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AirAsia
From Consumer Action Taskforce
AirAsia is budget airline of Malaysian origin.In 2007, The New York Times described AirAsia as a pioneer of low-cost travel in Asia. As of January 2025, they service Asia, the Middle East and Australia.
Summary (TLDR)
AirAsia secretly and forcefully subscribes any user who creates or links an account with them to 23 different types of spam ("AirAsia communications") .
- Users are neither made aware of this fact nor presented with the option to opt out.
- Normally companies bury opt in text within their terms and conditions, but even the AirAsia Privacy terms page is vague about this.
- Unsubscribing from AirAsia's spam is an 8-step process where users have to log into their account.
Non-consensual opt-in to AirAsia marketing spam
AirAsia secretly and automatically forces users to opt-in to 23 different types of promotional and marketing emails (that they call "communications") when they create or link an account.
- When booking a flight with AirAsia, a popup dialog appears and pushes users to sign in, create or link an account; with multiple sign up and easy sign in options pushed with large font sizes and prominent, colored icons.
- The option to book a flight is presented as a small, plain text link "Continue as guest" at the bottom of the popup dialog. (SEE IMAGE 1)
- During sign up/log in, users are not made aware that they will be opted in automatically to receiving spam "communication" emails from AirAsia. They are also forced into opting in by default, with no ability to opt out directly on the same page.
- Typically companies sneak promotional and marketing email opt in into their TOS or Privacy Terms page, but on the AirAsia Privacy Statement page[1], they are still extremely vague about the fact they are opting users into their spam, automatically, forcefully and unknowingly; with the terms referencing promotional material being:
- "The information may be used to provide you with location-based services such as search results and marketing content." ("Information collection" section[2])
- "AirAsia and AirAsia Group of Companies who have access to this Personal Information with our permission and who need to know or have access to this Personal Information in order to: perform the service requested by you (including to make, administer, and manage reservations or handle payments, "single sign-on", and customer service); analyze how you use this Website and other websites belonging to AirAsia or AirAsia Group of Companies, improve and provide new and personalized offers, products and services, and marketing, for purposes of research, analytics, to develop and improve any existing and future products or services offered by us, to explore further potential initiatives, to optimise research, improve our forecasting abilities, and for other business purposes of AirAsia or AirAsia Group of Companies; detect, prevent, and investigate fraudulent transactions and/or activities, other illegal activities, and data breaches; internal (audit/compliance) investigations; or as otherwise required or permitted by applicable law." ("Use of information collected" section[3])
- We may share your Personal Information to: data analytics, marketing agency, third party suppliers of products and services, business partners or service providers, parties which have business or contractual dealings with AirAsia and the AirAsia Group of Companies, and other third party who is able to demonstrate that you have explicitly consented to the disclosure of your Personal Information by us to such third party (collectively known as “Authorised Third Party”) ("Sharing of Information Collected" section[4])
- The same Privacy Statement does provide steps to "Manage your marketing communications"[5], which is a 3-step process assuming the user does this after creating their account and/or booking their flight. The steps highlighted on that page are:
- Click on Account (your name with the user icon in the upper right side of the page)
- Click on My Account
- Click on Notifications Preferences
- However, since the user is not made aware that they will be opted into a barrage of spam emails, they would not be aware or have reason to go into "Notification Preferences" immediately after account creation/booking.
- Since most users will learn about the spam later, the unsubscribe process is in reality an 8-step process that takes 8 clicks instead of 3 suggested by AirAsia's Privacy Statement page (see below)
Multi-step friction to unsubscribe from AirAsia marketing spam
- User clicks on unsubscribe button at bottom of AirAsia promotional email.
- Instead of directly unsubscribing the user or bringing them to an unsubscribe confirmation page, users are instead linked to their account "Notification Preferences" page where they have to log in.
- After entering their log in details, users have to also input a One Time Password. This step takes at least 5 additional clicks, where the user has to:
- Click on their email tab or client (assuming they have it opened)
- Click on the AirAsia OTP email (assuming they receive it immediately. Otherwise clicking refresh is another click)
- Copy or remember the OTP, click back to the AirAsia login tab
- Paste the OTP into the form
- Click continue
- User is now on their Notification Preferences page where they get to see the 23 different types of AirAsia spam they never knew they opted into. Assuming they never wanted and don't want to continue receiving any of these spam emails, they would click on "Pause all emails".
- User also has to click on "Pause all communications" if they wanted to stop spam from coming in via push notifications and WhatsApp.
- Another dark pattern/deceptive labeling here from AirAsia is "Pause all communications" implies the user would stop receiving any communications whatsoever. Users would typically want their booking emails, travel itinerary, etc so they would not think of clicking this option.
- In fine print above this button, there is a statement "Your account activities, transactional updates, payment updates, booking and delivery information are compulsory." Meaning such emails will be delivered regardless and "communications" in "Pause all communications" really refers to promotional/marketing spam.
- ↑ https://www.airasia.com/aa/about-us/en/gb/privacy-statement.html
- ↑ https://www.airasia.com/aa/about-us/en/gb/privacy-statement.html#information
- ↑ https://www.airasia.com/aa/about-us/en/gb/privacy-statement.html#informationuse
- ↑ https://www.airasia.com/aa/about-us/en/gb/privacy-statement.html#sharing
- ↑ https://www.airasia.com/aa/about-us/en/gb/privacy-statement.html#marketingcomm