Introduction
Ryanair is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
All personal data is collected and processed in accordance with Irish and EU data protection laws.
Data Controller
“Ryanair” (referred to as “we”, “us”, “our” or “Ryanair” in this policy) in this policy primarily refers to Ryanair D.A.C., the main operating company of the Ryanair group, and, where appropriate, to other companies in the Ryanair group or other entities over which Ryanair exercises management control, including Ryanair Sun S.A. Ryanair D.A.C. is the “data controller” of all personal information that is collected and used about Ryanair customers for the purposes of [the Irish Data Protection Act 2018]. Ryanair is registered in Ireland with registration number 104547 and registered offices at Ryanair Dublin Office, Airside Business Park, Swords, Co. Dublin.
We may engage third parties to provide services on our behalf. If you book a service offered by a third party (eg travel insurance, car hire, room booking) the third party will be identified in the applicable booking terms and conditions. The third party will be a “data controller” of your personal data in respect of the service they are providing. You should access the privacy policies/statements of those providers directly
What personal data we collect
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, booking reference number, payment details and information about your access and use of our website.
We may collect personal data from you when you book a flight with us (either directly or indirectly through our trusted third party partners), create a MyRyanair account, use our website and / or App and other websites accessible through our website and / or App, participate in a survey or competition, or when you contact us.
Specifically, we may collect the following categories of information:
- Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, credit/debit card or other payment details;
- Advance Passenger Information, which includes your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;
- Medical conditions for passengers who have special medical requirements and/or dietary requirements;
- Travel history, including information related to your flights and services/travel products booked in connection with your flights (e.g. if you purchase allocated seats or additional luggage);
- Information you provide about your and your companions’ travel preferences in your MyRyanair account;
- Information about your purchases of our trusted partners’ products and services;
- Information about your use of our website and/or App;
- The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
- Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the Location Services settings on your device and computer.
Special Categories of personal data
Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “special categories of personal data “under the GDPR and applicable data protection laws. We will only process such data where you have given your explicit consent, for example where you request special assistance before or during a flight, we will need to provide this information to the staff or our service providers of those airports to and from which you will be flying so they can provide the assistance you have requested or where it is necessary to protect your vital interests or those of other people (for instance if you request special assistance), or you have deliberately made it public.
When you have a specific medical condition, you need to inform us of that and in some instances provide us with a medical certificate. This is for your safety. Our General Terms & Conditions of Carriage provide more detail on what medical information you need to disclose to us.
What do we use your personal data for, why and for how long
Your data may be used for the following purposes:
- Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your flight, including requested flight changes;
- Contacting you in the event of a flight time change or cancellation: we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
- Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
- Administrative or legal purposes: we use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. Any profiling activity will be carried out with your prior consent only and by making best endeavours to ensure that all data it is based on is accurate. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
- Immigration/customs control safety: we may be obliged to provide your information to border control agencies;
- Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
- Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us. We may contact you for feedback in order that we can improve our services and experiences for customers;
h. Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your travel with us and to personalise the services we offer to you, such as special offers to your favourite destinations or Family Plus deals; - Marketing: from time to time we and our partner airline Laudamotion will contact you with information regarding flight promotions and ancillary products via e-mail, sms, push notifications, phone and / or post.
You will have the choice to opt in or opt out of receiving such marketing communications by indicating your choice on the payment page when booking your flight or by updating your app settings. You will also be given the opportunity at the bottom of every marketing e-mail to unsubscribe / opt out. See also Section 11 below on your data subject rights.
To opt out of SMS, please follow the instructions in the SMS message you receive.
To opt out of phone or post, please advise our call agents during the phone call or submit a request for opt-out through Ryanair’s dedicated web-form, available here.
To unsubscribe from push notifications you must update your App settings. Push notifications are set out in the initial permissions when downloading an app and vary depending on whether you have an IOS or android device. You should check the settings and permissions on your device in relation to push notifications and change your settings according to your preferences.
We aim to action opt out requests as quickly as we can but it is possible you will receive some marketing communications in the period prior to the change being made.
Please note that if you opt out of marketing communications you will still receive service communications in relation to existing bookings. See b. above.
GDPR and applicable data protection laws allow us to process your personal data where we have the legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases we will need to process your personal data so we can process your booking, enter into our contract of carriage and perform that contract with you.
We may also process your personal data for one or more of the following:
- To comply with a legal obligation (e.g. Immigration or customs requirements);
- You have consented to us using your personal data (e.g. for marketing related uses);
- To protect your vital interests or those of another person (e.g. in case of a medical emergency);
- It is in our legitimate interests in operating as an airline (e.g. for administrative purposes).
Only children aged 16 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required.
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations (e.g. in relation to claims for cancelled flights under EU Regulation 261/2004) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made. For retention of information on your myRyanair account, please see the below section about myRyanair.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
All payment details are transmitted over SSL across dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Irish and EU law on data protection rules.
International Data Transfer
Ryanair operates businesses in multiple jurisdictions, some of which are not located in the European Economic Area (EEA), such as Israel, Morocco, Jordan and USA. While countries outside the EEA do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with Irish and EU law on data protection. We utilise standard means under EU law to legitimise data transfers outside the EEA.
Sharing your personal data
Your personal data may be shared with other companies within the Ryanair Group.
We may also share your personal data with the following third parties for the purpose described in this Privacy Policy:
- Government authorities, law enforcement bodies, regulators and airports in your itinerary or to which your flight may fly over for compliance with legal requirements;
- Trusted GDS (Global Distribution System) agents through which you book your Ryanair flight;
- Partner airlines required to deliver the services you have asked for, such as Air Europa;
- Trusted service providers we are using to run our business such as ground handling agents assisting our passengers at airports in all countries we operate in, call centres and flight connection service providers providing assistance to our customers, cloud service and e-mail marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns;
- Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment and flight booking to process payment or ensure the security of your payment transaction;
- Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation to our contract with you;
- Our trusted third party ancillary partners (identified on our website) who offer travel related products and services on our website: If you choose to purchase products or services offered on our websites by third parties such as Cartrawler or Europ Assistance Travel Insurance, you may be a customer of both Ryanair and these third parties, and we and our partners may collect and share information about you, such as your contact details and your billing information. We are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes. Please consult their privacy policies for further information.
- Social media:You may be able to access third party social media services through our website or App or before coming to our website or App. When you are registered with your social service account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our website or App. We may also use social media plugins on our website or App. As a result your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.
Our website contains links to other websites. Once you use those links and leave our website, we do not have any control over that other website. We are not responsible for the protection and privacy of any data which you provide whilst visiting these other websites. They are governed by their own privacy statements.
myRyanair section
All data collected upon registration in the myRyanair section will be processed in line with this Privacy Policy.
We understand the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, children under 16 will not be permitted to open a myRyanair account. We will delete any myRyanair account created by a child under 16, as soon as we are made aware of it.
You will have the option to stay signed-in into your myRyanair account by checking the “keep me logged in” box. This option will only apply to the computer / device and the browser that you’re using when you select the box. If you do not wish to stay signed on a particular browser, simply sign out of myRyanair on that browser.
When our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time. You can do this by submitting your request through our dedicated web-form (see Section on Your data protection rights).
We will delete any information of a travel companion collected without the companion’s consent, as soon as we become aware of it.
We keep your personal information contained in your myRyanair account for as long as you hold the account. You can change the personal data in your myRyanair account directly in the account. Any changes made by you will only show in bookings made after these changes have been made and not in existing bookings.
Please note that general retention periods apply to any personal data we collect to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.
Cookies and site tracking
This site uses cookies to enable us to improve our service to you and to provide certain features that you may find useful (see Ryanair’s Cookie Policy). This may include cookies of media and advertising partners that are being placed on your machine when visiting our website or App. Please visit our partners’ websites for information on their privacy and cookie policy.
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your reservation. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org.
We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal passenger information.
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. In addition, you always have the right to make a complaint at any time to a supervisory authority. The Irish Data Protection Commissioner is our lead data protection supervisory authority for Ryanair.
Your Data Protection Rights
The GDPR and other data protection laws give you specific rights in relation to your personal information. Details of these rights and how to exercise them are set out below.
DATA RIGHTS
Your rights include the following:
- Opt out/Unsubscribe. You can request to be removed from our marketing mailing list by filling in the form. This requires verification of your email address. Please follow the instructions provided through the link. See also point 4. i above.
Please note that if you opt out of marketing communications you will still receive service communications in relation to existing bookings. See 5 b. above. These can include information about the services you may be using (e.g. seat reservation, checked baggage etc.).
- Request for erasure of your personal information (right to be forgotten). You may ask us to delete or remove personal data, where we have no legal basis to continue to process it. This includes deletion of the MyRyanair account linked to the email address provided and/or used in booking a flight. However, we will retain the personal data that relates to a contract between you and Ryanair (flight booking) to perform the contract, defend or pursue our legal rights and meet our obligations towards regulatory or governmental authorities.
You can request erasure by filling in the form. This requires verification of your email address. Please follow the instructions provided through the link.
Please note we will make every effort to erase data where this right has been exercised by you and we no longer have a legal basis for processing same but some personal data sets are impossible (or infeasible) to edit or remove (eg. server backup or microfiche).
- Object to processing. You have the right to object to the use of your data for direct marketing purposes at any time through this form. This will remove you from our marketing databases. It requires verification of your email address. Please follow the instructions provided through the link.
You may also request us to stop processing your personal data where we are doing so based on legitimate interests (e.g. target you with personalized offers in the booking process) unless we require your data for dealing with legal claims or we have compelling legitimate grounds which override your rights. If this is the basis for your objection, then fill in our online request form and set out in the comment area your basis for objection.
- Request information. Section 3 above sets out what personal data we collect and Section 4 sets out the reasons we collect it.
- Request access to the personal data we hold about you. If you have a MyRyanair account you can view the personal data held in this account by logging into your account. If you wish to access other personal data we hold about you other than what is in your MyRyanair account, then you can use our webform. You will need to provide a copy of your photo ID, either passport or national ID, when making your request so we can verify your identity. We may not be able to provide you access to the data when it involves information relating to others who have not consented to the disclosure of their information. We will also have to verify your email address before we can send the data to the email address provided in the request.
- Request correction of the personal information that we hold about you. This can be done by you through your MyRyanair account. We have added new tools in your MyRyanair account, allowing you to directly change personal data you have provided there.
Please note that if you require changes in active bookings you need to contact Customer Services directly, as set out in our General Terms and Conditions of Carriage and FAQs.
- Object to automated decision-making including profiling, which produce a legal effect or similarly significant effects. We do use personal data to personalize the services and offers you receive, however we do not engage in automated processing with legal or similarly significant effects.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, but only in limited circumstances, which you must set out in the comment section of our webform. Open webform
- Request portability of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format. Open webform
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. In relation to marketing communications, this can be done as set out above under opt out/unsubscribe. In your MyRyanair account this can be done through your account by using the delete buttons provided where consent is the basis for our processing. Once we have received notification that you have withdrawn 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.
- Third parties. If you are applying on behalf of another person then we require a signed letter of authority from the data subject provided in this document. If you are applying as a parent/guardian of children then we require the signed letter of authority provided in this document. In addition to the other requirements set out below, we will also verify the email of the data subject before processing such requests. If you wish to make a request on behalf of someone else, please use our third party webform, which allows for attachment of 1) required documents to allow us to validate the identity of the data subject and 2) the above signed letter of authority from the person making the request on behalf of a data subject.
This policy should help you to better understand how we use your personal information, it explains in detail the types of personal information we collect, what we use it for and who we may share it with. If you have any further questions about this policy or how we handle your personal information, which are not dealt with here or through our webform or through your MyRyanair account, please get in touch with us by writing to our Data Protection Officer at Ryanair Head Office, Airside Business Park, Swords, County Dublin, Ireland (or DPO@ryanair.com).
These requests cannot be processed if made via email, due to their volume and the need to verify your identity before we can act on your request. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Changes to Privacy Policy
Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on our website.