Privacy Policy

Last updated: 28 July 2025.

Welcome to Global Airlines Ltd’s privacy policy.

Global Airlines Ltd (collectively referred to as "we", "us" or "our") is committed to protecting and respecting your privacy. This policy will inform you as to how we look after your personal data when you visit our website (or other applications), interact with our brand, or contact us by any other means. This policy also tells you about your privacy rights and how the law protects you.
So, if you’re looking for more information on how we keep your information safe and how we collect, use, store and share your personal data, this is the right place for you!

1. Important information and who we are

1.1 Purpose of this privacy policy
This privacy policy aims to give you information on how Global Airlines Ltd collects and processes your personal data through your use of our website, applications or when you interact with us by any other means, including when you sign up to our newsletter,make an enquiry to us, take part in a competition or survey or provide us with feedback.

It is important that you read this privacy policy together with any other privacy 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 other notices and is not intended to override them.

We do not knowingly collect personal data directly from children under 16. If you are providing data on behalf of a child for the purpose of our services, you confirm that you have parental or guardianship responsibility and legal authority to share such data.

1.2 Controller
Global Airlines Ltd is the “data controller” for the purposes of data protection legislation. References to Global Airlines Ltd in this policy means Global Airlines Ltd (our UK company) and any company directly or indirectly owned and/or controlled by Global Airlines Ltd that you are interacting with.

We are responsible for your personal information, and, by law, we are required to provide you with information about us, about how and why we use your data and about the rights you have over it.

If you have any questions about this policy or our privacy practices, including any requests to exercise your legal rights, please contact us through the contact details set out below.

1.3 Changes to this privacy policy
We may review this privacy policy from time to time to ensure that the information we provide to you is up to date with any change of legislation and/or new business development and in accordance with the data protection laws. Any new version of this privacy policy will be uploaded on our website and/or applications. The “Last updated” date at the top of this policy will also be adjusted accordingly.

You are advised to review this policy periodically for any changes. Changes to this policy are effective when they are posted on our website and/or other applications.

1.4 Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 Third-party links
This website and/or the applications may include links to third-party websites, plug-ins and applications. 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 our website and/or application, we encourage you to read the privacy policy of every website you visit.

2. The types of personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

Identity Data includes first name, last name and title
Contact Data includes email address
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 the website. This may also include information about your searches and the content you have viewed on our website, page response times, length of visits to certain pages and page interaction information (such as scrolling, clicks and mouse-overs). For instance, we may be able to determine that you visited our website and viewed information about our brand or services but did not complete a form submission. We may use this information to follow up or improve our content.
Profile Data includes details about your travel interests and preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

‘Special category of data’
Certain categories of personal information, such as information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, genetic and biometric information, are special categories of data (also known as sensitive personal data) requiring additional protection under the data protection laws. We do not currently collect or process special categories of personal data. Should we need to collect this data in the future, we will update this policy to reflect any collection and processing of special category data and ensure compliance with applicable data protection laws.

How do we use ‘Aggregated Data’?
We may collect, use, and share Aggregated Data, such as statistical or demographic data, to enhance our market analysis, refine our advertising strategies or support other legitimate business purposes.

Aggregated Data is derived from your personal data but is anonymised, meaning it cannot directly or indirectly identify you and is therefore not considered personal data under applicable law. For example, we might aggregate Usage Data to determine the percentage of users engaging with a specific website feature, helping us optimise user experience. If we combine or link Aggregated Data with your personal data in a way that could identify you, we will treat the combined data as personal data and process it in accordance with this privacy policy.

3. How is your personal data collected?

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

Direct interactions. You may give us your Identity and Contact by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes:
- personal data you provide when you subscribe to our newsletter
- request marketing to be sent to you;
- register for a competition, promotion or survey;
- interact with our social media pages, such as Facebook or Instagram or LinkedIn
- give us feedback or contact us.

Automated technologies or interactions. As you interact with our website or other applications, we will automatically collect Technical Data about your device, 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 our Cookie Policy for further details.
Third parties. This includes Technical Data from analytics and search information providers, such as Google, and advertising networks, such as Google Ads or Microsoft Advertising.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Necessary for the purposes of legitimate interests. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. This may include responding to enquiries from you optimising our website, applications and the overall user experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
Consent. In some circumstances, we may ask for your consent to process your information in a particular way (for example, we will get your consent before sending you direct marketing communications via email or text message, or any third-party marketing. You have the right to withdraw consent to marketing at any time by contacting us).

Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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Purpose/Activity

To enable you to participate in a competition or survey.

Type of data

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

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Purpose/Activity

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

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

(a) 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)

(b) Necessary to comply with a legal obligation

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Purpose/Activity

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

Type of data

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest

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

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Purpose/Activity

To use data analytics to improve our website, services, marketing, customer relationships and experiences

Type of data

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to identify our target customers, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

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Purpose/Activity

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

Type of data

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our services and grow our business, to tailor the contents of the website, applications, emails and other communicants sent to our customers)

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Marketing

When we have your permission, we will send you marketing communications from Global Airlines Ltd.

We will only allow third parties or other members of our group to send marketing communications to you when we have consented to receive your consent to receive marketing from third parties.

We will respect your choice as to what communications you wish to receive and how these are sent.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time. The ways to stop being sent marketing communications are described below:

You can change your marketing preferences at any time in your account area or by e-mailing us using the contact details below;
In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop receiving further marketing emails.

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.

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table ‘purposes for which we will use your personal data’ above.

External Third Parties:

Professional advisers including lawyers, bankers, auditors and insurers based in UK, Europe or the USA who provide consultancy, banking, legal, insurance and accounting services.
Government and/or enforcement authorities based in the United Kingdom.

Business Transfers:

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. In this case we may share and/or transfer customer information, including personal data, in connection with the evaluation of and entry into such transactions and based on our legitimate interest. Also, if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal data may be one of the assets transferred to or acquired by the third party.

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 in accordance with our instructions.

We do not sell your personal data to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.

6. International data transfers

We may share your personal data with third-party service providers located outside the country in which you are based, including outside the United Kingdom (UK) and the European Economic Area (EEA). As a global business, we may need to transfer your personal data internationally to deliver our services or to comply with lawful requests from government or regulatory authorities.

Whenever we transfer your personal data to a country outside the UK or the EEA, we ensure that appropriate safeguards are in place to provide a level of protection that meets the requirements of applicable data protection laws, including those of the UK Information Commissioner’s Office (ICO) and the European Data Protection Board (EDPB). These safeguards include:

Transfers to countries with adequacy decisions: We may transfer your data to countries that have been officially recognized by the European Commission and the UK Secretary of State as providing an adequate level of data protection.
Standard contractual clauses (SCCs): Where adequacy decisions are not in place, we use standard data protection clauses approved by the European Commission and the UK’s Information Commissioner, including the UK Addendum where appropriate, to ensure that your data continues to be protected.
Transfers to the USA: Where we transfer personal data to the United States:
- If the U.S.-based service provider is certified under the EU-U.S. Data Privacy Framework (DPF), including where applicable the UK Extension to the DPF, we rely on that certification as an approved transfer mechanism under UK and EU data protection laws. You can find more information about the DPF here: https://www.dataprivacyframework.gov.
- If the service provider is not certified under the DPF, we will rely on alternative appropriate safeguards, such as the EU Standard Contractual Clauses with the UK Addendum, to ensure that your personal data continues to be protected to the required standard.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

7. 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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

Request access (commonly known as a "data subject access request") – you have the right to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction - you have the right to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.

Request erasure (“right to be forgotten”) - you have the right to ask us to delete or remove the personal data we hold about you from our records. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons – for example, where we are legally obligated to keep the information or if it is impossible or disproportionate for us to erase the data. In this case, we won’t delete it, but we will only keep it for as long as it is needed, and we have time limits on our data systems.

Object to processing – you have the right to object to processing 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 feel such processing 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 - you have the right 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 – you have the right to ask us to transfer the personal data we hold about you, either to you or a third party you have chosen, 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 you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.

Object to automated processing, including profiling – in some circumstances you can ask us not to reach decisions that produce legal or similarly significant effects on you using automated decision-making, including profiling. Note, however, that the use of algorithms or machine learning techniques in ways that don’t have significant privacy implications on you is unlikely to render you with the right to object to such automated processing.

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

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 could 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 could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or our practices, please contact us at cco@globalairlines.com.

You have the right to make a complaint at any time to the ICO, the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.