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Our Policies

data protection & privacy policy

1. INTRODUCTION

1.1. Elin Air is committed to offering its customers a unique travel experience, all while
respecting their right to privacy. Our privacy policy is designed to give you a better
understanding of how we use your Personal Data that you share with us through this
website, what safeguards we have in place, and how you can exercise your rights.

1.2. For purposes of this Privacy Policy, the term Personal Data shall mean any information
relating to an identified or identifiable natural person (‘data subject’); an identifiable
natural person is one who can be identified, directly or indirectly, in particular 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 the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person; It can be anything
from a name, address, a photo, an email address, bank details, posts on social networking
websites, medical information, and other unique identifier such as but not limited to MAC
address, IP address, IMEI number, IMSI number, SIM and others

1.3. This Privacy Policy explains that Elin Air & Aviation Services Limited (hereinafter referred
to as, ‘we’, ‘us’ or ‘the Company’) may collect, use, share, safeguard and/or otherwise
process information (including Personal Data) provided through this website.

1.4. As from the effective date of this Privacy Policy, any existing Personal Data already held
by us shall be deemed to have been legally collected and processed unless you, as the data
subject, requests for the correction or deletion of any part of your information held.

2.1. We may collect Personal Data directly from you in the course of your use of this website
or your interaction with us through this website, except for instances where the law
permits us to collect your Personal Data from other sources.

2.2. We may also collect Personal Data directly from you through your subscriptions to any
service provided by the firm.

2.3. We may also collect other Personal Data in the course of providing services to you.
2.4. Some of the Personal Data that may be collected from your interaction with us from this
website include your name, business contact details, job title or position and your
expertise and interests.

2.5. If necessary, we may collect other Personal Data – for example, your financial information.

2.6. We collect Personal Data when we (or propose to) deal with, or provide or market our
services to you as a client. In accordance with our legal obligations, we inform you of the
following:
(a) the fact that we are collecting your Personal Data from you;
(b) the purpose for which we intend to collect your Personal Data including why we
are collecting your Personal Data and how we plan to use it (see section 3 below);
(c) the third parties to whom your personal data will be shared or transferred,
including details of safeguards adopted (see sections 4 and 5 below);
(d) a description of the technical and organizational security measures taken to ensure
the integrity and confidentiality of the data (see section 5 below);
(e) your rights as the subject of the Personal Data which we collect from you (see
section 6 below);
(f) the contacts of the data controller or data processor who will handle your Personal
Data (see section 7 below);
(g) whether the data is being collected pursuant to any law and whether such collection
is voluntary or mandatory (see paragraph (k) below); and
(h) the consequences where the data subject fails to provide all or any part of the
requested data (see paragraph (n) below).

2.7. If you apply for a job with us we may collect certain Personal Data from you, such as your
name and contact details and information about your working history. We may also collect
your Personal Data from relevant records checks, from any recruitment consultant and
from your previous employers, universities and others who may be able to provide
information to us to assist us in our decision on whether or not to make you an offer of
employment. As part of the job application process and in every other instance where we
intend to collect your Personal Data from other sources besides you, we will, in so far as
practicable, notify you of the fact that we intend to collect such Personal Data. In instances
where you apply for any employment position with us, you agree that by so doing, you are
validly consenting to our collection of your relevant Personal Data from other sources for
purposes of evaluating your application.

2.8. Should we ever collect your Personal Data from sources other than you, in any other
context besides where you have applied for employment with us, we will, in so far as it is
practicable, notify you before we collect such Personal Data from such other sources.

2.9. We generally only collect Personal Data from this website when it is provided voluntarily
by you.

2.10. If the Personal Data is intended to be collected pursuant to any law or where the collection
of such Personal Data is mandatorily required, we will notify you of this directly prior to
collecting such data.

2.11. We use cookies on our website and as such, we also obtain Personal Data from your IP
address, operating system and web browser that you use to access our website.

2.12. When you visit our website, our server will record your IP address together with the date,
time and duration of your visit. An IP address is an assigned number, similar to a
telephone number, which allows your computer to communicate over the Internet. It
enables us to identify which organizations have visited this website. We use this
information to compile statistical data on the use of our website to track how users
navigate through our site to enable us to evaluate and improve our site.

2.13. Please note that the provision of your Personal Data to us may be necessary for enabling
the use or functioning of certain features of this website or the provision of certain services
through this website. To that extent, any such features or services may not be functional
or available for use or capable of being used in the absence of the provision of your
Personal Data.

We may use your Personal Data in a variety of ways once collected including, but not
limited to:
(a) responding to your emails or online requests for products, services or
information;
(b) providing you with service communications such as bill reminders, order
confirmations, programme registrations and client service messages;
(c) fulfilling and/or delivering our products and services;
(d) delivering and processing surveys;
(e) personalizing and improving the usability of this website;
(f) tailoring content, advertising and marketing to you; and
(g) sharing your Personal Data with certain third parties so as to fulfil any express
service requests which you make to us. We may also share such information with
service providers that perform business functions for us.

4.1. We may on occasion be required to share your information with our other offices and any
third parties, who provide services on our behalf. In relation to any such disclosure of your
Personal Data, we will notify you of this as soon as reasonably practicable and shall only
disclose your Personal Data where you have given your consent or where we are required
or otherwise permitted to do so by any applicable law, or where it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights.

4.2. We may also share e-mail addresses with third parties as necessary for them to perform
ertain services on our behalf, such as packaging, mailing and delivering products to you
and processing event registrations and responding to your service requests.

4.3. Some of your Personal Data may be stored in a cloud or server located within or outside
Nigeria and managed by a third-party service provider. Where we transfer your Personal
Data outside Nigeria, this shall be solely for purposes of ensuring the safety of such
Personal Data and for purposes of ensuring operational efficiency. In addition to this, we
will take reasonable steps to ensure that your Personal Data is treated securely and that
the means of transfer provides adequate safeguards.

5.1. We use up-to-date data storage and security systems to hold your Personal Data securely
in electronic and physical form to protect your personal information from unauthorized
access, improper use or disclosure, unauthorized modification or unlawful destruction or
accidental loss. Our IT usage and security policy is supported by various security
standards, processes and procedures such as automated backups to cloud using google
cloud app, secure file sharing to authorized personnel, weekly updating of antimalware
against malware and unauthorized access, centralized computer management using
Microsoft Intune.

5.2. We implement commercially reasonable security measures to help protect against
unauthorized access to or unauthorized alteration, disclosure, or destruction of data.
Unfortunately, no data transmission over the Internet can be guaranteed to be one
hundred (100) percent secure. Accordingly, and despite our efforts, we cannot guarantee
or warrant the security of any information you transmit to us, or to or from our online
products or services.

5.3. All persons who have access to confidential information (including Personal Data) that we
hold, including our partners, staff and third-party service providers are subject to
confidentiality obligations.

6.1. You have certain rights that you can exercise in relation to any of your Personal Data that
we process. These are:
(a) the right to be informed of the use to which your Personal Data is to be put;
(b) the right to object to the processing of all or part of your Personal Data;
(c) the right to access your Personal Data;
(d) the right to the correction of any false or misleading parts of your Personal Data;
(e) the right to the deletion any false or misleading parts of your Personal Data.
(f) the right to data portability, which is the right to receive your Personal Data in a
structured, commonly used and machine-readable format and to transmit it from
us to another data controller or data processor without hindrance;
(g) the right not to be subjected to a decision based solely on automated processing
which produces legal effects that concern or significantly affect you;
(h) the right to the rectification of any inaccurate, outdated, incomplete or misleading
portions or parts of your Personal Data; and
(i) the right to the erasure or destruction of any portions or parts of your Personal
Data that are irrelevant, excessive, unlawfully obtained or that we are no longer
authorized to retain.

6.2. In the limited circumstances where you may have provided your consent to the collection,
processing and transfer of your Personal Data for a specific purpose, you have the right to
withdraw your consent for that specific purpose at any time. Once we receive notification
that you withdraw your consent, we will no longer process your information for the
purpose or purposes you originally agreed to, unless we have another legitimate basis for
doing so in law.

6.3. If you would like to exercise any of these rights, please contact us in writing by emailing info@flyelinair.com or by letter to No. 23 Ogidi Crescent, Admiralty Way, Lekki Phase 1, Lagos State, Nigeria.

7.1. If you would like more information concerning this privacy policy and how it affects you, please contact our data privacy officer at the email address info@flyelinair.com

7.2. Address: No. 23 Ogidi Crescent, Admiralty Way, Lekki Phase 1, Lagos State, Nigeria.

This version is applicable as from

May 1, 2026

We reserve the right to change this Policy from time to time. All changes are published on
our website. We invite you to read it regularly, especially when you book new flights with
our company.