Terms of Use and Privacy Policy – Angola

I. INTRODUCTION
ZenFly is committed to preserving privacy and protecting the personal data of Users who utilize this Channel. The purpose of this document is to inform Users about the general rules for the collection, use, storage, processing, protection, sharing, and deletion of their personal data gathered by “Status do Voo nas Palmas das Mãos” (therefore “Flight Status in the Palm of Your Hand”) in the provision of its services, especially when using the Mobile Application (WhatsApp).
By using our services, the User understands that we collect and use their personal information in the ways described in this Policy, in accordance with the provisions of the Personal Data Protection Law No. 22/11, of June 17, and other applicable rules of the Angolan legal system. Therefore, ZenFly, as the Data Controller, undertakes to comply with the provisions of this Privacy Policy. The use of ZenFly’s Services implies acceptance of these Terms.

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II. HISTORY OF CHANGES
ZenFly may update or modify this Privacy and Data Protection Policy (“Policy”), and all such changes will be duly recorded. If the User does not agree with these modifications, they may revoke their consent in accordance with legal standards.

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III. DEFINITIONS
To facilitate better understanding of this Policy, the following definitions are provided:
a. Personal Data: Any information relating to a living, identified, or identifiable person. Personal data also includes any distinct pieces of information that could lead to the identification of a specific individual.
b. Processing of Personal Data: Any operation or set of operations performed on personal data or on sets of personal data, by automated or non-automated means, such as collection, registration, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of availability, comparison or interconnection, restriction, erasure, or destruction.
c. User: A natural person with the legal capacity to engage in civil acts who accesses the “Flight Status in the Palm of Your Hand” Channel and its Mobile Application (WhatsApp) and provides (or does not provide) the requested data at the time of access.
d. Person Responsible for the Processing of Personal Data: A natural or legal person who determines the purposes and means of personal data processing.
e. “Flight Status in the Palm of Your Hand” Channel: A system that provides real-time flight information and offers of products and services at airports. This Channel offers the User a complete, advanced, and integrated solution for carrying out activities and obtaining more details about flights.
f. Data Protection Officer (Encarregado): A natural or legal person responsible for acting, on behalf of ZenFly, as a communication channel with the National Data Protection Authority and with the User, in the capacity of Personal Data Subject.
g. WhatsApp: A free instant messaging and voice call application that enables information exchange among individuals or groups, available for Android and iPhone.

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IV. SCOPE
This Policy applies to all employees at ZenFly’s headquarters, its subsidiaries, and to all volunteers, clients, and other individuals working on behalf of the company. It also applies to all managers (directors, board members, and advisors), as well as third parties and partner companies. All direct or indirect employees must endeavor to ensure that their actions follow the guidelines set out in this Policy, considering the specific needs and legal and regulatory aspects related to the collection, storage, handling, and disposal of personal data.

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V. PURPOSES
The “Flight Status in the Palm of Your Hand” Channel is a system that enables real-time flight tracking and the receipt of offers for products and services at airports. This Channel provides a complete, advanced, integrated, and swift solution for the User to carry out activities and obtain more flight information.
To allow the User to use the WhatsApp functionalities and access immediate and reliable information, ZenFly must gather and use certain information from Users who access “Flight Status in the Palm of Your Hand” via WhatsApp, such as: (i) The content of messages sent; (ii) Phone number; (iii) The User’s display name on WhatsApp. 
This Policy describes how this personal data should be collected, processed, and stored to meet the company’s data protection standards and to comply with Personal Data Protection Law No. 22/11, of June 17, and other applicable Angolan legal provisions.
Interaction with ZenFly’s WhatsApp channel may include links to third-party websites. ZenFly is not responsible for the content of any third-party websites or resources. These Terms of Use and Privacy Policy do not apply to third-party websites or resources, even if they were accessed via a link available in ZenFly’s WhatsApp channel. The User should review the privacy policies of any third-party websites before providing any information.

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VI. CONSENT
ZenFly processes the User’s personal data based on the User’s consent. Consent is the free, unequivocal, and explicit manifestation by which the User authorizes ZenFly to process their data. Thus, in accordance with the Data Protection Law, the User’s data will only be collected, processed, and stored after obtaining their prior and express consent, which is required to use the Channel.
Consent will be obtained specifically for each purpose described in this Policy, reflecting ZenFly’s commitment to transparency and good faith towards its Users, in line with relevant legislative requirements. By using the “Flight Status in the Palm of Your Hand” services and providing personal data, the User acknowledges and agrees to the provisions of this Privacy Policy and is aware of their rights and how to exercise them. The User may revoke consent at any time, at no cost.
It is important to note that revoking consent for data processing may render certain functionalities of the Channel inoperable if they depend on such data. These consequences will be previously communicated.

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VII. DATA PROTECTION LAW AND ITS PRINCIPLES
The Personal Data Protection Law, Law No. 22/11, of June 17, lays out how organizations must handle and store personal data. These rules apply regardless of whether the data is stored electronically, on paper, or in any other medium. To comply with the Law, all personal information must be collected and used fairly, stored securely, and not disclosed unlawfully.
The Data Protection Law is governed by six key principles, all of which ZenFly fully observes when collecting and processing data:
(i) Transparency: Data must be processed transparently, strictly respecting the principle of privacy, as well as constitutionally and legally enshrined public rights, freedoms, and guarantees. Personal data must be retained in a manner that allows the data subject to exercise their rights of access, information, rectification, cancellation, and objection.
(ii) Lawfulness: Data processing must be carried out legally and honestly, respecting the principle of good faith.
(iii) Proportionality: Personal data under processing must be relevant, appropriate, and not excessive in relation to the purposes that justified its collection and processing.
(iv) Purpose: Personal data must be collected and processed for specified, explicit, and legitimate purposes. It is prohibited to process personal data for purposes different from or incompatible with those for which it was originally collected and processed.
(v) Accuracy: Processed personal data must be accurate. Suitable measures must be taken to ensure that any data that is entirely or partially inaccurate or incomplete is erased or rectified so that it corresponds to the data subject’s current and actual situation.
(vi) Data Retention Period: Collected personal data must be kept in a way that allows the identification of its subjects only for as long as necessary to fulfill the purposes that justified its collection or processing. It must then be deleted or rendered anonymous. Non-personal data collected will be retained as long as necessary for meeting the objectives of tracking Tax Stamps, as safeguarded by the Channel.

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VIII. GUIDELINES
This Policy is intended to demonstrate ZenFly’s commitment to:
(i) Protecting the privacy and personal data collected from Users, employees, and partners, in the context of its business activities;
(ii) Promoting compliance with privacy and data protection legislation and best practices;
(iii) Ensuring transparency regarding how ZenFly processes any personal data collected;
(iv) Implementing practices to prevent data breaches and establishing standard procedures in the event of data breaches.

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IX. INFORMATION COLLECTED
This Policy applies to all data in ZenFly’s possession relating to living individuals, even if some information is technically outside the scope of the Data Protection Law. Such data may include: individual names, home addresses, email addresses, telephone numbers, tax identification numbers, and/or any other necessary information. 

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X. ENTITY RESPONSIBLE FOR DATA PROCESSING
The entity responsible for data processing is ZenFly.

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XI. PURPOSE OF DATA COLLECTION
Personal data is collected and processed by ZenFly for specific, explicit, and legitimate purposes and cannot be subsequently used in ways incompatible with these purposes. They are all fully aimed at the operation of the “Flight Status in the Palm of Your Hand” Channel, namely:
(i) Real-Time Flight Information Tracking;
(ii) Receiving offers for products and services. 

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XII. CONDITIONS OF USE
The User agrees to use the content and information provided by the Channel properly, including but not limited to:
(i) Not engaging in activities that are illegal or contrary to good faith or public order;
(ii) Not using the Channel in an abusive manner that could interfere with the information collected by the Channel;
(iii) Not causing damage to the Channel’s logical systems through the WhatsApp Application or to those of its suppliers or third parties; not introducing modified or falsified information, nor spreading computer viruses or any other hardware or software systems that could cause the damages mentioned above.

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XIII. TERMS OF USE
The User agrees to comply with these Terms of Service and with all applicable laws and regulations. The User agrees that they are responsible for compliance with any local laws. If the User does not agree with any of these terms, they are prohibited from using the Channel. The materials contained in this Channel are protected by applicable copyright and trademark laws.

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XIV. DATA SHARING
To facilitate the use of the services offered by ZenFly or to carry out commercial activities involving the offering of promotions, products, and services, ZenFly may share the personal data collected with third-party partner companies that also comply with the Data Protection Law. Examples include airport operators, airlines, commercial establishments, advertising and marketing agencies, among others.

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XV. RIGHTS OF PERSONAL DATA SUBJECTS AND EXERCISE OF THOSE RIGHTS
ZenFly ensures that data subjects—who may exercise the rights listed below by means of a written communication delivered to the company’s headquarters—can exercise their rights regarding the collection and processing of their personal data, as provided by applicable law:
a. Information
The data controller must provide data subjects with at least the following information:
(i) The identity and address of the data controller;
(ii) The purposes of the processing and the creation of a file for that purpose;
(iii) The recipients or categories of recipients of the data;
(iv) Whether providing data is mandatory or optional, and the possible consequences of not providing data;
(v) Consequences of collecting data without the consent of the data subject or, in the event of their incapacity, of their legal representative;
(vi) Any other information necessary to ensure lawful processing of such personal data.
b. Objection
The data subject has the right to object at any time, for compelling and legitimate reasons related to their particular situation, to the processing of data concerning them. They also have the right to object, upon request and free of charge, to the processing of their personal data for direct marketing or any other form of solicitation. In the event of an objection, entities that promote the sending of advertising messages must maintain a list of data subjects who have objected to such messages.
c. Rectification, Updating, and Erasure
The data subject has the right to request the rectification, updating, or erasure of personal data that does not comply with the provisions of the Data Protection Law, particularly due to the incomplete or inaccurate nature of such data.
d. Data Protection Supervisory Authority
Personal data subjects also have the right to lodge complaints with the Data Protection Supervisory Authority.

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XVI. PORTABILITY
Regarding the portability of data to another service or product provider, ZenFly will act upon an express request, in accordance with the regulations of the national authority, and subject to commercial and industrial confidentiality.

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XVII. DATA RETENTION
ZenFly retains personal data for as long as necessary and as long as there are legitimate purposes for which the data was collected, in compliance with legal, regulatory, and contractual obligations to which it is subject, while observing the deadlines for retaining personal data.

 

XVIII. SECURITY
ZenFly ensures adequate levels of security and protection for data subjects’ personal data. To that end, it adopts various technical and organizational security measures to protect personal data against loss, disclosure, alteration, unauthorized processing or access, as well as against any other unlawful processing.
This Policy and the security measures adopted by ZenFly help protect the company from some data security risks, including breaches of confidentiality (i.e., preventing information from being shared improperly), giving data subjects the opportunity to choose how the company uses information about them, and preventing data leakage risks.

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XIX. USER RESPONSIBILITIES
The User is responsible for adhering to the air transportation contract and for complying with notices from the carrier (airline) regarding check-in deadlines, including flight status and recommended arrival times. ZenFly assumes no responsibility for the User in any aspect, particularly regarding showing up for boarding.
The User acknowledges and agrees that the foregoing limitations of liability are agreed-upon risk allocations that form part of the service provision to the User, and that such limitations apply even if ZenFly has been informed of the possibility of such liabilities.

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XX. DISCLAIMER OF LIABILITY
Although ZenFly adopts high security standards to prevent incidents, no platform, virtual channel, or software is entirely risk-free. Accordingly, ZenFly is not liable for:
(i) Errors, mistakes, or inaccuracies in any content;
(ii) Any personal injury or property damage resulting from the User’s use of the Services;
(iii) Any unauthorized access to ZenFly’s servers or any personal and other information stored therein;
(iv) Any interruption or cessation of transmission to or from the Services;
(v) The use or display of any content or User Content transmitted or otherwise made available via the Services;
(vi) Events beyond ZenFly’s reasonable control, including any internet failure, equipment failure, power outage, labor disputes, riots, insurrection, civil unrest, labor or material shortages, fire, flood, storm, earthquake, explosion, force majeure, war, terrorism, natural disasters, government actions, court orders, or third-party defaults;
(vii) Missed flights, loss of use, data, profits, or other intangible losses resulting from the use or inability to use any or all of the Services.

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XXI. APPLICABLE LAW AND JURISDICTION
This document is governed by the Personal Data Protection Law No. 22/11, of June 17, and other applicable legislation. Any disputes must be submitted to the competent court, namely the Civil and Administrative Court of the Provincial Court of Luanda, in accordance with the laws in force.