Freedom Airline Privacy Policy
Last updated: 08/10/2025
1. Who we are
Freedom Airline ("Freedom Air," "we," "our," "us") operates scheduled and charter passenger flights and related services.
2. Scope
This Policy explains how we collect, use, disclose, retain and protect Personal Data when you:
- Book or fly with us
- Use freedomairexpress.com, our mobile app, kiosks, onboard Wi-Fi or social-media pages
- Enrol in Freedom Miles (our loyalty programme)
- Contact our call-centre or airport staff
- Receive marketing or employment services from us
By using any of the above you acknowledge you have read and understood this Policy.
3. What we mean by "Personal Data"
Any information relating to an identified or identifiable individual, including:
- Identity data – name, title, gender, date of birth, passport or ID numbers, government redress or Known Traveller numbers, photographs, CCTV images
- Contact data – postal address, email, phone, social-media handles
- Reservation data – PNR, ticket number, seat, meal or accessibility requests, baggage details, upgrades, companions
- Payment data – credit-card number (tokenised), billing address, transaction history
- Loyalty data – miles balance, tier status, partners you transfer points to/from
- Device / usage data – IP address, cookies, app analytics, flight-search history
- Health data – medical clearance, COVID-19 test certificates, wheelchair or dietary needs (only where necessary for carriage)
- Employment data – CVs, work permits (for job applicants)
4. How we collect it
- Directly from you when you book, check-in, email, call, or use our digital channels
- Automatically via cookies
- From third parties: travel agents, Global Distribution Systems (GDS), partner airlines in alliances, immigration authorities, credit-card issuers, social-media platforms, recruitment agencies
5. Legal bases for processing
We rely on:
- Contract – to issue tickets, carry you and provide ancillary services
- Legal obligation – border & security laws, safety reporting, accounting
- Legitimate interests – fraud prevention, network planning, direct marketing (with opt-out), IT security
- Consent – for optional cookies, profiling for personalised offers, health data where special-category
- Vital interests – medical emergencies onboard
6. Why we use your data
- Ticket issuance, payment, check-in, baggage, irregular-ops rebooking
- Safety & security screening, no-fly list matching, incident investigation
- Loyalty programme administration
- Customer support, feedback, complaints
- Legal & regulatory compliance (e.g., Advance Passenger Information)
- Marketing & analytics (segmentation, targeted emails, app push)
- Recruitment & HR
7. Automated decisions & profiling
We may auto-assign seats, determine upgrade wait-lists or show personalised fares.
You have the right to human review and to contest decisions (see Section 12).
8. Who we share it with
Government & enforcement – customs, immigration, police, courts (when legally compelled)
We never sell your email address or payment card number to third-party marketers.
10. Security
Industry-standard technical & organisational measures: TLS 1.3 in transit, AES-256 at rest, network segmentation, role-based access, PCI-DSS, ISO 27001, annual penetration tests, crew-NDAs.
11. Retention
- Booking & travel records: 7 years after flight (accounting & legal claims)
- Loyalty accounts: 3 years after last activity, then anonymised
- CCTV: 30 days except incidents (extended to investigation end)
- Job applications: 2 years (with consent)
- Shorter periods apply where mandated by local law.
12. Your rights
Depending on jurisdiction you may:
- Access your personal data
- Correct inaccuracies
- Request deletion
- Object to processing
- Request data portability
Submit requests via info@freedomairexpress.com; we respond within 30 days.
13. Cookies & tracking
We use essential, performance, functional and advertising cookies.
You control non-essential cookies via the banner.
See separate Cookie Notice for full table, retention and opt-outs.
15. Changes to this Policy
We may update it to reflect new laws or operational practices.
Material changes will be emailed to loyalty members and posted on our homepage 30 days in advance.
Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Email: info@freedomairexpress.com
Freedom Airline Express Ltd
Wilson Airport Hangar #6
Nairobi, Kenya