• Privacy Policy

Privacy Policy

Air Inuit Privacy Policy

Protecting privacy is important to Air Inuit and safeguarding subject rights is fundamental to us. This Privacy Policy provides important information about how we handle personal information. 

Any personal information provided to us will be subject to the terms of this Policy and applicable legislations.

1.   Definitions : 

"Personal information" means any information about an identifiable individual or that, taken separately or in combination with other data, allows an individual to be identified.

"Data Subject" means a natural person who can be identified, directly or indirectly, by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural, or social identity.

"Data processing activity" means all operations relating to personal data, including but not limited to collection, use, disclosure, sharing, etc., of personal data.

"Legal purpose of processing" means the main objective of the use of personal data. Data is collected for a precise and legitimate purpose and is not further processed in a way that is incompatible with this initial purpose.

" Supervisory Authority" means the competent authority responsible for ensuring the application of the law regarding the protection of personal information. 

"Legal basis for processing" means the legal justification that allows an organization to collect, process and use personal information about individuals. 

"Data Transfers outside Quebec" means disclosing or making available personal information outside Quebec (whether to other provinces or other countries).

"Transfer" means disclosing or making available personal information to an outside third party. 

"Data Controller" means the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal information.

"Sub-processor" means the natural or legal person who processes personal information on behalf of the Data Controller.

2.   Who is the data controller?

Air Inuit is a Canadian airline based in Montreal, Quebec, founded in 1978, specialized in regional air transport and serving mainly the remote and northern regions of Quebec.

Administration
T 1 800 361-5933 / 514 905-9445
F 514 905-8916

Address - Air Inuit
6005 Côte-Vertu Blvd.
Montréal (Québec) H4S 0B1

3.   Why do we collect and use your personal information?

Air Inuit guarantees your privacy and protects the confidential nature of the information you submit. Any information you submit will remain strictly confidential and may be used for the sole purpose of establishing a customer database in order to create and promote products and services that are better suited to the needs of individual customers.

Air Inuit will not use or disclose personal data collected for any purpose other than that for which the data was collected without the express consent of the customer or as required or permitted by law.

A) Providing services 

In order to manage, by Internet or by telephone, or in-person:
-      travel reservations, travel arrangements and purchases, or
-      to provide freight forwarding services or
-      to charter our aircraft,
we need identification information, including contact information, to identify the persons receiving the service and:
-      issue ticket(s) to provide all the information relating to flights, the various stages of the journey (check-in, boarding) and changes to flight status,
-      issue an Air Waybill to ensure correct carriage of cargo shipments,
-      issue a quote and invoice for a chartering an aircraft.

In order to provide a service that meets your expectations, we also process all information relating to your requests and preferences, in particular if you have created a personal account and if you have subscribed to one of our loyalty programs. We may also record telephone calls in order to manage your requests or provide you with our products, services or support.

Thus, we process personal information because it is necessary for the performance of your contract of transport and the provision of our services.

Eventual recipient of this data

- Our service providers who support us with various functions can be provided upon request in relation to your data. (for more information see section 4 below).

B) Send you updates, and special offers tailored to your interests:

We will send you various communications (e-mails, etc.) relating to the management of your requests. If you have subscribed, we will send you personalized announcements and offers by e-mail for products and services related to our company. You can unsubscribe at any time. Our communications with you will indicate how to unsubscribe.

Channels: We use various channels such as e-mail, postal mail, advertising space on websites and social networks. For example:

  • E-mails concerning bookings and flight management: If you book a flight with us, you and the person(s) for whom you provided contact information for, may receive several e-mails concerning your booking (for example, your booking confirmation, check-in and boarding information). These messages may contain advertisements and offers for products and services related to our company.
  • E-mails concerning your cargo shipment: If you booked a cargo shipment and provided contact details for yourself and the consignee, you may both receive emails confirming the shipment travel status. These messages may contain advertisements and offers for products and services related to our company.
  • E-mails concerning your chartered aircraft: If you charter an aircraft you, and the person(s) for whom you provided contact information for, may receive emails confirming the travel arrangements. These messages contain advertisements and offers for products and services related to our company.
  • E-mails containing updates on company news and offers relating to our products and services: These e-mails contain offers relating to our products and services as well as similar services offered by our partners. With your consent, we may also send you e-mails on special occasions, such as a special offer for your birthday or personalized offers for a forthcoming trip in the months following your return.

In this way, we send you e-mails relating to the travel booked and shipment requests for the execution of the contract. With your consent, we send you communications containing company news updates and offers relating to our products and services. 

C) Communicating with you 

We use your information to communicate with you about our products, services or loyalty programs, to answer your questions and to process your complaints.

Thus, we process your personal information because it is necessary for the performance of your contract of carriage and the provision of our services. 

D) Ensuring flight safety 

Any incident likely to jeopardize the safety or security of a flight may be recorded by computer and/or a complaint filed, and in the event of serious offences, may result in the passengers concerned being barred from Air Inuit flights. This computerized recording is mainly carried out to ensure the management of significant events linked to flight safety, and in particular events linked to the behaviour of unruly passengers. 

We process this information in order to comply with our legal or regulatory obligations and to ensure the safety of our flights and passengers. 

Eventual recipient of this data : 
- Public authorities or governmental organizations for the purposes of the Canadian Government’s Passenger Protection Program, border control, immigration, entry into a country, and other security or fight against terrorism measures.

E) Manage our litigation, prevent fraud or comply with our legal obligations 

We collect, store and use your information for internal business purposes, such as record keeping, managing our legal affairs, preventing non-payment and fighting fraud. In the event of fraud, we may include your personal information in our internal control and alert systems. In addition, we process your personal information in accordance with our legal and tax obligations.

We process this information in order to comply with our legal or regulatory obligations.

Eventual recipient of this data : 
- Public authorities or governmental organizations for the purposes of travel control, entry into the territory of a State or Province, security or the fight against terrorism. 

F) Offer you specific services, events, competitions or exceptional campaigns

For specific services, events, contests or special campaigns, we may use your personal information for purposes other than those described in this Privacy Policy. We will inform you of these purposes when you sign up for the service, event, contest or campaign. 

This processing of personal data is based on your consent. You may withdraw your consent at any time for the processing concerned. 

Eventual recipient of this data : 
-        Our occasional partners for events, contests or special campaigns (the specific recipients are indicated in the information on the processing of your personal data, if you need further information, please contact us).

4.   Third Party Services Providers

We may transfer personal information you provide to service providers who support us with various functions including, reservations and ground handling, information security, data storage, research, customer relations, payment processing, data analysis, email delivery, IT, customer service, and marketing. 

To the extent Air Inuit employs third-party service providers to store, handle or process personal information on our behalf, they must agree to certain privacy obligations in their contracts with us. 

Personal information may be sent to our partners, including those to provide:
-        the transport of goods.
-        service charter and aircraft maintenance.
-        customers with flight services.
-        flight planning and operations.

Some of these providers may store the personal information you provide in other provinces or countries. If you have questions about how we share this information with third parties outside of Quebec or Canada, or you would like to obtain more information about our policies and practices with respect to service providers, please contact our Data Protection Officer at RPRP-DPO@airinuit.com.

5.   What personal information do we process during our activities?

a) Personal identifying information: 

When you make a reservation, arrange a cargo shipment, or charter an aircraft with Air Inuit, we may collect identifying information of such as title, surname, first name, gender, date of birth, nationality, country of residence, as well as information contained in travel documents, such as passport or any other document accepted and issued by the relevant authorities (citizenship card, permanent residence card, driver's license, health insurance card, etc.). For example, for unaccompanied minors, we collect the identification information of the parent or legal guardian. You can save this information in your personal account and use it for future bookings, but this is optional.

b) Contact, personal account or registration information:

Contact information provided to us, including telephone number(s) and e-mail address(s), are recorded at the time of booking. If you create a personal account or subscribe to a specific service, we may also record your postal address, login details and any other information provided on the relevant registration forms. For example, for unaccompanied minors, we collect the contact details of the parents or legal guardians, as well as the persons responsible for dropping off and picking up the child at the airport of departure and arrival. In the case of business trips, we may collect information relating to your company, such as company name and address, via contract numbers.

c) Information concerning your reservations, ticket purchases or other services:

When you make a reservation on an Air Inuit flight, arrange a cargo shipment, or charter an aircraft we process the information you provide, including flight details, prices and booking dates. We also process information about additional services that may be selected such as extra baggage and seating options, specific cargo requirements as well as information needed to finalize and pay for your reservation or cargo shipment. If product purchases are made on the Air Inuit website, we also collect information relating to these purchases.

d) Travel information:

When you and the passengers you have booked for travel with Air Inuit, we process information related to the trip, such as the itinerary, online or airport check-in, mobile or printed boarding pass. We may also collect specific assistance needs for travel at airports and on board our aircraft, as well as meal preferences. We may also be required to collect and check documents required by the authorities in the destination country for public health purposes, such as the health context linked to the Covid-19 epidemic. 

e) Information relating to our loyalty programs :

If you become a member of Air Inuit programs (Isaruuk Rewards, Katutjiniq Start-up Incentive, Ilaujuq for beneficiaries, etc.), we process information such as your membership number and other details required in order to ensure points are earned and redeemed, and that other activities can be performed relating to your loyalty benefits. As the information collected for this purpose may constantly change, if you would like more up-to-date details, please contact us at RPRP-DPO@airinuit.com.

f) Membership of our other offers or discount programs :

When you subscribe to one of Air Inuit's specific offers or programs, we collect the information needed to validate your subscription and provide the corresponding services during your trip.

g) Activating travel entertainment services :

If you use the on-board entertainment services offered free of charge by Air Inuit, we do not store any information regarding your browsing.

h) Interactions, electronic or telephone communications :

When you communicate with us by e-mail or on social networks, we keep a record of these exchanges. We may also record telephone calls as part of service quality monitoring or for evidential or fraud prevention purposes. Your communication preferences, such as subscribing to or unsubscribing from our newsletters, are also recorded.

i) Information you choose to share with us :

We process the information you choose to share with us, for example when you share your interests and preferences on our website, leave a comment on our social networking pages or on our website. 

j) Sensitive information : 

We may collect information that is sensitive under applicable privacy laws, such as specific assistance needs or meal preferences for medical or religious reasons. This information is only collected with your consent and is used solely to provide the service concerned during your travel.

k) Collecting information on minors :

We only collect and process personal data relating to minors under the age of 14 with the prior consent of their parents or guardians. If personal data relating to minors under the age of 14 is collected without such consent, the parents or guardians have the right to object to the corresponding processing or to request the deletion of such data.

6.   How do we collect personal information?

a)     We collect the personal information you provide to us directly. 

For example, we collect personal information when you book a flight with us, make a purchase, check in, create an online account, enroll in one of our loyalty programs, arrange a cargo shipment, charter an aircraft, make a request or claim, respond to a satisfaction survey, leave us a message on social networks, contact our customer service, subscribe to receive our e-mails, or register for one of our events, contests or specific campaigns. 

b)    We receive your personal information from your tour operator or travel agent, from our airline partners or from other companies involved in the organization and management of your travel. 

We receive your information from these third parties via reservation systems (e.g. Global Distribution System/GDS, or any other technology) in order to deliver our services to you. For example, when you book a flight through a travel agency or an online booking site, we receive all the information we need to manage your reservation and make your trip possible. The companies involved in organizing and managing your travel arrangements are also responsible for processing your personal information. You will find more information on how they handle your personal information in their respective privacy policies.

c)     When you use our website, we collect information using cookies and similar technologies.

Air Inuit uses its own cookies and third-party cookies, or similar technologies, to ensure that we give you the best experience on our website. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work more efficiently and to provide information to the owners of the website. We may use both session cookies or persistent cookies, for example, to remember the selected language and whether the visitor is signed-in to the website’s administration dashboard. By continuing to visit or use our website, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this policy. You can change your cookies settings anytime following the controls provided by your browser. Please contact us at RPRP-DPO@airinuit.com for a current list of third-party cookies providers we use and more details.

7.   Under what regulatory framework can information be transferred outside the Province of Quebec?

Before disclosing personal information outside Quebec, Air Inuit is responsible for conducting a Privacy Impact Assessment (PIA), taking into account:

-        the sensitivity of the information
-        the purposes for which it will be used
-        the safeguards that would apply, including contractual safeguards; and
-        the applicable legal framework in the jurisdiction where the information would be disclosed, including the extent to which the legal framework is consistent with Quebec privacy laws.

Personal information is then transferred outside Quebec only if the assessment determines that it benefits from an adequate level of protection.

8.   How do we protect personal information? 

As the controller, Air Inuit takes all necessary measures to ensure the security and confidentiality of personal information. We strive to prevent any damage, unauthorized access or misuse of information. To achieve this goal, we implement appropriate organizational and technical measures, taking into account the sensitivity of the information and the risks involved in processing such information.

Air Inuit's Internet systems are configured with data encryption. This means that when an individual submits personal information through its website, the electronic data is protected by Secure Socket Layer (SSL) technology to ensure its safe transmission. In addition, any personal information kept in hard copy is retained in secure facilities. Access to these facilities is restricted to authorized Air Inuit personnel only. The physical security of our IT systems is a priority, and we ensure that the buildings housing these systems are well secured. Therefore, we also ensure that information is stored in secure information systems, with access restricted and protected.

We require all our staff, and anyone involved in the processing of information, to scrupulously comply with data protection rules and to maintain the confidentiality of the information processed. We also establish strict confidentiality agreements with our subcontractors and partners to ensure that they also comply with privacy rules. Our aim is to guarantee the confidentiality, integrity, availability and resilience of information, while maintaining an appropriate level of security for its processing.

9.   How long do we keep your personal information?  

Our data retention objective is set by legal responsibility, i.e. 7 years (point a) c) d) of the purposes for processing your personal information). Where the processing of your personal information is based on consent (points b) and f) of the purposes for which your personal information is processed), the retention periods for your personal information may coincide with the withdrawal of your consent. Some personal information must still be retained to comply with legal or other constraints. 

When no longer needed, personal information is destroyed, anonymized or disposed of using secure methods.  If you have any questions regarding the retention period that applies to your personal information, please contact our Data Protection Officer at RPRP-DPO@airinuit.com.

10.   What rights do you have and how can you exercise them? 

In accordance with the applicable regulations, you may have the right to (a) access, (b) rectify, (c) delete, (d) limit the processing of your data, (e) portability of your data and (f) object to the processing of your data.

a)     The right of access 
You may have the right to request confirmation that we are processing your personal data and, if so, to receive a copy of it. When we respond to a request to exercise the right of access, we also provide you with additional information such as the purposes of the processing concerned, the categories of personal information and any other information relating to such processing. 

b)    The right of rectification 
You may have the right to request rectification of your personal data if you find it to be inaccurate. You may also, in view of the purposes of the processing concerned, request that it be supplemented, which may involve the provision of additional information. 

c)     The right to erasure 
You may have the right to request the deletion of your personal information. This right can only be exercised in certain cases. For example, your personal data may no longer be required for the purposes for which it was collected, or it may have been processed unlawfully. If you exercise this right, and if one of the reasons applies to your request, we will delete your personal data as soon as possible.

d)    The right to portability of personal information
You may have the right to request the provision of the personal information you have directly communicated to us in a structured, commonly used and machine-readable format. Where appropriate and technically feasible, you may also directly request the transfer of this information to another data controller.    

e)     The right to limit the processing of personal information
You may have the right to limit the processing of your personal data. This means that we will mark your personal data, if we keep it, with a view to temporarily suspending its processing. This right does not give rise to erasure, and we are obliged to inform you before the corresponding processing restriction is lifted.

f)      The right to object 
You may have the right to object to the processing of your personal information. This means that you can ask us to stop processing your personal data. For example, you can object at any time and without any cost to the processing of your personal data for direct marketing purposes, including profiling purposes insofar as they are related to such direct marketing. If you exercise this right, we will no longer process your personal data for these purposes. You may also, when in contact with our customer service department during a recorded call, decide not to continue the call.

g)    Withdrawal of your consent 
Where required by law for certain processing purposes, your information will only be used after we have obtained your explicit consent.  You may withdraw your consent at any time by following the specific instructions relating to the processing concerned. For example, you can withdraw your consent by clicking on the unsubscribe link contained in our e-mails (e.g. Air Inuit newsletter), or by changing your communication preferences on your account if the option is available. For more information on how you can withdraw your consent to the cookies and similar technologies we use when you visit our websites or use our mobile applications, please consult section 6)c) of this policy.

h)    Complaints to the Supervisory Authority
Individuals may, if they deem it necessary, especially after contacting us, lodge a complaint with the competent personal information protection authority (Commission d'Accès à l'Information pour le Québec). 

i)      Refusal of certain requests 
The rights described above are not applicable in all situations. Indeed, in accordance with applicable regulations, we may be entitled to refuse certain requests. For each request, we carefully assess whether such an exception applies and inform you accordingly. We may, for example, refuse your request for access if this is necessary to protect the rights and freedoms of other individuals, or refuse to delete your personal information if the processing of such information is necessary to meet legal requirements.

j)      Contact for exercising rights.

If you wish to exercise your rights, please contact us:

By post to : 

Air Inuit Ltd.
Care of Data Protection Officer – Maria Godoy
6005 Côte-Vertu Blvd.
Montréal (Québec) H4S 0B1

By e-mail to the following address 

RPRP-DPO@airinuit.com

 

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