Flair Cargo is the dedicated air-freight division of Flair Airlines Ltd. ("Flair", "Flair Cargo", "we", "us", or "our"). This policy explains how we collect, use, disclose, and protect personal information when you use the Flair Cargo website and related digital properties (the "Flair Cargo Site") or otherwise deal with us as a customer, shipper, consignee, freight forwarder, customs broker, or account holder. Flair Cargo transports shipments, not passengers, and this policy is written accordingly.
The Flair Cargo Site is hosted and operated on Flair's behalf by a third-party technology provider. Flair remains accountable for personal information handled on its behalf, and requires that provider and its other service providers to maintain safeguards equivalent to those Flair applies, as described below.
General
We have designed this policy to meet or exceed the requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL); and, where applicable, Quebec's private-sector privacy legislation ("Law 25") and the privacy laws of U.S. states. Much of the information we handle relates to businesses and to individuals acting in a business capacity; where information identifies an individual, we protect it in accordance with this policy and applicable law.
We reserve the right to update or revise this policy from time to time. Where required by law, we will give notice of material changes, and any revised policy will bear a new effective date.
Our Commitment and Accountability
We maintain internal policies and procedures designed to protect personal information, limit access to those who need it, train our personnel, and bind them by confidentiality obligations. Flair has designated a Privacy Officer responsible for compliance with this policy and applicable law and for responding to your requests. The Flair Cargo Site is hosted and operated on Flair's behalf by a third-party technology provider, and we use other service providers to deliver our services. That provider and our other service providers are contractually required to protect personal information using administrative, technical, and physical safeguards equivalent to those Flair applies; to process personal information only for the purposes we authorize, under our direction; and to comply with applicable privacy law.
Scope and Third-Party Sites
Unless we tell you otherwise at the time of collection, this policy applies to all personal information we collect when you deal with Flair Cargo. The Flair Cargo Site may contain links to third-party websites (for example, customs, tracking, or partner-carrier systems), which are governed by their own privacy policies.
Personal Information We Collect
Depending on how you interact with us, we may collect:
- Identification and business-contact information: the name, job title, employer, business address, email address, and telephone number of shippers, consignees, freight forwarders, customs brokers, account holders, and their authorized representatives;
- Account information: log-in credentials, account numbers, and credit-application and billing details;
- Payment information: payment-card or bank details, billing address, and transaction history (processed by our payment processor);
- Shipment information: air waybill and booking details, commodity descriptions, weights and dimensions, origin and destination, routing, special-handling requirements, and dangerous-goods or other regulatory declarations;
- Government and regulatory information: information we are required to collect or share with customs, border, security, and transportation authorities (including the Canada Border Services Agency, Transport Canada, and U.S. authorities), and information relating to security screening and known-shipper or regulated-agent status;
- Digital and technical information: IP address, device identifiers, browser type, and website-usage data collected through cookies and similar technologies; and
- Communications: records of your correspondence and interactions with us, including customer-service and claims communications.
Purposes for Collecting Personal Information
We may use personal information for purposes reasonably necessary to provide our air-freight services, and for related purposes, including to:
- To set up and manage accounts, and process, book, document, and manage shipments, payments, and air waybills;
- To coordinate with the parties involved in carriage, including interline and partner carriers, ground handlers, customs brokers, and screening and security providers;
- To comply with customs, border, security, dangerous-goods, export-control, sanctions, and other legal and regulatory requirements of Canadian, U.S., and international authorities;
- To prevent, detect, and investigate fraud;
- To provide tracking updates, respond to inquiries, and handle claims;
- To send commercial electronic communications where consent has been provided, each of which includes a functioning unsubscribe mechanism;
- To analyze and improve our services, website, and operations; and
- To protect the safety and security of our operations and personnel, and meet our legal obligations.
Consent
We collect, use, and disclose personal information with knowledge and consent, except where otherwise permitted or required by law. You may withdraw consent at any time, subject to legal and contractual restrictions, by contacting our Privacy Officer, who will explain the consequences. Certain information must be collected, retained, or disclosed regardless of consent to meet customs, security, or other legal requirements.
Disclosure of Personal Information to Third Parties
We do not sell personal information. We may disclose it in the following or similar circumstances:
- Service providers: the provider that hosts and operates the Flair Cargo Site, and our other service providers (such as IT and cloud providers and payment processors), which process personal information only on our behalf and under equivalent safeguards;
- Carriage and logistics partners: interline and partner carriers (if applicable), ground handlers, customs brokers, and screening providers involved in transporting and clearing your shipment;
- Government and regulatory authorities: customs, border, security, and transportation authorities where required by law or regulation, which in some cases may occur without consent as permitted by law;
- Legal proceedings: in response to valid legal process or where reasonably necessary to protect rights, property, or safety; and
- Corporate transactions: in connection with a merger, acquisition, financing, or sale of assets, subject to equivalent privacy protections.
Cross-Border Use of Personal Information
Air freight is international by nature. Personal information may be transferred to, stored in, or accessed from destinations outside your province or country, including outside Canada, to carry and clear shipments and operate our business. We use contractual and other means to ensure comparable protection. While in another jurisdiction, personal information may be accessible to the courts, law enforcement, and other authorities of that jurisdiction under its domestic law.
Security Safeguards
We use physical, technological, and administrative safeguards to protect personal information against loss, theft, and unauthorized access, disclosure, use, or modification, including controlled premises access, encryption (including TLS for information transmitted through the Flair Cargo Site), access controls, training, audits, and confidentiality obligations. As noted above, our service providers are contractually required to maintain equivalent safeguards.
Retention
We retain personal information only as long as necessary to fulfil the purposes for which it was collected and to meet legal, regulatory, customs, accounting, and tax obligations. Shipment, customs, and transaction records are generally retained for a minimum of seven (7) years, or longer where a law or authority requires. When no longer required, personal information is securely destroyed or anonymized.
Your Privacy Rights
Subject to applicable law, you may access the personal information we hold about you and ask how it is used; request correction of inaccurate, incomplete, or out-of-date information; withdraw consent, subject to legal and contractual restrictions; request data portability where applicable law provides that right; and make a complaint to our Privacy Officer and, if unsatisfied, to the appropriate regulatory authority.
How to Contact Us
To exercise your rights or ask questions about this policy, contact our Privacy Officer:
Attention: Privacy Officer, Flair Cargo (Flair Airlines Ltd.)
Email: privacy@flyflair.com
Mailing Address: 6543 – 1000 Airport Road, Edmonton International Airport, Leduc, Alberta, T9E 0V3
This Privacy Policy is effective as of the date shown above and may be updated from time to time, in which case the posted policy will bear a new effective date.