We respect the privacy of our customers, and any users of our Online Services, and developed this Policy to demonstrate our commitment to protecting your privacy. In order to deliver our Online Services to you, from time to time we collect personal information.

This Policy describes:

• The types of personal information we may collect or that you may provide when you book, access or use in any way the Online Services
• Our practices for collecting, using, maintaining, protecting, and disclosing that personal information

This policy DOES NOT apply to information that:

• We collect offline or through any other means
• Relates to employees or contractors
• You provide to or is collected by any third party, including through any application or content that may link to or be accessible from or on the website. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them

Some of our Online Services (such as our digital platforms) may contain links that connect you with third party partners, programs, products and services. These links do not operate under this Policy.

These third-party websites may independently solicit and collect personal information from you. While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review the privacy policies of all third-party websites you visit to understand their information practices before providing personal information directly to them.

Please read this Policy carefully. It is your choice whether or not to provide personal information to us. If you choose not to provide your personal information to us, you may not be able to use our Online Services (such as make a booking) and we may not be able to communicate with you. If you do not agree with our policies and practices, do not book, access or use the Online Services.

By accessing or using the Online Services, you accept and agree to be bound and abide by our Privacy Policy.

We may collect several types of information from and about you, including some or all of the following information:

• Your identity and contact details including; name, address, email address, telephone number, date of birth, gender, employer, passport or other identification details and photograph
• Payment information such as credit or debit card details used in connection with a booking or additional products or services purchased during your flight or through any of our digital applications
• Travel related information such as your destination, use of our inflight entertainment systems or details of products purchased from any of our digital applications
• Health information such as dietary requirements and other requests for specific assistance
• Feedback, compliments and complaints and any other correspondence that you may share with us including without limitation details of any incidents
• IP address or MAC address when using our digital platforms (such as website or app (and other associated details, including geolocation, the date and time of your visit , pages viewed, the URL of the website that you viewed before our website and the type of browser you use)
• If you use social media, any information that you allow the social media site to share with us
• CCTV images from surveillance equipment located at various Bonza offices, hangars and other operational locations

We collect this information:

• Directly from you when you provide it to us, such as when you make a booking or purchase a product from us or even when you sign up to receive offers or information;
• Automatically when you access or use our digital applications.

A.        Information Provided by You

We also collect the following types of personal information from you when you access the Online Services. The most common of these circumstances where you would provide personal information and the categories of personal information we collect in those circumstances include the following:

• Making a Booking or Registering for the Online Services. In order to fulfil your booking or complete the registration and/or to enable you to use certain features of the Online Services, we may collect your full name, email address and payment details (such as credit card information). We will store and use this information to administer the Online Services in which you choose to participate, and as permitted by this Policy
• Contacting Customer Service. When you contact our customer service, we may ask you to provide, or confirm, personal information, including your first and last name and email address so that we can better serve you; we may also use your details for quality assurance and training purposes
• Emails. We may collect your email address to send you reminders or other communication
• Promotional or Marketing Communications. If you sign up to receive promotional communications or notifications from us, we may ask you to provide personal information, including first name, last name, and email address, so that we can tailor our communication to you

The above list provides examples of the personal information that may be collected when using the Online Services. If you do not want us to collect your personal information, please do not provide it to us.

B.        Information that We Collect Automatically From You

When you access and use the Online Services, we may use technology to automatically collect information to improve our Online Services and to deliver a better and more personalised service:

• Usage Details. When you access and use the Online Services, we may automatically collect certain details of your access to and use of the Online Services, including clicks on ads, location data, time of visit, ad impressions viewed, audiences or segments to which the ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages on customers website visited by an end user, the URL from the referring website, downloads and installations of apps, and other interactions, events and actions which are chosen to measure and analyse within the app or website (e.g add to cart, in-app purchases made, clicks, engagement times etc) as well as the length of time you visit the Online Services or specific pages, page views, scroll depth, logs, scoring content that you are interested in, and other communication data and the resources that you access and use on or through the Online Services
• Technical Information and Identifiers. We may collect technical information related to you as well as technical identifiers about your device (whether that be a mobile device or computer) and internet connection, including your device type and model, the device’s unique device identifier, CPU, system language, memory, OS version, IP address (which may also provide general location information), wi-fi status, timestamp and zone, device motion parameters and carrier,, User Agent, IDFA (Identifier for advertisers), Android IS (in Android devices), Google Advertiser ID, Customer issued user ID and other similar unique identifiers, operating system, browser type, network information, Flash version, JavaScript support, screen resolution, and screen colour processing ability

C.        Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

• Cookies (or browser/mobile cookies) or other collection technologies (such as API’s, pixels, redirect links, javascript tags). When you visit our Online Services, we may assign your computer one or more cookies to help you navigate our Online Services efficiently, to personalise your online experience, and to perform certain functions, including Online Services traffic analysis. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Online Services. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Online Services. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign into our Online Services, we will record your GUID (Globally Unique Identifier) in the cookie file on your computer. This cookie is removed when you sign-out. In the case of sites and services that do not use a user ID, the cookie will contain a unique identifier. We may allow our authorised service providers to serve cookies from our Online Services to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Online Services may not function properly
• Web Beacons and Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies (such as bots), to track and collect your personal information as described above when tracking your use of our Online Services. We also may include web beacons in promotional email to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the services we offer to our users and to measure the overall effectiveness of our Online Services. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website
• Google Analytics. We use Google Analytics provided by Google Inc. It uses cookies to collect certain information, for example, information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Online Services. On subsequent repeated visits to the Online Services, frequently used information is automatically displayed for you. We are able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Online Services is transmitted to a Google server, which may be located within or outside of, the United States, and stored there. Google will use this information to evaluate your use of the Online Services. Google may transfer these rights to third parties insofar as it is required to do so by law or in order that data may be processed on Google’s behalf. By accepting this policy, you consent to the processing of your data by Google.

While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below:

• Provide you with access to the Online Services
• Provide you with and administration of your travel booking including allowing you to select and purchase travel segments and ancillary services
• Connect you with partners, programs, products, and services related to your travel
• For marketing purposes to provide you with updates and offers, and to operate any competitions that we may run
• Send you email communications related to your travel, your account, news, updates or offers
• Develop new services and to enhance, improve or modify our Online Services
• Perform attribution, analytics and ad fraud protection services
• Perform research and analysis about your use of, or interest in, our Online Services
• Track and analyse non-identifying and aggregate usage and volume statistical information from our users
• Exercise, defend, or protect our legal rights or the rights of our clients or third parties
• Protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business
• To establish matches between devices used and to detect fraud
• Keeping our Online Services and IT systems secure
• Making sure that our own processes, procedures and systems are as efficient as possible
• For service administration requirements where we need to contact you for reasons related to our services (for example, where we need to send you a password reminder, to notify you about service updates)
• For legal compliance purposes including for any health, safety or security purposes

Legal Basis for Processing. The General Data Protection Regulation (GDPR) requires that we inform you of the legal bases for our processing of your personal information. Where the GDPR is applicable, our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it. Bonza relies on the following lawful basis for processing personal information: your explicit consent, contract performance, our legitimate interests, and compliance with legal obligations.

When you provide us with your personal information by making a booking and by registering to use the Online Services, our legal basis for the processing of that personal information is that processing is necessary for us to provide a service to you or for us to perform our part of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

We also collect and process personal information about you as necessary to provide the Online Services, product development and improvement, and/or product usage analytics. In these instances, our lawful basis of processing your personal information is our legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms).

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either securely destroy it, or irreversibly anonymise the data (and we may further retain and use the anonymised information)

We may share your personal information as necessary to provide the Online Services you request, including sharing information with our third party service providers, when required by law, to protect rights and safety, and with your consent. Your personal information is not used for other business purposes other than providing the Online Services to you and reporting to those persons below.

We may share personal information with:

• Authorised service providers: We may share your personal information with our authorised service providers that perform certain services on our behalf. These services may include delivering our Online Services to you or providing customer service and support to the Services you have licensed, providing nudge emails to you, supporting our Online Services functionality, conducting surveys and research for product development and improvement, and supporting surveys, questionnaires, and other features of our Online Services
• Insurance Providers: When you book travel, you or we may purchase insurance on your trip to insure against disruptions in travel. When we purchase such insurance, we will share your personal information with the insurer
• Third Parties: To fulfil the travel arrangements for the customer and traveller, it will in most cases be necessary to transmit personal data to a third party. These will include but are not limited hotels, and car hire companies. Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of travel arrangements
• Government Officials. We may share your personal information with government officials for the purposes of complying with or aiding in security, customs or public health matters.
• Other situations: We also may disclose your information:

• a. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us
• b. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies, related to this Privacy Policy, to our Websites or to our Services
• c. In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
• d. When you provide us with your consent to share your information with third parties

Aggregated and Non-personal information: We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

We store your personal information here in Australia. However, in those exceptional circumstances where we need to process your personal information overseas we will only do so where we are satisfied that there are comparable levels of protection equivalent to Australia by using a legitimate transfer mechanism to the extent required under applicable laws, such as pursuant to contractual clauses and other safeguards. Under certain data protection laws and regulations, there may be additional requirements with which we must comply before transferring any personal information outside of the territory from which it has been collected, including without limitation, having obtained explicit consent from you with respect to such offshore transfer of personal information and undertaken certain security assessments mandated by local laws and regulations.

You may have certain rights in relation to your personal information. If you would like to exercise any of them, please contact us privacy@flybonza.com.
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

How You Can Access or Request to Delete Your Information: If you have an online account with us, you have the ability to access, review, edit, correct, and update your personal information online by logging into your account, to the extent that information is held within our Online Services.

You may request to have your personal information that you provided when you registered along with the information relating to your use of the Online Services removed from our databases, as well as request for the deletion/deregistration of any online accounts you have created (where applicable) by submitting a request to our contact information set forth at the end of this Policy, and insert “Privacy Rights Request” in the subject line. We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by applicable law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information may be subject to those third parties’ policies.

Your Choices About Collection and Use of Your Information:You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Online Services because such information may be required in order for us to finalise and administer your travel booking or to enable you to purchase a product .

Opt-Out: At any time you can choose to no longer receive commercial or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication or on our Online Services and following the instructions or contacting us. You may modify your choice at any time by using the “Opt-Out” link as described above.

You also will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take a little while for us to process an opt-out request or such shorter period as may be prescribed by applicable law. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us.

Even if you opt-out of receiving promotional or marketing communications, you may continue to receive emails and notifications relating to the Online Services that are necessary to fulfil your travel booking or conclude your purchase of our products.

The security and confidentiality of your personal information is important to us. We have implemented reasonable measures (including by taking physical, technical, and administrative measures) to protect your personal information from accidental loss and from unauthorised access, use, alteration, and disclosure.

While we are focused on the security of your personal information and follow strict standards, processes and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.

The safety and security of your information also depends on you. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Where we have given you (or where you have chosen) a username and password which enables you to access the Services, you are responsible for keeping these details confidential. We ask you not to share your password with anyone.

The Online Services such as digital applications are not intended for use by children under 16 years of age. We do not solicit or knowingly collect any information from visitors or users under 16 years of age. Please do not use the Online Services if you are under 16 years of age. The exception to this is the collection of personal information for a minor for the purposes of administering and facilitating a travel booking. If we learn we have collected or received personal information from a child under 16, we will delete that information except in relation to a travel booking.

This Policy does not create rights enforceable by third parties.

We will occasionally update this Policy to reflect changes in our privacy practices. If we make any such changes we will update it on our website. We encourage you to review the Policy each time you visit the Online Services to see if this Policy has been updated since your last visit to make sure you understand how your personal information will be processed.

If you have any questions about this Policy or our privacy practices, please contact us as follows:


Bonza Aviation Pty Ltd
Attention Privacy Officer
3 Friendship Avenue, Marcoola, QLD 4564

Email: Privacy@flybonza.com

Version 1.0 Dated 24 January 2023