1. ABOUT US

1.1 Welcome to Skymaster Airlines (SkymasterAir) privacy notice. We respect your privacy and are committed to protecting your personal data. This privacy notice informs you about our commitment in looking after personal data of our customers, potential customer and vendors. It also provides information about your privacy rights and how the legislation protects you. This policy is in compliance with the Nigeria Data Protection Regulation 2019 (NDPR), the General Data Protection Regulation (GDPR), and other applicable data protection laws.

1.2 We have a dedicated unit under our Customer Relations Department which will handle any questions or requests in relation to this privacy policy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the below contact details. .

2. CONTACT DETAILS

2.1 Our full details are:

Full name of legal entity: Skymaster Achievers International Services Limited Email address: customerrelations@skymasterair.com Postal address: Ritaxxa Plaza G.U Ake Road, Eliozu, Port Harcourt, Rivers State.

2.2 You have the right to make a complaint at any time to your country’s supervisory authority for data protection issues. In Nigeria, this is the Nigerian Data Protection Bureau (NDPB). However, we would, appreciate the chance to deal with your concerns before you approach the relevant data protection authority, so please contact us in the first instance using the contact details above.

3. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

3.1 This is our first version privacy policy written on April 10, 2025. New version will replace this version and will be reported here.

4. DEFINITIONS

4.1 Personal data means 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, anonline identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identity has been removed (anonymous data).

4.2 Sensitive personal data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

4.3 Profiling is any form of automated processing of personal data consisting of the use of personal data in order to evaluate certain personal aspects relating to an individual.

4.4 Data processing/processing is any activity, operation or set of operations performed on personal data or sets thereof, irrespective of the procedure and the means (automated or not) applied, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, revision, disclosure by transmission, dissemination or otherwise making available, alignment or combination, interconnection, blocking (locking), erasure archiving, viewing and destruction of personal data.

4.5 Data file means any structured set of personal data which are accessible in such a way as to make it possible to deduce the person in question from the data. 4.6 Disclosure means making personal data accessible.

4.7 Data Protection Impact Assessment is a systematic process for identifying, evaluating and documenting the risks and impact of personal data processing activities to the rights of individuals.

4.8 Data controller is the legal person who decides and determines the purpose and means of processing personal data.

4.9 Data processor is the physical or legal person that processes personal data on behalf of the Data controller.

5. THIRD-PARTY LINKS

5.1 Our website (www.skymasterairline.com) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and thus SkymasterAir shallnot be responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

6. CATEGORIES OF INFORMATION WE COLLECT

6.1 We may collect, use, store and transfer different kinds of personal data about you only with your explicit, informed consent, and in compliance with applicable legal provisions, which we have grouped together as follows:

6.1.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

6.1.2 Contact Data includes billing address, delivery address, email address and telephone numbers.

6.1.3 Financial Data includes bank account and payment card details.

6.1.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

6.1.5 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

6.1.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

6.1.7 Usage Data includes information about how you use our website, products and services.

6.1.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

7. HOW WE COLLECT YOUR INFORMATION

7.1 We collect personal data about you whenever and wherever you use our services (whether services provided directly by us or by other companies or agents acting on our behalf), when you travel with us, when you use our websites, or when you use our call centres or mobile applications. Consent is obtained through clear opt-in mechanisms, and you may withdraw consent at any time without detriment.

8. WHY WE COLLECT YOUR INFORMATION

8.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:8.1.1 Where we need to perform the contract we are about to enter into or have entered into with you and/or in order to take steps at the data subject’s request prior to entering into a contract,

8.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

8.1.3 Where we need to comply with a legal or regulatory obligation;

8.1.4 In order to protect the vital interests of the data subject or another natural person,

8.1.5 For the performance of a task carried out in the public interest or in the exercise of official authority vested in SkymasterAir,

8.1.6 For providing to you tailored services;

8.1.7 For management and administrative purposes;

8.1.8 For carrying out analysis and market research;

8.1.9 For carrying out marketing and keep you informed of products and services;

8.1.10 For purposes of website improvement, products and services;

8.1.11 For commercial purposes; and/or

8.1.12 For detecting suspicious financial transactions.

9. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

9.1 We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

9.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

10. CHANGE OF PURPOSE

10.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible withthe original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

10.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. COOKIES, WEB BEACONS, AND OTHER SIMILAR TECHNOLOGIES

12. CHILDREN’S PRIVACY

12.1 We do not knowingly collect personal data from children under the age of 18 without verifiable parental consent. If we become aware that we have collected data from a child without appropriate consent, we will take steps to delete such information promptly.

13. WHO ELSE MAY HAVE ACCESS TO YOUR INFORMATION

13.1 To best serve you, we may share your personal data with service providers that provide support services to us or that help us market our products and services. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from SkymasterAir.

13.2 In particular and in order to facilitate your travel arrangements, we will often need to share your personal data with third parties such as airlines, airport operators, customs, immigration authorities and travel agents involved in making your travel arrangements. We also share your personal data with third parties who deliver services either to you or to us, such as companies that provide airport assistance.

13.3 We may disclose your personal data to a third party to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

13.4 We may also disclose your personal data to a third party when you ask us to do so or when we believe it is required by law.

14. COUNTRIES HAVING ACCESS TO YOUR INFORMATION

14.1 Our servers, storing and keeping your information secure, are located in Europe. In addition, SkymasterAir Staff members and service providers are located in Nigeria and other countries. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Where we use providers based in the US or transfers to the US, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and other relevant safeguards which requires them to provide similar protection to personal data shared between the Europe and the US. {Note: Privacy Shield has been invalidated by the EU Court} SkymasterAir may transmit reservation, checking and boarding data collected from the passengers ( API/PNR) to the competent authorities in Europe and other countries for the purposes and under conditions as defined in the national legislations of each country.

15. PRIVACY BY DESIGN

15.1 When new data processing systems are introduced, we ensure a high standard of data protection. Particularly, any new systems and processes must comply with the following principles: Technical and organizational measures must be taken to ensure systematic and secure life cycle management of personal data from collection to processing to deletion, Data processing systems must be aimed at collecting as few personal data as necessary to fulfil the purpose for which the data was collected, Where anonymizing the data does not inhibit with the data processing purpose, personal data must be rendered anonymous in a way that the data subject is no longer identifiable, Where personal data can’t be anonymized, security measures appropriate to the nature of the data must be taken, such as pseudonymization, encryption, or access restriction,Access to personal data shall be granted according to the “need-to-know” principle, meaning that personal data shall only be made accessible to those persons who require it to perform their assigned roles and responsibilities, Systematic quality checking of personal data must be part of data life cycle management to ensure high data quality. In particular, processes must be established to detect and correct false or incomplete personal data, Data processing systems must be adequately protected from unauthorized access through technical and organizational measures, Data subjects must be provided with transparent, user-friendly and effective means of control concerning their personal data.

16. PRIVACY BY DEFAULT

16.1 We set up data processing systems in a way that the strictest privacy settings apply automatically.

16.2 We permit more extensive processing of personal data only if the data subject gives its explicit consent to extended processing.

17. DATA SECURITY

17.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

17.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

18. RETENTION OF YOUR INFORMATION

18.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

18.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

18.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

18.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

19. YOUR RIGHTS

19.1 You have the right to:

19.1.1 Request access o your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

19.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

19.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

19.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

19.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

19.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

19.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

20. NO FEE USUALLY REQUIRED

20.1 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or if additional copies of your personal data are requested. Alternatively, we may refuse to comply with your request in these circumstances.

21. WHAT WE MAY NEED FROM YOU

21.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

22. TIME LIMIT TO RESPOND

22.1 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

23. RESPONSIBILITIES

23.1 Data controller
SkymasterAir is responsible for the lawful processing of personal data and compliance with data protection and data security requirements as set out in this policy or pursuant to applicable law. In particular, for: the observance of the “privacy by design” and “privacy by default” principles when developing new data processing activities, the effective handling of data subjects’ rights requests, the conducting of data protection impact assessments for personal data processing with the assistance of the data protection officer, the appointment of a data processor, the notification of a personal data breach to the supervisory authority, the data subject and other data controllers in accordance with the Data Breach Notification Policy of SkymasterAir. the provision of employee awareness training.

23.2 Data processor
The data processor is responsible for processing personal data according to the instructions received from the data controller. Furthermore, the data processor is responsible for notifying the data controller of a data protection breach without delay and specifically within 24 hours. Processing by a data processor shall be governed by a contract, that is binding on the processor with regard to SkymasterAir and that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. That contract covers all the following elements: processing of data can only occur on the basis of the instructions from the controller; the processor must employ staff with confidentiality obligations; the processor must take the required security measures; the conditions for engaging a service provider (sub-processor). Specifically, the data processor must contractually grant that any eventual sub-contractor instructed to perform the data processing, complies with the same instructions received from SkymasterAir; how to handle data subject requests; reporting and assistance in the event of a personal data breach; the deletion or return of all personal data at end of contract ; and the right to obtain information from the processor demonstrating its compliance and allow on-site inspections. However, SkymasterAir, as data controller, remains the ultimate responsible party towards the relevant persons, in particular the data subject and the authorities.

23.3 Executive management
The executive management of SkymasterAir is responsible for implementing this policy and shall provide the necessary personnel and financial resources. SkymasterAir’s managers are required to enforce the policy in their area of responsibility and ensure that employees, individuals, and entities for which they are responsible, are aware of, understand, and adhere to the requirements of this policy, and are appropriately trained to fully discharge this responsibility.

24. POLICY CHANGES

This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.