subscribe to our newsletter or when you register for one of our events or participate in a promotional contest. Furthermore, your personal data may be obtained from our group companies, partners or other service providers when you request for our services (travel agents, third party platform providers, hotels, car rental companies,…) or from public authorities or governmental organizations.

Article 5. Purposes for which Vietnam Airlines collect and process your data

Personal information or data provided to us is primarily used to serve your interests and privileges when you enjoy travelling with us, purchasing or using our services, including Lotusmiles, visiting our websites, using our mobile site and mobile applications or contacting us. For this reason, the main purposes for which we collect and process your personal information are as follows:

1. To perform our contractual obligations and enable an appropriate level of service to our customers

In order to handle and perform the contract of carriage and/or travel arrangement, Vietnam Airlines will process the information described above (article 3) including your name, surname, passport number and other identifying information to issue your ticket such as your contact details in order to inform you properly about changes of your flight status.

In order to perform the contract of carriage in compliance with applicable law and an appropriate level of care, Vietnam Airlines offers you the possibility to indicate some sensitive information such as information about your specified medical needs or special meals to be provided aboard. Collection and processing of these sensitive personal data will be subject to your express consent and will be exclusively used by Vietnam Airlines in order to perform the contract of carriage and provide you with an appropriate level of service.

2. For Lotusmiles membership's purposes

To facilitate our Lotusmiles program, we use the data detailed under article 3.1 in order (i) to update members on new Lotusmiles policy and regulation, (ii) let you benefit from the discounts and rewards under, (iii) to process and administer the reservation and issuance of tickets for Customer, (iv) to contact Members regarding their enquiries, (v) to provide services requested by members, (vi) to manage, analyse and evaluate data on flight frequency of Lotusmiles members to develop the appropriate fare policy and customer service policy, (vii) to receive information, comments, suggestions, claims of members to improve the service quality of Vietnam Airlines.

3. To ascertain a high level of security and safety on our flights

Vietnam Airlines use your personal information in order to protect safety of all passengers by namely (i) checking every passenger identity before they check-in, (ii) maintaining a list of the passengers who have not observed the safety rules, public order or discipline, either on board or on the ground, and for which Vietnam Airlines will refuse the carriage or restrict it to specific conditions, (iii) sharing your identifying information and your booking and travel information with public authorities or governmental organizations for the purpose of border control, immigration, entering the territory of a State, security or combatting terrorism.

4. Accounting and financial requirement

We collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations. These data will be kept for a period of 10 years, following a legal obligation imposed to Vietnam Airlines.

5. For customer care purposes

Your personal data are used by Vietnam Airlines to provide you with a customer care service, enabling Vietnam Airlines namely (i) to receive information, comments, suggestions, claims of members to improve the service quality of Vietnam Airlines, (ii) to contact and communicate customers regarding their enquiries, (iii) for statistical analysis in order to develop and improve Vietnam Airlines services and offerings on the basis of personal information and requests and (iv) to provide more quickly responsive support to customers and improve the content and designs of Vietnam Airlines' website, mobile site and apps, (v) realize surveys regarding the satisfaction of customers and for better understanding of customers' needs and (vi) potential complaints or claims of passengers.

6. To communicate with you

We use your contact details to communicate with you in relation to our services or loyalty programs, to answer your questions or to handle your complaints.

7. For direct marketing purposes

Vietnam Airlines may use your personal information for purposes of direct marketing such as (i) to send you latest promotions and offers in connection with our products and services, (ii) to send you newsletters, magazines, promotions or other marketing communications, (ii) to analyze which information is relevantly suitable to you, (iii) to communicate with you for marketing campaign and strategy to serve members' best interests and preferences, (iv) send you personalized ads and special offers for airline related products and services in our booking related emails, (v) send you latest (non-)personalized offers from Vietnam Airlines and our partners relating to our services and products.

We only send you direct marketing notifications as described in the first paragraph with your prior consent (opt-in).

You can always object to the use of your personal data for such direct marketing purposes, by clicking the unsubscribe link in the email or contacting us.

Article 6. Legal basis of the processing of your personal data

Vietnam Airlines processes your personal data (i) on the basis of your explicit consent, (ii) to perform the contract or in order to take steps at the request of the data subject prior to entering into a contract, (iii) to comply with legal obligations we are subject to or (iv) to perform Vietnam Airlines' legitimate interests.

Your consent may always be withdrawn at any time in accordance with article 9 below. In such case, be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal. Furthermore, if you refuse to provide Vietnam Airlines with some of personal data or if you provide Vietnam Airlines with incomplete or inaccurate information required for the performance of the contract or for compliance with a legal obligation, be aware that we may not be able to provide or deliver you all or parts of the services, which you may have requested from us in full quality. When we process your personal data for our legitimate interests or the interests of a third party, Vietnam Airlines ensures that a balance of these interests against your legitimate interests has been done. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you.

Article 7. Period for Personal data retention

Vietnam Airlines will retain your personal information collected on our internal system in the period of services provision or as long as fulfilling the purposes which it was collected or in so far as such is necessary for compliance with statutory obligations and for solving any disputes or until the information are required to be deleted by you.

Article 8.– Potential recipient of your personal data

1. Potential recipient of your personal data

Vietnam Airlines may disclose the Personal Information to third parties, such as authorized Vietnam Airlines' employees, undertakings of the Vietnam Airlines group, business partners (our travel agents, SkyTeam Airlines, car rental companies, hotels, credit card companies...) service providers or travel-related businesses pursuant to the performance of the services (bookings and travel arrangements, support services and customers' care, loyalty programs, statistical analysis,…) our legal obligations (security and safety on board, PNR information,…) or our legitimate interests (direct marketing purposes of Vietnam Airlines or our partners,…) and for the purpose of providing the best services to you.

As any airline company, Vietnam Airlines may be required to provide personal information to authorized public authorities (customs, immigration, police, etc.), such as for the completion of mandatory immigration formalities or for the purpose of preventing and fighting terrorism and other serious offences. Moreover, pursuant to the Directive 2016/681 of 27 April 2016, Vietnam Airlines may be required to transmit passengers booking, check-in and boarding data to the competent authorities.

Vietnam Airlines will use its best endeavours to ensure that its employees, officers, agents, consultants or such other third parties mentioned above who are involved in the collection, processing and disclosure of Personal Information will observe and adhere this Privacy Policy.

The disclosure of third party processor will be conducted by a contract, where it requires and ensures the protection of your personal data in accordance with this policy, and the applicable law.

2. Transfers of personal data to third countries

You are informed that Vietnam Airlines may transfer your personal data to third parties located outside the European Union, such as mainly Vietnam and the USA in order to be processed and stored.

In that context, Vietnam Airlines undertakes to guarantee the protection of your data in accordance with the strictest rules by implementing Bindings Corporate Rules (BCRS) in accordance with Article 47 of the GDPR which put in place rules comparable to those of the GDPR and European Union standard clauses.

Article 9. Your rights to the Personal data collected

1. Subject to the applicable law you, as the possessor of personal data, have the following rights:

  1. The Right of access
    You have the right to ask Vietnam Airlines, at any moment, for confirmation that certain of your personal data are processed by Vietnam Airlines and to obtain certain information such as the categories of personal data concerned, the purposes of the processing and the recipients or categories of recipient of those data.
  2. The right of rectification
    You have the right to obtain from Vietnam Airlines the rectification of inaccurate or incomplete personal data concerning you.
  3. The right to be forgotten
    You have the right to obtain the erasure (deletion of your personal data) of your personal data stored by Vietnam Airlines in the situations provided by the GDPR such as in situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully.
  4. The right to restriction of processing
    You have the right to obtain from Vietnam Airlines a limitation of the processing of your personal data without deleting the personal data concerned on the conditions stated in the GDPR.
  5. The Right to data portability
    You have the right to recover some of your data for your own use or to transmit them to another company in the conditions provided by the GDPR.
  6. The right to object
    Your have the right to object at any time to the processing of its data for prospecting and direct marketing purposes.
  7. The right to withdraw consent
    When the processing of your personal data is subject to your prior consent, you have the right to withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal.
    You shall be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal. In case of the withdrawal, it may mean we will not be able to provide or deliver you all or parts of the services, which you may have requested from us in full quality
  8. The right to lodge a complaint
    You have the right to lodge a complaint to the competent authority in the event of violation by Vietnam Airlines of the applicable legislation regarding the protection of personal data and in particular the GDPR.

2. You can exercise your rights listed above by sending a postal mail or an email to the following address:

Vietnam Airlines JSC

Mr. Nguyen Nam Tien, Data Protection Officer

Email: dpo@vietnamairlines.com

Address: 200 Nguyen Son Street, Bo De Ward, Long Bien District, Hanoi City, Vietnam.

In this context, please include in your request the elements necessary to your identification (name, first name, e-mail) as well as any other information necessary for the confirmation of your identity.

Article 10. Personal Information of children

We collects, shares and uses personal information of a child under fourteen (14) years who hold a Korean nationality, only if after receiving the consent of the child’s parent, legal representative and/or guardian, who may request to view, edit their child’s personal information or to alter or withdraw consent at our sales offices on the website.

For a child who is in a Member State of European Union who is below the minimum age of consent as defined by concerned Member State's regulation (13 for Denmark, Spain and the United Kingdom, 14 for Austria and Italy, 15 for Czech Republic and France, 16 for Germany and The Netherlands), we may collect information of the child requiring its consent, after obtaining consent or authorization from his or her parent or guardian.

For a child who hold another nationality we may collect information of the child after obtaining consent or authorization from his or her parent or guardian in accordance with data protection applicable law.

Article 11. Technical Measures for protecting Personal Information

To secure the safety of Personal Information from a loss, theft, leak, falsification, or damage, Vietnam Airlines employees the following technical, managerial, physical devises as:

1. The important personal information is stored and managed in password protected mode within the limited access.

2. Given the risk of hacking, varying likelihood and severity for the rights and freedoms of natural persons, Viet Nam Airlines is committed:

  1. To prevent customers’ Personal Information from leakage or damage by hacking or computer virus.
  2. To control the access suspension system, unauthorized accesses from outside.
  3. To implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including the pseudonymisation and encryption of personal data.
  4. To ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  5. To restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  6. To ensure a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing
  7. To minimize a number of employees for managing personal Information.
  8. To operate an exclusive organization for protecting personal Information.

Article 12. Communication with you and notification to the local authority in case of a breach of your personal data

1. We will communicate immediately, when your personal data are breached, to you and to the local authority as every time it is required by the GDPR. This communication about your personal data breach will describe in clear and plain language the nature of the personal data breach and contain at least the following information and measures :

  1. communicate the name and contact details of the data protection officer or other contact point where more information can be obtained;
  2. describe the likely consequences of the personal data breach
  3. describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects

2. The communication to you referred to in paragraph 12.1 of this Article shall not be required if any of the following conditions are met :

  1. Vietnam Airlines has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption.
  2. Vietnam Airlines has taken subsequent measures which ensure that the high risk to your rights and freedoms referred to in paragraph 1 is no longer likely to materialize;
  3. It would involve disproportionate effort for Vietnam Airlines. In such a case, there shall instead be a public communication or similar measure whereby you are informed in an equally effective manner.

Article 13. The Data Controller and the Data Protection Officer.

The Data Controller is Vietnam Airlines JSC, a lawfully incorporated under the law of Vietnam, having its head office at 200 Nguyen Son Street, Bo De Ward, Long Bien District, Hanoi, Vietnam

Name: Vietnam Airlines JSC

Email: dpo@vietnamairlines.com

Address: 200 Nguyen Son Street, Bo De Ward, Long Bien District, Hanoi City, Vietnam

In order to ensure the security of your personal information and to protect your rights and freedoms, we have appointed two Data Protection Officers:

Name: Nguyen Nam Tien (Mr.)

Address: 200 Nguyen Son Street, Bo De Ward, Long Bien District, Hanoi City, Vietnam

Email: dpo@vietnamairlines.com

Name: Pham Ngoc Binh (Mrs.)

Address: 51-53 avenue des Champs Elysées, 75008 Paris, France

Email: dpo@vietnamairlines.com

Article 14. The effectiveness of this Privacy Policy

This Privacy Policy shall take effective as of 25 May 2018 and replaces our previous Privacy Policy.

Vietnam Airlines makes sure that the protection for Personal Information is implemented and the person in charge of it complies with the required policy.

We reserve the right to amend this Privacy Policy from time to time if necessary. The updated version will be posted on our website and date stamped so that you can aware of when the Privacy Policy was last updated.

This Privacy Policy is updated to date as of 25th May 2018.