Privacy policy

General

The Airline was established in accordance with laws of the Russian Federation and is registered at: Property 4, bldg 1, Kievskoe Shosse, 22nd km, Moscovsky Settlement, Moscow, 108811; TIN 9705001313, PSRN 5147746103380; Call Center (subject to toll): +7 (809) 505-6777.

The Policy regulates which of your personal data may be processed by the Airline.

It is for informational purposes only and is not part of an air carriage contract or any other consumer contract that may be made between you and the Airline. However, if you sign an air carriage contract or other consumer contract with the Airline, this means that before signing the contract you have carefully read the Policy and agree with its contents without any reservations.

When processing your personal data, the Airline shall take, or ensure, all actions as may be required for the data protection.

For questions related to personal data processing, please contact the Airline’s representatives by email at dpo@pobeda.aero, or by sending a letter to the Airline’s postal address as mentioned in this paragraph hereof.

The current version of the Policy is available on the Airline’s official website at https://www.flypobeda.ru.

Basic Terms

The Airline shall mean Pobeda Airlines Limited Liability Company.

You/the client shall mean the Airline’s clients and, in some cases, other persons using the Airline’s services or the Airline’s online resources.

The Airline’s Online Resources shall mean tools on the Internet, which may be run by the Airline.

The Personal Data Processing shall mean any action (operation) or a set of actions (operations) performed, with or without the use of automation tools, with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating and/or changing), extraction, use, transfer (disclosing and/or providing access to), blocking, deletion and destruction of personal data.

The Personal Data shall mean any information relating to an identified or identifiable, directly or indirectly, natural person (Personal Data Subject).

The Policy shall mean this document.

The Special Category Personal Data shall mean Personal Data of a Personal Data Subject relating to race, ethnicity, political views, religious or philosophical beliefs, health status, intimacy or criminal records.

Sources of personal data

The Airline may process your Personal Data that you have provided, as follows:

• through the Airline’s Online Resources, including when you agree to receive newsletters (in an automated way);
• through the Airline’s mobile app (in an automated manner);
• through the Airline’s authorized agents as well as its partners providing services for booking and processing transportation documents;
• when you contact the Airline in person, e. g., in writing, by email, or when contacting the Call Center (both automated and non-automated methods).

In all of the above cases, your Personal Data may be obtained by the Airline not only from you personally, but also from third parties who may act on your behalf or in your interests (e. g., travel agents other than our partners, or other persons who may book a flight for you).

A person providing his or her Personal Data or Personal Data of any third party to be processed by the Airline guarantees that he/she is of full legal age and acts with the consent of the Personal Data Subject, or on other legal grounds.

Where you find out that your Personal Data were transferred to the Airline without your consent or against your will, or where the transferred data are incomplete or outdated, you should immediately contact the Airline in writing.

Personal Data Processing for Air Carriage

In order to conclude and execute an air carriage contract or other consumer contract, the Airline will process the following Personal Data of the client: full name, date of birth, gender, citizenship, email address, mobile phone number, identity document details, as well as information on the actual execution of the air carriage contract or other consumer contract in relation to the relevant individual.

These data may be retained after the completion of the air carriage to the extent required by the applicable law, in particular, to resolve any dispute which may potentially arise in the future.

In order to conclude and execute the air carriage contract or other consumer contract, the Airline may provide access to Personal Data to any third party that may be involved in the execution of the contract and to the extent as may be necessary for the execution thereof. In particular, the Airline may provide such access to companies involved in ground handling of aircraft, passengers and baggage, or other persons engaged by the Airline for the purpose of executing contracts that may be concluded with you.

For the purposes of air carriage, clients’ Personal Data are collected and processed by RT-Transcom, LLC (19 Leninskaya Sloboda St., floor 1, room/office 41Kh1D/V4Yu, Moscow, 115280) as instructed by the Airline. RT-Transcom, LLC shall be entitled to entrust Sirena-Travel, JSC (37/12 Leningradsky Ave., floor 4, room 42, Moscow, 125167) and International Processing Systems, LLC (5 Akademika Volgina St., Moscow, 117485) with processing Personal Data for the purpose of executing the Air Carriage Contract, including for the purposes of booking and issuing air tickets (travel tickets), baggage receipts or other transportation documents.

Processing special categories of personal data

The Airline shall process the data pertaining to a client’s health status to the extent as may be necessary for the execution and performance of an air carriage contract or any other consumer contract and for the consideration of clients’ requests related to such contracts, in particular:

• when ordering auxiliary services related to air carriage of clients with disabilities or other restrictions that may affect the normal performance of the Airline’s contract;
• when transporting certain categories of clients, when, in accordance with the current regulation, a certificate or other medical document is required to prove that there are no contraindications to the flight for health reasons or due to pregnancy;
• in the event of injuries or other health conditions that may have occurred during the air carriage, especially when staying on board the aircraft, including for further insurance claim payments;
• when considering clients’ requests or claims, including property claims, when the client refers to a particular health condition.

In those cases, receiving and processing relevant information regarding your health status is necessary to prevent harm to life and health and the proper execution of the air carriage contract or other consumer contract, therefore, your refusal to provide such information may be a reason for the subsequent refusal to provide you with the relevant service because the Airline will not be able to satisfy the minimum flight safety requirements or ensure comprehensive consideration of your request.

These data may be retained after the completion of the air carriage to the extent required by the applicable law, in particular, to resolve any dispute which may potentially arise in the future.

The Airline shall not collect data regarding the client’s health status, except as mentioned above.

Where the client is denied an air carriage contract or where the air carriage contract is terminated due to the relevant decision of an authority of the Russian Federation or other state (in particular, by virtue of Paragraph 4 of Article 786 of the Civil Code of the Russian Federation), or if the air carriage contract is terminated by the client or due to any medical indication, the Airline shall continue to process such data in accordance with the applicable laws.

Processing Personal Data as Required by Law

Personal Data of a Personal Data Subject may be stored, processed and transferred if the Airline is required to do so by a law, other regulation, or an authority.

Personal Data may be disclosed at the request of a court, bodies enforcing court decisions, law enforcement agencies or other authorities during the implementation of control and supervisory measures to monitor compliance with the rights of clients, or otherwise as required by law.

In accordance with Article 85.1 of the Air Code of the Russian Federation, in case of international carriage passengers’ Personal Data shall be transferred to authorized bodies of the states of departure, destination or transit.

Processing Personal Data for Marketing Purposes

When you subscribe to the Airline’s newsletters or participate in promotional campaigns, your Personal Data (such as your email address or other data you have provided) may be used for the purpose of advertising the Airline and the services it provides. Thus, you will be kept up to date with news about sales and will be stay informed about new flight destinations, upcoming events, etc. This information may be combined with other information in order to provide and improve our services and for advertising purposes.

This information shall be stored until you withdraw your consent, or until the purpose of processing your Personal Data is achieved.

If you wish to unsubscribe from newsletters, you can do so at any time by following the Unsubscribe link in any newsletter, by informing us via the feedback form or by sending your request to dpo@pobeda.aero.

The consent to, or refusal of, newsletters does not affect communications carried out in connection with the conclusion and execution of an air carriage contract (e. g., messages with itinerary receipts or flight status details).

Collecting Data on the Airline’s Media Resources

The Airline collects information about how you use the Airline’s mobile app and website using cookies, which are small text files stored on the user’s device and designed to provide better user experience when using the website and save time. Collection of such information is due to technological features of the above media resources, is transient (temporary) in nature and is not aimed at collecting personal information exclusively about you. Such data can be stored within a few minutes to several years, depending on the type of cookies and your browser settings.

Types of cookies used on the Airline’s websites:

• Strictly necessary cookies that are required for the website’s functions;
• Functionality cookies that help apply user settings to the website;
• Analytics cookies that collect information about how the user uses the website and that help improve its functionality.

The Airline uses Yandex.Metrica and Mindbox to collect information about how its website is used, such as how often users visit the website. This information shall not be used for any purposes other than the purpose of improving the services provided on the website. We do not combine the information received through Yandex.Metrica and Mindbox with Personal Data.

If you do not want the Airline to process the information mentioned in this section, you should refrain from visiting the Airline’s website and using its mobile app. Additionally, you can block cookies, or delete previously stored cookies, using your browser settings. In this case, some of the website’s functions may be unavailable.