Privacy policy

General provisions

This document clarifies which personal data Pobeda Airlines LLC (hereinafter referred to as the "Airline") collects regarding its customers and, in certain cases, other persons (hereinafter referred to as “you”, “personal data subjects”), how this data is used, and to whom it is transmitted.

This document is for informational purposes only and is not part of an air carriage contract or any other consumer contract made between you and the Airline. At the same time, the Airline assumes that any person who enters into an air carriage contract or any other consumer contract with the Airline has carefully read this document before making the contract and has agreed with its contents without any reservations.

The Airline is the operator of personal data in the sense of the international law and the applicable Russian law. The full name of the Airline is Pobeda Airlines Limited Liability Company. Address: Kievskoe Shosse 22 km, House 4, Property 1, Moscow, 108811.  The Airline was established in accordance with the law of the Russian Federation, TIN 9705001313, PSRN 5147746103380. Phone: +7 (809) 505-4777, form for applications regarding personal data processing.

Concept of personal data

Personal data refers to any information related to an identified or identifiable individual based on this information. Personal data may include (including, but not limited to the above) surname, first name, patronymic, date of birth, gender, citizenship, type and number of the document, identification document, phone number, e-mail address, other online identifiers (including conditional names in social networks and other web resources), payment information (date and amount of payment, payment method, name of the bank card holder, etc.), information about the contract of carriage (including booking code, time and flight route, additional services, seat on the aircraft).

Sources of personal data

The Airline may receive your personal data:

• through the Airline's website and the Airline’s mobile apps for iOS and Android, for example, when you book a flight, arrange additional services or subscribe to a newsletter;
• when applying the Airline in person (in writing, by e-mail or through the call center);
• from other sources: for example, if you decide to link your social network account to our website, certain information from your social network profile.

In all these cases, personal data may be received by the Airline not only from you personally, but also from third parties, in particular from agents authorized by the Airline, as well as from third parties who act on your behalf or in your interests (for example, from travel agents who are not our partners, or from other persons, who book a flight for you).

Processing of personal data in connection with performance of a contract or presence of a legitimate purpose

In the case of execution and performance of a customer air carriage contract or any other consumer contract, the Airline shall process the personal data of the customer (other consumer), including information about the actual execution of the air carriage contract or any other consumer contract with respect to the corresponding person.

This information shall be used by the Airline, for example, to identify customers and baggage at check-in and when boarding the aircraft, when sending electronic itinerary receipts and other documents, when informing customers about possible changes and delays in the flight schedule provided for by the air carriage contract, etc.

In addition, the Airline may store the above-mentioned personal data in case of a legitimate interest in retaining them. In particular, the Airline may retain information regarding execution and performance of an air carriage contract even after its full execution, since this information is necessary to resolve possible future disputes with the customer or with the Airline's counterparties as well as to control the quality of customer service. The storage period of personal data in these cases, as a rule, may not be less than the maximum possible limitation period for the customer's claims against the Airline arising from the air carriage contract.

In order to conclude and execute an air carriage contract or other consumer contract, the Airline may transfer personal data to third parties involved in the execution of the contract. In particular, the Airline may transmit information about customers of future flights to the operator of the departure airport for the purpose of customer registration and baggage clearance or information about non-arrival of baggage to the operator of the arrival airport and to specialized baggage search systems.

Processing special categories of personal data

The Airline shall process data on the customer’s health status to the extent necessary for execution and performance of an air carriage contract or any other consumer contract and consideration of customer applications related to such contracts, in particular:

• when ordering additional services related to air carriage of customers with disabilities or other restrictions that may affect the normal performance of a contract by the Airline;
• when transporting certain categories of customers, when, in accordance with the current regulation, a certificate or other medical document is required that there are no contraindications to the flight for health reasons or due to pregnancy;
• in cases of injuries and other medical conditions that occurred during air carriage, especially when staying on board the aircraft, including for further payment of insurance compensation;
• when considering applications and claims of customers, including property, when the customer justifies their claim by the presence of a particular medical condition;

In these cases, receiving and processing relevant information regarding your health status is necessary to prevent harm to life and health and the proper execution of an air carriage contract or other consumer contract in connection with which your refusal to provide this information may be one of the reasons for the subsequent refusal to provide you with the relevant service due to the inability to ensure minimum requirements in the field of flight safety or comprehensive consideration of the application.

The Airline may retain these data even after completion of air carriage to the extent necessary to resolve possible future disputes.

The Airline shall not process data regarding the customer's health status, except for the cases specified above.

In case of refusal to make an air carriage contract to the customer or in case of termination of the air carriage contract due to the existence of a corresponding decision taken by the authority of the Russian Federation or another state (in particular, by virtue of paragraph 4 of Article 786 of the Civil Code of the Russian Federation), the Airline reserves the right to retain the relevant information.

In any case, the Airline shall not collect or process information about racial and ethnic origin, political and religious views, membership in professional and other associations, sexual life and sexual orientation as well as biometric information.

Processing of personal data by virtue of the law

Personal data of any personal data subject may be stored, processed and transferred if such an obligation is imposed on the Airline by virtue of the law, other regulatory legal act or a requirement of an authority. For example, in order to comply with the formalities, the Airline may transmit information regarding booking an air ticket in the name of a customer and regarding the flight (indicating the name, date of birth, details of the identity document, and other information) to the competent transport security authorities and border control authorities of the Russian Federation as well as the states of departure, arrival or transit of the customer.

Personal data may also be disclosed at the request of a court and bodies enforcing court decisions, law enforcement agencies, at the request of a lawyer, during the implementation of control and supervisory measures to monitor compliance with the rights of customers and in other cases provided for by the law.

In each such case, specific personal data that is subject to storage, processing or transfer shall be determined by the applicable law of the Russian Federation as the State in which the Airline's activities are licensed, the states of departure, arrival or transit of the customer and other states.

Processing of personal data subject to your consent

By making an air carriage contract with the Airline, or by using the tools for managing the services of Pobeda Airlines on the website www.pobeda.aero or in the mobile application of Pobeda Airlines on the iOS and Android platforms (for example, by making appropriate entries in registration forms, but not limited to this), in accordance with Article 9 of Federal Law on Personal Data No. 152-ФЗ dated 27.07.2006, it is assumed that you have provided the Pobeda Airline Limited Liability Company (PSRN 5147746103380, license No. ПП 0377 of the Federal Air Transport Agency dated 01.10.2015) and its authorized representatives your explicit consent to processing your personal data as well as any other data related to the identity of the customer, for any action (operation) or set of actions (operations) to be performed with personal data, including (without limitation) collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), cross-border transfer (the USA, the UK, as well as the customer's destination states), depersonalization, blocking, deletion, destruction as well as the implementation of any other actions provided for by the current law of the Russian Federation, using automation tools, including in information and telecommunication networks or without use of such tools as well as consent to sending e-mails and informational messages to the customer to the e-mail address and/or mobile phone number specified by the customer, including sending information about the activities carried out by Pobeda Airline and its partners promotions and messages of other informational nature as well as use the email address specified by the customer to display targeted advertising and informational messages.

The Airline may use your personal data for the purpose of providing or promoting the Airline's products and services. For this purpose, the Airline may transfer some of the information containing your personal data to its strategic partners. This allows you to keep up to date with news about sales, to inform about the opening of new flight destinations and upcoming events.

For example, when you subscribe to Airline newsletters, it assumes that you have allowed the Airline to transmit information about the Airline's services to you. This information may be combined with other information in order to provide and improve our services and for advertising purposes, including targeted advertising. If you want to unsubscribe from newsletters, you can do this at any time by changing the appropriate settings in the "Personal Account", clicking on the "Unsubscribe" link in the email or by informing us via the feedback form. The consent or refusal of newsletters does not affect the sending of official messages carried out in connection with the conclusion and execution of an air carriage contract (for example, messages with itinerary receipts or flight status information).

The Airline may also use your personal data to conduct marketing, sociological and other similar studies, in particular when conducting surveys of Airline customers and when studying the structure of consumer demand.

The use of personal data for all purposes specified in this section is allowed, unless you have indicated the opposite when providing personal data and have not expressed your disagreement with the use of your personal data for these purposes subsequently.

Consideration of applications

You may contact the Airline to:

• get information about your personal data stored by the Airline, for example, get information about what personal data is stored by the Airline or get a copy of your personal data;
• make corrections to your personal data if it does not correspond to reality. However, correction of personal data shall not automatically change the terms of the current air carriage contract;
• revoke your consent to storage and/or processing of your personal data in cases where such consent has been given, and storage and/or processing of personal data depend on the availability of such consent.

The Airline commends to your attention the fact that deletion of your personal data is impossible if their availability is necessary for the performance of an air carriage contract or other consumer contract, if the Airline has a legitimate purpose to retain your personal data, and if the Airline stores personal data by virtue of the law.

As a rule, the application shall be sent in a hard copy by post to the mailing address of the Airline (in some cases, in particular, other methods that are specifically mentioned in this document may be used to refuse newsletters). The Airline shall consider applications if the application form and the information contained in it allow you to uniquely identify you and exclude "identity theft". The term of consideration of the application shall be one month from the date of receipt of the application by the Airline. The application shall be signed either by the person whose personal data this application concerns or by their legal representative (parent, guardian — in the case of minority or incapacity) or by a person acting on behalf of these persons. In the latter two cases, it is mandatory to attach to the application a document confirming the authority of the person sending the application (for example, a birth certificate or a notarized power of attorney or their copies certified by a notary). The Airline commends to your attention the fact that the originals of the application and any documents received with the application are not returned.

As a general rule, applications shall be considered free of charge. At the same time, in the case of obviously unjustified applications as well as applications for which a response has already been given, the Airline may charge a fee for processing such an application or refuse to consider such an application on the merits.

In some cases, specifically provided for by the legal acts of the Russian Federation or foreign states, a fee for making changes to personal data may be charged directly by virtue of these norms.

Сollecting information on the Airline's information resources

When you visit the Airline's website or use a mobile application, the Airline may collect information about how you use these information resources using cookies and server log files. Collection of this information is conditional upon the technological features of the work of these information resources are transient (temporary) in nature and are not aimed at collecting personal information exclusively about you.

Personal data protection

As part of the protection of personal data, the Airline’s measures aimed at preventing their accidental or unauthorized destruction or accidental loss as well as preventing unauthorized access, modification or dissemination of personal data.

When accessing the Airline's website, the HTTPS protocol is used by default, which ensures data protection. We do not recommend using the HTTP protocol when using the Airline’s website. The Airline is only responsible for the operation of the website www.pobeda.aero and is not responsible for the processing of personal data by the owners of third-party websites, even if a link from the Airline's website leads to such a site.

In order to prevent any unauthorized access to your personal data, it is strongly recommended not to disclose to unauthorized persons the account information for access to the Airline’s information resources (for example, the login and password of the account on the website) as well as the identifiers of a particular trip, including the booking code (a combination of six Latin letters and numbers), the ticket number and the specified information should be provided only when interacting with the Airline.

Data protection officer

If you have any questions regarding the processing of your personal data, you may contact our data protection officer who will be available in case of a request for information, suggestions, questions or complaints: dpo@pobeda.aero.

Provision of personal data by third parties

In all cases of receiving personal data, the Airline shall assume that this data is entered either by the person themself, or by their legal representative (parent, guardian) or by a third person on behalf and with the consent of these persons. For example, when booking a person's ticket on the Airline's website or through a mobile application, it shall be assumed that the person making this booking and, accordingly, entering the customer's personal data on the ticket is:

• the customer themself, who is of full legal age and legally capable; or
• the legal representative (parent, guardian) of a minor or incapacitated customer; or
• a person who has legally obtained the explicit consent of these persons to transfer their personal data to the Airline during the booking of the ticket.

If you find that your personal data has been transferred to the Airline without your consent or against your will, you should immediately contact the Airline, using the methods specified in the section "Consideration of Applications" to prevent unauthorized use of your data.