Last update: 15.01.2022

1. Introduction

Proper handling of personal data is extremely important to us. We therefore take great care when processing and protecting your personal data. This is done in accordance with provisions set out in the applicable privacy laws (including but not limited to The Russian Federal Law on Personal Data (No. 152-FZ), The (EU) Regulation 2016/679 (General Data Protection Regulation)). We want you (hereinafter referred to as: «User», «You») to understand how and why «Air Company «North-West»., a company incorporated under the law of the Russian Federation at 119530, Moscow, Russia, Ochakovskoe Shosse, build 34, (hereinafter referred to as: Air Company «North-West » «we» «our» or «us») collects, uses, and shares information about You (hereinafter referred to as: «Personal Information», «PI», «PD») when You use our websites and other services (collectively, referred to as: «Services») or when You otherwise interact with us or receive a communication from us.

We may revise this Privacy Policy from time to time. The most current version of the the Privacy Policy will govern our processing of Your Personal Data and will always be at If we make a change to the Privacy Policy that, in our sole discretion, is material, we will notify You via email to the email address associated with You. If required by law, we will get Your permission or give You the opportunity to opt out of any new usage of Your Personal Information.

We take great care to limit the Personal Information we collect and to use only the Personal Information which is necessary for providing our Services.

Air Company «North-West» collects and processes Personal Information that is necessary for legitimate business purposes, which will be disclosed to the data subject. Air Company «North-West» will use and process this information only for the purposes for which it was collected, retaining the Personal Information only for so long as is required for the specific purpose for which the information was collected.

Air Company «North-West» will not collect sensitive Personal Data unless permitted or required to do so by law, and will do so only for legitimate business purposes. If in any other instance a need arises to collect sensitive Personal Data, Air Company «North-West» will do so only with the data subject’s express consent, which can be withdrawn at any time.

We retain Your Personal Data for as long as required to satisfy the purpose for which it was collected and used, unless a longer period is necessary for our legal obligations.

We do not transfer Your Personal Data to third parties, except in cases, which are mentioned in this Privacy Policy.

This Privacy Policy is incorporated into and is subject to the Air Company «North-West» Terms of Use. Your use of the Services and any Personal Information You provide on our Services remains subject to the terms of this Privacy Policy and our Terms of Use.

2. Personal Information

Personal Information we collect and use

The Personal Information we collect about You when You use our Services, include the following:

Information about You. We collect information regarding Your name and Your contact information (including but not limited to: contact phone number and email).

Actions you take. We collect information about the actions You take when using the Services.

Other information. You may choose to provide other information directly to us. For example, we may collect information when You request customer support or otherwise communicate with us. You may provide us the information about Your e-mail to receive mails.

Requesting additional permissions

We request permission for push notifications. You may opt out of receiving push notifications by going to Your device «Settings».

Personal Information we collect automatically

When You access or use our Services, we may also automatically collect information about You.

This includes:

Technical data. We may log information when You access and use the Services. This may include your IP address, browser type, operating system, device information (e.g., device IDs), hardware settings.

Information collected from cookies. When You use our website, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to Your computer that uniquely identifies Your browser. We use both session cookies and persistent cookies on this Website. A persistent cookie remains after You close Your browser. Your browser may use persistent cookies on subsequent visits to the site. Persistent cookies can be removed by following the directions in Your web browser's help file. A session cookie is temporary and disappears after You close Your browser. You can reset Your web browser to decline all cookies or to receive indication when a cookie is receive. However, some features of our website may not function properly if the ability to accept cookies is disabled.

3. Purposes of Personal Information collection

We use information about You to:

1.    Provide, maintain and improve the Services;
2.    Research and develop new Services;
3.    Help protect the safety of Air Company «North-West» and our Users, which includes blocking addressing abuse and enforcing our Terms of Use and our other policies;
4.    Send You technical notices, updates, security alerts and other support and administrative messages;
5.    Provide customer service;
6.    Communicate with You about services, offers, promotions, events and provide other news and information we think will be of interest to You;
7.    Monitor and analyze trends, usage and activities in connection with our Services;
8.    Personalize the Services and provide advertisements, content and features that match Your interests.

We collect general anonymous analytical information on the use of the Website for its optimization, including the frequency of entries, frequency of clicks, time spent on different pages, country of use, etc. - to optimize the Website.

4. Your rights regarding collected PI

You have the right to receive information regarding purposes of Personal Information collection, regarding third parties, to which we disclose Your Personal Information, information regarding safeguards that are undertaken for secure storage of Your Personal Information, the period of time for which Personal Information will be stored.

You also have the right to demand erasure of Personal Data which concerns by You. Air Company «North-West» shall fulfill Your demand in an appropriate period of time. If there is no other lawful ground for storing and processing of Your PI, as prescribed in applicable law, Air Company «North-West» shall erase such information. If there is another legal ground for such processing, Air Company «North-West» shall notify You in an appropriate period of time.

You also have the right to demand restriction of the storing and processing of the PI, if legal grounds for such demands have arisen as prescribed in the applicable law.

You have the right to object to processing of Personal Data which concerns Yourself under circumstances, that are prescribed in the applicable law. In case of such objection, Air Company «North-West» shall restrain from processing of Your PI, if there will be no other legal grounds for continuing of processing.

You have the right to ask Air Company «North-West» for providing You with a structured, list of previously provided PI. You also can ask Air Company «North-West» to transmit Your PI to previously chosen third party.

5. Collection of children’s PI

Children can only use our Services under the supervision of their parents/legal guardians. Consent for processing of a minors’ PI shall be given by the holder of parental responsibility over the minor.

Air Company «North-West» does not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Air Company «North-West» Services from persons under 13 years of age, and no part of our Services is directed to persons under 13. If You are under 13 years of age, then please do not use or access the Air Company «North-West» Services at any time or in any manner. If Air Company «North-West» learns that personally identifiable information of persons less than 13 years of age has been collected by the Air Company «North-West» Services without verified parental consent, then Air Company «North-West» will take the appropriate steps to delete this information.

Additionally, if You are in the EEA, You must be over the age required by the laws of Your country to use the Services, or we would need to obtain verifiable consent from Your parent or Your legal guardian.

6. Cookies

A cookie is a small piece of data that is stored on Your computer or mobile device. Like many websites, we use cookies and similar technologies to collect additional website usage data and to operate our Services. Cookies are not required for many parts of our Services. Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert You when a website is attempting to place a cookie on Your computer. However, some of our Services may not function properly if You disable cookies. When Your browser or device allows it, we use both session cookies and persistent cookies to better understand how You interact with our Services, to monitor aggregate usage patterns, and to personalize and otherwise operate our Services such as by personalizing the content we show You including ads, and remembering Your language preferences. We do not support the Do Not Track browser option.

When You visit the Air Company «North-West» website, we may send one or more cookies. Air Company «North-West» uses both session cookies and persistent cookies. A persistent cookie remains after You close your browser. Your browser may use persistent cookies on subsequent visits to the site. Persistent cookies can be removed by following the directions in Your web browser's help file. A session cookie is temporary and disappears after You close Your browser. You can reset Your web browser to delete all cookies or to indicate when it receives a cookie.

We show You the Cookie-banner for receiving Your clear consent for usage of cookies. You are able to restrict our usage of cookies anytime in Your profile settings. It is impossible to maintain our web-site without minimal usage of cookies and this is why we show You the Cookie-banner. We use required Cookies even if You do not accept banner.

7. Usage, processing and disclosure of PI.

Our Privacy Policy applies only to the Air Company «North-West» Services. Air Company «North-West» may contain links to other sites. We do not exercise control over any site that may be linked to from content on this site. We are not responsible for the privacy policies or content of such web sites.
We do not transfer your Personal Data to third parties, except cases, that are mentioned in this Privacy Policy.

With our partners. We may share information with vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out work for us. The partner’s use of personal data will be subject to appropriate confidentiality and security measures.

To comply with the law. We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, we will attempt to provide You with prior notice before disclosing Your information in response to such a request.

In an emergency. We may share information if we believe it's necessary to prevent imminent and serious bodily harm to a person.

To enforce our policies and rights. We may share information if we believe that Your actions are inconsistent with our User agreements, rules, or other Air Company «North-West» policies, or to protect the rights, property, and safety of ourselves and others.

With our affiliates. We may share information between and among Air Company «North-West» and any of our parents, affiliates, subsidiaries, and other companies under common control and ownership.

With Your consent. We may share information about You with your consent or at your direction.

We engage service providers to perform functions and provide services to us. We may share your private Personal Data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use Your private Personal Data only on our behalf and pursuant to our instructions.

We may partner with third-party advertisers, ad networks to deliver advertising and content targeted to Your interests and to better understand Your use of the Services. These third parties may collect information sent by Your computer, browser, or mobile device in response to a request for content, such as unique identifiers, Your IP address or other information about Your computer or device.

If You submit personally Identifiable Information to us through the Air Company «North-West» Services, then we may use Your Personal Information to operate, maintain, and provide features and functionality of the our website and another Services.

Other information, that does not personally identify You as an individual is collected by Air Company «North-West» (such as, for example, patterns of use) and is exclusively owned by Air Company «North-West». Air Company «North-West» can use this information in such manner that Air Company «North-West»,  in its sole discretion, deems appropriate.

We may share specific aggregated, non-personal information with third parties, such as the number of Users, the volume and pattern of traffic to and within the site, etc. That information will not identify You, the individual, in any way.

We shall not use Your email or other contact information for sending any commercial proposal, other marketing needs, without Your prior consent.

We do not use your email address or other personally Identifiable Information to send commercial or marketing messages without Your consent except as a part of a specific program or feature for which You will have the ability to opt-in or opt-out. We may, however, use Your email address without further consent for non-marketing or administrative purposes (such as notifying You of major Air Company «North-West» site changes or for customer service purposes).

As were mentioned above, when You send messages to us, we can keep them for administering your inquiries, for improving our Services. We shall not transfer information from such messages to third parties.

We restrict access to Personal Information to our employees, contractors and agents who need that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to disciplinare actions, including termination and criminal prosecution, if they fail to meet these obligations.

You can control and manage PI, that is being provided to the Air Company «North-West» by appealing to Air Company «North-West» with a request by e-mail to at any time.

You may update or correct your Personal Information at any time by appealing to Air Company «North-West». You can also delete Your Personal Information on the Air Company «North-West» website. We may retain certain data contributed by You if it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data or if required by applicable law. All retained data will continue to be subject to the terms of the Air Company «North-West» Privacy Policy that You have previously agreed to. To request the removal Your information from the Air Company «North-West» service, please send Your request. Please send Your request using an email that you have registered when You used our Services.

When You send emails or other communication to us, we may retain those communications in order to process Your inquiries, respond to Your requests and improve our services. We won't share any information You send to us in those communications with any third parties.

8. Protection of the Personal Information

We provide the following safety measures regarding protection of Your PI:

1.    Evaluation of the effectiveness of used security measures, prior to the launch of the Air Company «North-West» website and its updates;
2.    Establishment of rules for access to personal data processed by the E Air Company «North-West» website, as well as ensuring registration and recording of all actions performed with PI in the information systems of the Site;
3.    Detection of the facts of unauthorized access to PI and the adoption of appropriate response measures;
4.    Restoration of PI that was modified or destroyed due to unauthorized access to them (within the framework of technical capability of the Project).

We uses store and process Your PI on Air Company «North-West» servers in Russian Federation, where our facilities and/or service providers are located. By filling a «Consent Application» You agree to this transfer, storing, or processing. Air Company «North-West» will take all the steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. Air Company «North-West» protects Your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards: Air Company «North-West» use firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Air Company «North-West» also authorizes access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations. Third parties may be located in other countries where the laws on processing of Personal Data may be less stringent than in Your country. From time to time, the Personal Data may be also stored in other locations, and in such cases, Air Company «North-West» will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.

9. Notification

In the case of a Personal Data breach, Air Company «North-West» shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, about the Personal Information breach to notify the supervisory compent authority, unless the Personal Information breach is unlikely to result in a risk to the rights and freedoms of natural persons.

If Air Company «North-West» learns of a security systems breach, then we may attempt to notify You electronically so that You can take appropriate protective steps. Air Company «North-West» may post a notice on the our website if a security breach occurs.
When the personal data breach is highly likely jeopardize the rights and freedoms of Users, the Air Company «North-West» will inform You.

In the event that Air Company «North-West» is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control. If we become involved in a merger, acquisition, or any form of sale of some or all of its assets, we will notify Users before Personal Information is transferred and becomes subject to a different privacy policy. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how Your Personal Information is treated, transferred, or used.

10. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of Your Personal Data and will always be at If we make a change to this policy that, in our sole discretion, is material, we will notify You via email to the email address associated with You. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your Personal Information.

11. Contact us

If You have any questions about this Privacy Policy, please feel free to contact us or to write to us at:
Correspondence address: 119530, Moscow, Russia, Ochakovskoe Shosse, build 34.