Privacy Policy

“Roam by Avios” Privacy Policy

“Roam by Avios” is a trade name used by Avios Group (AGL) Limited (company registration number 02260073), registered in United Kingdom whose registered office is at Waterside, Speedbird Way, Harmondsworth, West Drayton UB7 0GB. Avios Group (AGL) Ltd is the distributor of “Roam by Avios” for the purpose of marketing, facilitating the customer relationship, Avios award and other ancillary activities.  In this Policy you can find more details about how Avios Group (AGL) Limited will be treating your data when you purchase a plan with “Roam by Avios”.
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When does this policy apply?

This Privacy Policy applies to the personal information that we process when you purchase a “Roam by Avios” product, for the purpose of marketing, facilitating the customer relationship, Avios award and other ancillary activities related to “Roam by Avios”.
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Who is responsible for your Personal Data

Avios Group (AGL) Limited is the Controller of the personal information processed in connection with this Privacy Policy. Our address is Avios Group (AGL) Limited, Waterside, Harmondsworth, UB7 0GB, England. You can direct your questions or complaints to support@roamavios.co.uk.

AGL is part of the International Airline Group (“IAG”) and its role as a Data Controller in the Avios Programme relates primarily to the awarding and redemption of Avios in the following Programmes: British Airways Executive Club, Iberia Plus, AerClub, and Vueling Club. AGL receive, store and process Avios Programme Member Data to administer parts of the Schemes.

You can find more information about how your information is used as part of the British Airways Executive Club, where British Airways Plc and AGL are separate data controller with responsibilities for the processing of personal information as part of the Programme.

eSIM Data Plan are provided by our partner Gigs Wireless LLC (“Gigs”). If you have made a purchase with “Roam by Avios”, Gigs will be a separate Controller of your data for processing your personal data relating to the management and provision of the e-sim service, including the Roam by Avios account. Please refer to the Terms of Service of Roam by Avios (Gigs) and you can find more information regarding how Gigs handle your personal data in their Privacy Policy. You may direct your questions or concerns to legal@gigs.com.
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When do we collect personal information?

We collect personal information about you when you purchase a plan with “Roam by Avios”, use our websites, interact with us by email or use our contact centres.  

In addition, we may receive personal information about you from Gigs as the service provider or other third parties when you have given prior authorisation to do so.
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What types of personal information do we collect and retain?

When you interact with “Roam by Avios” we will collect the following categories of personal information:

• Information you provide to complete a purchase of a “Roam by Avios” product. This can include your name and contact details, addresses, purchase or account history, account information and website user information (including user journeys and cookie tracking)

• Information about your Avios Programme so you can collect your Avios. This can include your British Airways Executive Club member account number and number of Avios you have collected

• Information about the services provided to you.  This can include your name, address, email, contact details, destination of the plan, account details and details of your transactions such as products purchased

• Information about your use of our websites, contact centres and mobile applications. To help us customise your personal information and to improve our website we use “cookies” and other similar technologies and collect information about your searches and the contents you have visited on our website, such as what website you are surfing from, or the banner advertisements or links appearing in our marketing partners’ websites.

Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data requiring additional protection under European Union and UK data protection law and is referred to here as “sensitive personal data”. Generally, we do not collect or process sensitive personal data unless you have otherwise chosen to provide such information to us.
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What do we do with your personal data and its lawful basis?

We process personal information for the below purposes: 

• Based on our contractual relationship with you, to fulfil the services you have asked for, including the Avios.

• Based on our contractual relationship with you, to send status updates and service communications to you regarding the contracted plan. 

• Based on our legitimate interest to carry out analysis and market research. For example, we will analyse the way in which our sales channels, products and services are being used by customers so that we can understand how to improve the service we offer and encourage customers to use the full range of our products and services. 

• Based on the consent you have previously given, to carry out marketing including online advertising and keep you informed of Roam by Avios updates or related products and services.  We may tailor the content of our websites, applications, emails and other communications to ensure they are as relevant to you as possible – including previous plan destinations including offers and/or services relating to that or a similar destination.

We may combine/match customer relationship marketing data with a third party (e.g. Google) so both companies can understand behavioural activities such as knowing other sites visited. To undertake targeted online advertising.  For example, we may combine/match identifiers with a third party (e.g. Google) so both companies carry out advertising on our behalf.

• Based on our legitimate interest, to improve our websites, products and services. For example, we may monitor the way that you and other customers use our website so that we can identify ways to improve the website experience.

• Based on our contractual relationship with you, to be able to manage any transactions, operations, contracting of products and services that may take place by any means, or any type of query, complaint, claim or suggestion that you may submit to us.

‍Based on compliance with our legal obligations, depending on the case, we may also use your data for other management and administration purposes.
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How long do we keep personal information?

We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you make a purchase we will keep the information related to your Avios awarded, so we can carry our obligations to you and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.  The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any Avios points which are due to you.

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.
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Who do we share information with?

Your personal information may be shared with the companies within our group, which includes International Consolidated Airlines Group S.A (IAG), British Airways, Iberia, Iberia Express, Vueling, Aer Lingus, OpenSkies, British Airways Holidays, BA CityFlyer, IAG Connect and IAG GBS. For more details about our group please visit the website of our parent company, IAG. We share information with them, so they can assist us in providing services to you and to understand more about you.

We may also disclose your personal information to the following third parties:

• Our loyalty Partners for the purpose of administering offers and awarding of Avios, including transaction monitoring information when you make a purchase with them.
• In response to a valid, legal request from Government and law enforcement agencies
• Third party service providers we are using to provide services that involve data processing, for example, to carry out customer surveys on our behalf
• Third parties, such as law firms and law courts, to enforce or apply any contract with you
• Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.

We do not sell personal information to third parties, and we only allow third parties to send you marketing information where you have agreed and consented to this.
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What countries will your personal information be sent to?

We will not transfer your data to parties in countries outside the UK or European Economic Area for marketing, facilitating the customer relationship, Avios award and other ancillary activities purposes. We will ensure that if your personal information is shared outside of UK or the European Economic Area, the necessary safeguards will always be in place to protect your personal information.

Gigs as a separate Controller of your data for processing your personal data relating to the management and provision of the e-sim service, including the Roam by Avios account, operates outside of the UK and European Economic Area. Please refer to their privacy policy for further information about other countries where your personal information can be set as part of their services.  
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Your individual rights in relation to your personal data and how to exercise them

Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. When applicable, responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated, we may extend the deadline for responding to three months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.

We would like to make you aware that your rights do not always apply in all cases, for example we might not be able to delete your data if we need it to fulfil your order or we are required to keep it by law. We also might not be able to provide you with information if it would infringe someone else’s rights. We’ll always try to help you with your request and will let you know in our correspondence with you how we will be able to meet your request and explain why if we are unable to do so.

Your rights include the following:

1. Marketing – If you no longer wish to receive marketing communications related to Roam by Avios you can unsubscribe in the footer of any email from team@roamavios.co.uk or contact support@roamavios.co.uk 
2. Access – You may request access to the personal information that we hold about you.
3. Processing - You may request us to stop using your personal information where we are doing so under legitimate interests, see the section What is our legal basis for using your personal information' for examples of when that applies, unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights.
4. Restriction – You may ask that we restrict the processing of your personal data to a specific purpose or purposes.
5. Correction - You may ask us to correct your personal information, the 'right of rectification’, if that information is inaccurate.
6. Erasure - You may ask for personal information which identifies you to be erased, or forgotten.

If you would like to exercise any of your rights in relation to the data managed by Avios Group (AGL) Ltd, please include the following information with your request:

1. Your name and postal address
2. How you would prefer to receive the response (email, post)
3. Details of your request
4. Any details which may help us locate the information, which is the subject of your request, for example Frequent Flyer programme and membership identifier or telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call(s)).
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We may ask you to provide:

1. a photocopy of your passport or driving licence, so that we can verify your identity
2. signed authority from a third party if you are applying on their behalf
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Please send your request to:

Email: support@roamavios.co.uk 
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Post: Data Protection Officer

Avios Group (AGL) Limited
Waterside
PO Box 365
Harmondsworth
UB7 0GB
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How to complain

If you wish to contact us in relation to this Privacy Policy or you have any concerns, please contact us at support@roamavios.co.uk Alternatively, you can contact our Data Protection Officer at data.protection@avios.com, including in the subject “Roam by Avios”. 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: +44 (0) 303 123 1113

Website: https://www.ico.org.uk/make-a-complaint
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Last updated

We will routinely review the content of this Privacy Policy and make minor adjustments and corrections as necessary. As required by law, when we make any significant changes that would have an impact on your rights and your Personal Data, we will announce these changes in advance, and make sure you are informed of these changes, which may require us to send you an email announcement.

last version produced date December 1, 2024