5. PURPOSES AND LEGAL BASES FOR COLLECTING AND PROCESSING YOUR PERSONAL DATA

5.1 We process your personal data solely for the purpose for which it was collected, which may be based on several legal grounds, as outlined below:

Purpose for Processing	Category of Personal Data	Legal Basis
To process and manage your booking and travel with us, including payment, ticketing, check-in, and in-flight services	Identity Data, Contact Data, Booking and Itinerary Data, Payment Data	Performance of a contract; Legal obligation
To register and manage your participation in the SFEER loyalty program, including account creation, profile updates and redemption of benefits	Identity Data, Contact Data, Profile Data	Performance of a contract; Legitimate interest – to manage account and administer loyalty benefits
To respond to and resolve your queries, complaints, and feedback about our Services or products	Identity Data, Contact Data, Communication Data	Legitimate interest – to manage and improve customer support
To enable your participation in promotional campaigns, contests, and competitions through our Platforms	Social Media Data, Contact Data, Profile Data	Consent; Legitimate interest – to run promotions and contests
To facilitate access to lounges and flight-related premium services, including identity verification and access control	Booking and Itinerary Data, Identity Data, Profile Data	Performance of a contract; Legitimate interest – to offer premium Services
To manage and facilitate air cargo Services, including shipment processing, payment, and customs clearance	Cargo Data, Payment Data Consignor/consignee data, cargo details, payment data	Performance of a contract; Legal obligation
To provide appropriate support in emergency situations, including medical attention or notification of emergency contacts	Health Data, Emergency Contact Data	Vital interests; Legal obligation
To collect and analyze information from cookies and similar technologies to enhance functionality, performance, and user experience across our digital platforms	Device and Location Data, Technical Data, Usage Data	Consent (where required); Legitimate interest – to enhance user experience
To collect and enrich your profile with data from third-party platforms for a more personalized experience	Identity Data, Social Media Data, Marketing and Communication Preferences	Consent; Legitimate interest – to supplement customer profile
To manage our interactions with you across channels, including preferences, Service history, and communications	Contact Data, Communication Data, Profile Data	Legitimate interest – to manage and maintain customer relationships
To send marketing communications and measure engagement, based on your stated preferences and behaviours	Marketing and Communication Preferences, Usage Data	Consent
To use biometric information for identity verification and access facilitation, such as during boarding or entry to secure areas	Biometric Data	Consent; Legal obligation (if required by law)
To investigate, manage and resolve legal claims or disputes involving you or third parties	Identity Data, Communication Data, Security and Safety Data	Legitimate interest; Legal obligation
To comply with legal, regulatory and governmental requirements, including aviation, customs, tax, and safety obligations	Identity Data, Travel Document and Entry Data, Government and Regulatory Data	Legal obligation
To arrange and deliver special assistance you request, including mobility aid, medical support, or other accommodations	Health Data, Travel Preferences	Consent

5.2 To the extent permitted by applicable law, we may anonymise, aggregate or otherwise de-identify your personal data to generate statistical, analytical, or industrial insights (“Aggregated Data”). This Aggregated Data may be used by us or shared with third parties for purposes such as improving our services, conducting research, or supporting marketing and business development activities.

5.3 Aggregated Data is derived from your personal data but is not considered personal data under applicable law if it does not directly or indirectly identity you. If we combine or connect Aggregated Data with your personal data in a way that could identify you, we will treat the combined data as personal data and handle it in accordance with this Privacy Policy.