Effective date:

Flair Vacations’ Privacy Policy

Flair Vacations is the vacation-package service of Flair Vacations LP, a subsidiary of Flair Airlines Ltd. (“Flair”, “Flair Vacations”, “we”, “us”, or “our”), through which you can book flights, accommodation, car rental, excursions, travel insurance, and related travel services. This policy explains how we collect, use, disclose, and protect personal information when you visit the Flair Vacations website and related web applications (the “Flair Vacations Site”), make a booking, or otherwise interact with us.

General

We have designed this policy to meet or exceed the requirements of the Government of Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada’s Anti-Spam Legislation (CASL); Quebec’s Act respecting the protection of personal information in the private sector, as amended (commonly referred to as “Law 25”); and, where applicable to a particular traveller, the privacy laws of U.S. states that apply to residents travelling to or from the United States. Where the law of a traveller’s place of residence provides a higher standard of protection, we apply that higher standard.

Flair Vacations’ Site and booking management may be hosted and operated, in whole or in part, on Flair’s behalf by third-party travel technology providers (the “Third-Party Provider”). Because our Third-Party Provider may be established in Quebec and we serve travellers across Canada, including Quebec residents, personal information processed through the Flair Vacations Site is handled in accordance with the stringent requirements of Quebec’s private-sector privacy legislation, in addition to the other laws described below.

We reserve the right to update or revise this policy from time to time. Where required by applicable law, we will give notice of material changes. Any revised policy will govern personal information handled after the revision takes effect and will bear a new effective date.

Our Commitment & Accountability

We have adopted internal policies and procedures designed to protect the personal information in our possession or control, and we review them regularly. Access to personal information is limited to those who require it to perform their duties; our personnel receive privacy training; and they are bound by confidentiality obligations. Flair has designated a person responsible for the protection of personal information (our Privacy Officer), whose role is to oversee compliance with this policy and applicable law and to respond to your requests. You can reach the Privacy Officer using the contact details at the end of this policy.

Flair remains accountable for personal information handled on its behalf. The Flair Vacations Site is hosted and operated by the Third-Party Provider, and we also use other service providers to help us deliver our services. The Third-Party Provider and our other service providers are contractually required to protect personal information using administrative, technical, and physical safeguards that are equivalent to those Flair applies; to process personal information only for the purposes we authorize, under our direction, and in accordance with this policy; and to comply with applicable privacy law, including Law 25. Where personal information is processed in Quebec by our provider, it benefits from the protections of Quebec law.

Scope & Third-Party Sites

Unless we tell you otherwise at the time of collection, this policy applies to all personal information we collect and process when you deal with Flair Vacations. The Flair Vacations Site may contain links to third-party websites (for example, hotels, insurers, or excursion operators). Those sites are not governed by this policy, and we encourage you to review their privacy policies before providing personal information to them.

How We Define Personal Information

Personal information refers to details unique to an identifiable individual. We only collect the personal information necessary to provide our services to you. “Personal information” includes your full name, address, telephone number, date of birth, email address, and any other information unique to you alone. This information helps identify who you are and may be used to contact you if necessary to complete your purchase.

Additionally, we request your gender or other statistics to assist in estimating the aircraft’s total load and to help us identify you for legal, security, and aviation regulatory compliance purposes. You are only required to disclose your gender if your itinerary includes international travel.

Personal information becomes known to Flair when you provide it directly to us, or when a third party, such as a friend or family member, books travel on your behalf with your consent.
If you request a customized service, such as support with accessibility or for the carriage of special items, we may also need to collect additional personal information, as described below.

Personal Information We Collect

The personal information we collect depends on how you interact with us and the services you request. It may include:

  • Identification information: full legal name, date of birth, gender where required for travel, citizenship or nationality, and passport, visa, or other travel-document details;

  • Contact information: home address, telephone number, email address, and emergency-contact details;

  • Booking and package details: your itinerary, flight, hotel, car rental, excursion, and insurance selections, reservation references, seat and room preferences, and loyalty details;

  • Payment information: credit or debit card details, billing address, and transaction history (processed by our payment processor);

  • Government-required information: information we are required to collect or share with Canadian, U.S., or international authorities, including advance passenger and passenger-name-record information;

  • Special-service and sensitive information: accessibility needs, mobility-aid or medical requirements, and dietary requirements, which you provide so that we can arrange the services you request;

  • Digital and technical information: IP address, device identifiers, browser type, website-usage data, and, depending on your device settings, location data collected through cookies and similar technologies (see the Cookies section); and

  • Communications: records of your correspondence and interactions with us, including customer-service communications.

Where a booking is made on your behalf by a family member, friend, travel agent, or other third party, that third party must have your authority to provide your personal information and consent, and the handling of that information is subject to this policy.

How We Collect that Personal Information

Personal information can be collected directly from you during any interactions you have with us, for example when you visit the Flair Vacations Site and book your vacation, or when you communicate with us by telephone or email, or when you participate in a survey or contest. But it may also come from other sources, including:

  • Third-party partners who act on our behalf to provide services to you, for example as gate agents, ground handlers and baggage handlers;

  • Third-party suppliers or commercial partners, for example when you book through a travel agency, or stay with a partner hotel;

  • Authorities such as airport, border and immigration officials or police;

  • Your family or friends or anyone that you have authorized to act on your behalf, for example when someone makes a travel booking for you.

Our Purposes for Collecting & Using Personal Information

We use personal information for business purposes such as to process, manage and fulfill your vacation booking, and any such purpose that is reasonably necessary to provide the services you request, including to:

  • To identify you, in order to confirm and manage your booking;

  • To process and fulfill your bookings and travel arrangements, and coordinate with the travel partners involved in your package (including Flair Airlines, hotels, car-rental companies, excursion and tour operators, and insurers);

  • To process payments and prevent, detect, and investigate fraud;

  • To identify you when you are using our airport services, such as when you check in at our airport counters or self-service kiosks;

  • To verify identity and meet security, border, customs, and aviation-regulatory requirements of Canadian, U.S., and international authorities;

  • To communicate with you about your bookings, including confirmations, schedule changes, and disruptions. We may need to contact you by email, telephone, SMS for administrative or operational reasons (e.g. informing you of your travel itinerary notify of check-in, or disruption management);

  • To arrange the accessibility, medical, dietary, or other special services you request;

  • To send you marketing communications where you have consented, each of which includes a functioning unsubscribe mechanism;

  • To analyze and improve our services, website, and operations;

  • To administer loyalty, credit, promotional, or other programs in which you participate; and

  • To protect the safety and security of travellers, our personnel, and our operations, and meet our legal obligations.

Depending on the circumstances, we rely on one or more of the following bases to process your personal information: your consent; the performance of our contract with you (for example, to fulfil your booking); compliance with our legal obligations (for example, sharing information with border, customs, or security authorities); and our legitimate business interests, provided these are not overridden by your privacy rights (for example, fraud prevention, security, and service improvement).

We collect, use, and disclose your personal information with your knowledge and consent, except where otherwise permitted or required by law. Consent may be express or implied, and the form of consent we seek reflects the sensitivity of the information. You may withdraw your consent at any time, subject to legal and contractual restrictions, by contacting our Privacy Officer; we will explain the consequences of withdrawal, which may include our inability to provide certain services.

Where a booking is made on behalf of a minor, the person making the booking confirms that they have the authority to provide the minor’s personal information and consent. In Quebec, the personal information of a minor under 14 years of age is collected only with the consent of a person having parental authority or a tutor, except where collecting it is clearly for the minor’s benefit.

Sensitive Personal Information

Some information is sensitive because of its medical, biometric, or otherwise intimate nature, or because it could reveal information such as health, disability, or religious beliefs (for example, a request for accessibility assistance, a medical requirement, or a special meal). We collect sensitive personal information only where it is necessary to provide the services you have requested, and we collect and use it only with your express consent. We apply governance measures appropriate to the sensitivity of the information.

Disclosure of Personal Information to Third Parties

We do not sell your personal information. We may disclose it in the following or similar circumstances:

  • Service providers: The Third-Party Provider which hosts and operates the Flair Vacations Site, and our other service providers (such as IT and cloud providers, payment processors, and customer-service and marketing providers) process personal information only on our behalf, under our direction, and only for the purposes we authorize. They are contractually required to apply administrative, technical, and physical safeguards equivalent to those Flair applies and to comply with applicable privacy law;

  • Travel partners: the airlines (including Flair Airlines), hotels, car-rental companies, excursion and tour operators, and insurers needed to deliver your package;

  • Government and regulatory authorities: where required by law or by border, customs, security, or aviation regulations, which in some cases may occur without your consent as permitted by law;

  • Legal proceedings: in response to a valid court order, subpoena, or other legal process, or where reasonably necessary to protect rights, property, or safety; and

  • Corporate transactions: in connection with a merger, acquisition, financing, or sale of assets, subject to equivalent privacy protections.

Cookies & Tracking Technologies

The Flair Vacations Site uses cookies and similar technologies. Essential cookies are necessary for the site to function; analytics cookies help us understand and improve the site; and advertising/targeting cookies may be used to show you relevant advertisements. Where we use technology that includes functions allowing you to be identified, located, or profiled, we will inform you and those functions are deactivated by default unless you activate them. You can manage cookies through your browser or our cookie-preference tool.

Cross-Border Use of Personal Information

Because travel is international by nature, your personal information may be transferred to, stored in, or accessed from destinations outside your province or country of residence, including outside Canada. We use contractual and other means to ensure that the information receives protection that is comparable to that afforded under applicable Canadian law. You should be aware that, while your personal information is in another jurisdiction, it may be accessible to the courts, law enforcement, and national-security or other authorities of that jurisdiction under its domestic law.

How We Keep Your Personal Information Safe (Security Safeguards)

We use physical, technological, and administrative measures to protect personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. These include:

  • Physical safeguards: controlled access to premises and secure storage;

  • Technological safeguards: encryption (Transport Layer Security), access controls, and monitoring;

  • Administrative safeguards: privacy and security training, internal governance policies, audits, and confidentiality obligations; and

  • Contractual safeguards: as noted above, the Third-Party Provider and our other service providers are required to maintain safeguards equivalent to those Flair applies.

Despite these measures, no method of transmission or storage is completely secure. If a confidentiality incident (a breach of security safeguards) involving your personal information occurs and it presents a risk of serious injury, we will, in accordance with Law 25, notify the Commission d’accès à l’information du Québec and the affected individuals as promptly as possible, and we will notify the Office of the Privacy Commissioner of Canada and affected individuals where required under PIPEDA.

Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and to meet legal, accounting, and tax obligations. Retain will vary according to each situation and Flair must consider limitation periods and appeals that may be relevant and applicable. We may retain your personal information after your business relationship with us has ended, such as to retain your personal information for customer service purposes and to enhance your experience with us. We protect the personal information we hold and once the retention period has expired and personal information is no longer required, we that personal information is securely destroyed or anonymized as the case may be.

Your Privacy Rights

Subject to applicable law, you may:

  • Access the personal information we hold about you and ask how it is used and disclosed;

  • Request that we correct inaccurate, incomplete, or out-of-date information;

  • Withdraw your consent to the collection, use, or disclosure of personal information, subject to legal and contractual restrictions;

  • Request that computerized personal information you have provided be communicated to you, or to a person or body you designate, in a structured, commonly used technological format (data portability), where Law 25 or other applicable law provides this right;

  • Request, where applicable, that we cease disseminating personal information or de-index a link where dissemination causes serious injury contrary to law; and

  • Make a complaint about our handling of your personal information to our Privacy Officer and, if you are not satisfied, to the Commission d’accès à l’information du Québec (for Quebec residents) or the Office of the Privacy Commissioner of Canada, or the applicable authority in your jurisdiction.

How to Contact Us

To exercise your rights or ask questions about this policy, contact the person responsible for the protection of personal information (our Privacy Officer):

Attention: Privacy Officer, Flair Vacations (Flair Airlines Ltd.)
Email: privacy@flyflair.com
Mailing Address: 6543 – 1000 Airport Road, Edmonton International Airport, Leduc, Alberta, T9E 0V3

We will respond to your request within the time required by applicable law (generally within 30 days).

Language

This policy is available in French, and the French-language version is made available to Quebec residents in accordance with the Charter of the French Language. You may deal with us in French or English.

Effective Date and Revisions

This Privacy Policy is effective as of the date shown above. Flair may update or amend it from time to time, in which case the posted policy will bear a new effective date. is in another jurisdiction, it may be accessible to the courts, law enforcement, and national-security or other authorities of that jurisdiction under its domestic law.