Privacy Policy

Privacy Policy

Introduction

Welcome to the Privacy Policy of SriLankan Airlines Limited (SriLankan).

SriLankan is a company registered in Sri Lanka with the company registration number PB 67 and the registered office is at “Airline Centre”, Bandaranaike International Airport, Katunayake, Sri Lanka.

Your privacy is important to us and we want to assure you that that the Personal Data we collect about you will be treated with care. This Privacy Policy will inform you about how we look after your Personal Data when you avail the services of SriLankan through various means such as visiting our website, purchasing a ticket through our website or the Global Contact Centre, from one of our offices or agents, and tell you about your privacy rights and how the law protects you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here. By continuing to avail SLA’s services, you agree that you have read, understood and agreed to this Privacy Policy.


Definitions

This Privacy Policy uses a number of definitions which are set out below:

Comply with a legal or regulatory obligation: processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Legitimate Interest  the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract: processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Personal Data:  any information which identifies an individual or information relating to an individual who can be identified (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data does not include anonymous data or data that has had the identity of an individual permanently removed.

Processing or Process:  any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Special Categories of Personal Data: any data which reveals details about sensitive issues such as an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health or genetic and biometric data.


Important Information And Who We Are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of this website, global contact centre, purchasing air tickets, including any data you may provide through this website when you make or amend a flight booking, join our Frequent Flyer Programme of ours and participating in the frequent flyer programme of any member of oneworld Alliance, purchasing any holiday package from us, obtaining any other value added services from us, participating any survey, or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children unless provided by the parents or guardians.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Data Controller

SriLankan is the Data Controller of all Personal Data relating to our passengers, employees and third party individual contact, as well as any other Personal Data used in our business for our own commercial purposes. This means that SriLankan is responsible for determining when, why and how to Process Personal Data and for establishing practices and policies in line with applicable data protection law.

SriLankan is part of the SriLankan Airlines’ Group, including SriLankan Catering Limited, which, together with SriLankan itself, are collectively referred to as the Group

For the purpose of the General Data Protection Regulation (“GDPR”), SriLankan has appointed the UK Information Commissioner’s Office (ICO) as its Supervisory Authority. Our office in London is the representative in the EU for the purposes of GDPR and it is located at 7th Floor One Lampton Road Hounslow Middlesex TW3 1JB United Kingdom.

This Privacy Policy is issued on behalf of the Group so when we mention “SriLankan”, "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a service with us. SriLankan is the controller and responsible for this website.

Data Protection Officer

SriLankan has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Contact details

  • Full name of legal entity: SriLankan Airlines Limited
  • Name or title of DPO: Data Protection Officer
  • Email address: privacy.office@srilankan.com
  • Postal address: “Airline Centre”, Bandaranaike International Centre, Katunayake 11450, Sri Lanka.
  • Telephone number: (0094) 19733 4488
  • Fax number: (0094) 19733 5588

Your duty to inform us of changes

It is important that the Personal Data we hold about you is accurate and current. It is your obligation as well to keep us informed if your Personal Data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by SriLankan. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this website, we encourage you to read the Privacy Policy of every website you visit.


The Data We Collect About You

Personal Data

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

  • Identity Data  includes first name, middle name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, emails from your passport or other identification documents, and Frequent Flyer Programme membership number.

  • Booking Data   includes travel details, flight numbers, itinerary, seat and meal preferences, any reservations made for value-added services, and information about your travel companions.

  • Contact Data  includes e-mail address, telephone, mobile number, postal address and fax number.

  • Financial Data  includes credit and debit card information, including your card number, expiry date, cardholder’s name, billing address, and other billing information.

  • Transaction Data  includes details about payments from you other details of services you have purchased from us.

  • Technical Data  includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

  • Profile Data   includes your username and password, Frequent Flyer Programme membership number, bookings made by you, your interests, service preferences, places of visit, feedback and survey responses.

  • Usage Data  includes information about how you use this website and services.

  • Marketing and Communications Data  includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data

When you visit this website or use any SriLankan mobile applications, we may also collect, use, store and share aggregated, anonymised statistical or demographic data (Aggregated Data)). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as it cannot directly or indirectly reveal your identity.

Aggregated Data may include the time and length of your visit to this website, the pages you have visited on this website, as well as details of the website you visited immediately prior to visiting this website. We may also record the name of your internet service provider. We use this information only to measure site activity and to develop ideas for improving our services.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

It is a necessary part of our business to collect certain types of Special Categories of Personal Data about you. For example, we need to collect data about your state of health if you inform us about that you are pregnant, have a medical condition which requires special equipment, or when you make a request for mobility assistance. Making certain meal choices will also involve the collection of data about your religious beliefs or state of health, for example if you inform us that you require a Halal or diabetic meal.

We treat our obligations to protect Special Categories of Personal Data very seriously and we will always ask your express consent to collect, process or transfer such data for specified purposes each time you provide it to us.

Personal Data relating to minor passengers

In certain circumstances, we may need to collect, process or transfer Personal Data relating to minor passengers (i.e. children under the age of 16), for example where a flight booking is made in respect of a minor passenger. This is necessary for us to pursue our legitimate interest in running our business and to perform the contract of carriage.

We will only use Personal Data relating to minor passengers for the specified purposes set out in paragraph 6 and with the express consent of the person who has parental responsibility for the minor passenger. Minor passengers have the same rights as any other passenger regarding their Personal Data which are set out in paragraph 11.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, or we are required that information mandatorily to provide the services your are looking for and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept the services you are looking for, but we will notify you if this is the case at the time.


How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide to us when you:

    • book a flight or arrange any other service with us;

    • create an account on this website;

    • join our Frequent Flyer Programme;

    • purchasing holiday packages from us;

    • subscribe to our newsletter;

    • enter a competition, promotion or survey; or

    • give us some feedback;

    • making complaints on our services.

  • This website. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see paragraph 6 below and our Cookie Policy for further details.

  • Our mobile website and mobile applications. Our mobile website and mobile applications have the ability to access mobile device information to better serve passengers in the service that is used. We may use location data for our mobile website and mobile applications to enable us to provide the most helpful format and content (for example pre-populating your departure airport based on current location) providing that you have agreed to the use of your location data. If you would like to restrict our collection of your location data, please adjust the settings on your device.

  • Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources such as set out below:

    1. (i) analytics providers such as Google based outside the EU;

    2. (ii) advertising networks based within and/or outside the EU;

    3. (iii) search information providers within or outside EU;

    4. (iv) contact, Financial and Transaction Data from providers of technical or payment services within or outside the EU; or

    5. (v) identity and Contact Data from data brokers or aggregators within or outside the EU].


How We Use Your Personal Data

We will only use your Personal Data in the manners permitted by law. Most commonly, we will rely on the following types of lawful basis to process your Personal Data:

  • Legitimate Interests: the interests of SriLankan in conducting and managing our business in order to give you the highest standard of service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests.

    We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your express consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Performance of Contract: processing your data is necessary for the performance of the contract of carriage to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation: processing your Personal Data may be necessary for compliance with a legal or regulatory obligation to which we are subject.
  • Consent: in certain circumstances, we may ask for your express consent to collect, process or transfer your Personal Data, for example in relation to opting in to our newsletter and other direct marketing. You have the right to withdraw your consent at any time simply by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of primary ways we will use your Personal Data, and which types of legal basis we rely on to do so. However, it is may not be an exhaustive list and we will be able to provide additional information you may require in that regard upon request. We have also identified what our legitimate interests are where appropriate. We may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new account holder or Frequent Flyer Programme

  1. Identity

  2. Contact

Necessary for our legitimate interests (for running our business)

To process and administer flight reservations and any other requests that you make in connection with our services including:

  1. Manage payments, fees and charges

  2. Collect and recover money owed to us

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

  5. Marketing and Communications

  1. Performance of a contract with you

  2. Necessary for our legitimate interests (to recover debts due to us)

To process and administer reservations for our cargo services

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

  5. Marketing and Communications

  1. Performance of a contract with you

  2. Necessary for our legitimate interests (to recover debts due to us)

To arrange any special assistance you require or make arrangements for special medical equipment, which may necessitate providing the data to our third party suppliers

  1. Identity

  2. Special Categories

  1. Performance of a contract with you

  2. Necessary for our legitimate interests (to enable us to assist you in boarding your flight and travelling safely)

  3. Express consent requested during the booking process

To arrange meal choices which may identify your religious beliefs or state of health, which may necessitate providing the data to our third party suppliers

 

  1. Identity

  2. Special Categories

  1. Necessary for our legitimate interests (to enable us to provide you with a meal which fits your religious beliefs or to ensure medical safety)

  2. Express consent requested during the booking process

To manage our relationship with you which will include:

  1. Notifying you about changes to our conditions of carriage, Privacy Policy or any other terms and conditions

  2. Asking you to leave a review or take a survey

  3. personalising your customer experience

  4. improving our customer service

  1. Identity

  2. Contact

  3. Profile

  4. Marketing and Communications

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation

  3. Necessary for our legitimate interests (to keep our records updated and to study how passengers use our services)

  4. Necessary for our legitimate interests to present you with the right kinds of products and services

  5. Necessary for our legitimate interest in improving our customer service

To enable you to partake in a prize draw, competition or complete a survey

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Marketing and Communications

  1. Performance of a contract with you

  2. Necessary for our legitimate interests (to study how passengers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity

  2. Contact

  3. Technical

  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

  2. Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Marketing and Communications

  6. Technical

Necessary for our legitimate interests (to study how passengers use our services, to develop them, to grow our business and to inform our marketing strategy)

To improve the security and safety of our services

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

  5. Profile

Necessary for our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so

To use data analytics to improve this website, services, marketing, passenger relationships and experiences

  1. Technical

  2. Usage

Necessary for our legitimate interests (to define types of passengers for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

Necessary for our legitimate interests (to develop our services and grow our business)

To process your job applications

  1. Identity
  2. Contact
  3. Job Application

Necessary for our legitimate interest to recruit new employees or contractors

Cookies

This website makes use of cookies to measure site activity and to enhance your experience in searching our services. Cookies are alphanumeric identifiers that are sent to your computer when you visit websites and online services. If your web browser’s preferences are set to accept it, the cookie is stored on your computer’s hard drive. Cookies enable our and other websites to recognize your preferences and to tailor content to you.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

The “soft opt-in”

You will continue to receive marketing communications from us if you have previously booked flights or purchased other services from in the past, or if you have requested information from us in connection with a potential booking or purchase, unless you have opted out of receiving future marketing communications.

Third-party marketing

We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.

Opting out

You may withdraw your consent to receive promotional emails at any time either by unsubscribing through the link provided in such an email or by changing the settings in your personal account with us.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Disclosures Of Your Personal Data

We may have to share your Personal Data with the parties set out below for the purposes set out in paragraphs 5 and 6 above

Internal Third Parties

Other companies in the Group, outstations, branches and offices based in Sri Lanka and other countries who are acting as joint controllers or processors.

External Third Parties

  • Service providers, contractors, and agents acting as processors based who provide providing services such as hotels, insurance packages, duty free items on board, call centres, data processing and analytics, marketing and research, limousine services, distribution, revenue optimization, payment, and other services to SriLankan in connection with the operations of the business of SriLankan Airlines’ Group.

  • Business partners of SriLankan such as code-share partners, sea and land transport service providers, and members of any airline alliance in which SriLankan is a member.

  • With partners of the Frequent Flyer Programme of SriLankan.

  • With the frequent flyer programmes of operators of other partner airlines.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • With Internet payment gateway service providers, banks, credit/debit card companies, and other financial services providers.

  • With any law enforcement authority or governmental institution for security, customs, immigration, or any other investigative purpose.

  • Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.


International Transfers

Internal Transfers

SriLankan is an international commercial airline operating in many different jurisdictions and, accordingly, it will be necessary to transfer your data outside of the European Economic Area (EEA).

External Transfers

Many of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Data to third parties which are based outside the EEA, we ensure a similar degree of protection is afforded to the data by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.


Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


Data Retention

How long will you use my Personal Data for?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In order comply with applicable laws locally, we may store your data up to a period of 12 years from the time of receiving.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure at paragraph 11 below for further information.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

  • Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


Changes To This Privacy Policy

SriLankan will amend this Privacy Policy from time to time in accordance with applicable laws and regulations, and the updated version will be posted on this website. We request that you revisit this website from time to time for updates on the Privacy Policy. Historic versions of this Privacy Policy can be obtained by contacting us.

The Privacy Policy may be translated into different languages, and in the event of any inconsistency among the versions, the English version shall prevail.


Complaints

If you have any comments, questions or concerns about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us to see if we can help resolve the issue in the first instance.


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