Data Privacy
1. Controller
We, Lufthansa AG, Linnicher Straße 48, 50933 Köln, Deutschland (hereinafter also “Lufthansa”, “we”, “us”), wish to inform you how your personal data is processed when you use our website develeoper.lufthansa.com (“website”).
If you have any further queries regarding data protection in connection with our website or the services offered, please contact our data protection officer:
Group Data Protection Officer for the Lufthansa Group
Email: datenschutz@dlh.de
2. Scope, purpose and legal basis of processing personal data
We collect and use personal data directly from our users and other sources (mentioned below) in the following situations:
2.1. Provision of the website and log file creation
By visiting our website the system automatically records data and information about the user’s computer system each time the website is accessed. The following data (“technical information”) are collected:
(1) Information on the browser type and version used
(2) The user’s operating system
(3) The user’s Internet service provider
(4) The user’s IP address
(5) Date and time of access
(6) Websites from which the user’s system accesses our website
(7) Websites accessed by the user’s system via our website
The data are also saved in our system’s log files. The user’s IP addresses and other data which enable these data to be attributed to a user are not affected by this. These data are not stored together with other personal data of the user.
We collect and use this technical information for the purposes of (network) security (to for example ward off cyber-attacks), marketing and to better understand our users’ needs as well as to continuously improve our website and enable users to access the website from their computers.
Art. 6(1)(f) GDPR forms the legal basis for the temporary storage of the data.
2.1.1. Use of cookies
Our website uses cookies. Cookies are text files stored in the web browser or by the web browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a distinctive character string which allows for unique identification of the browser when the website is accessed again.
Cookies are stored on the user’s computer, which transmits these to our website. Therefore, users have full control over the use of cookies. You may disable or restrict the transmission of cookies by changing your web browser settings. Previously stored cookies can be deleted at any time. This may also be done automatically. If cookies are disabled for our website, you may no longer be able to use all of its functionality.
2.1.2. Tracking tools
We use the following tracking and (re)marketing tools on our website:
Our legitimate interest pursuant to Art. 6(1)(f) GDPR for the purposes of increasing the efficiency of our website and (direct) marketing is the legal basis for the use of the tools listed.
For further information on the individual tools, please check the appendix/“Tracking Tool Policy”.
2.1.3. Social media plugins
On our website, we use a “two-click solution” for the following social media plugins:
With the two-click solution, your data are only transmitted to the relevant social networking provider after initial activation (approval) of the respective plugin button, Art. 6(1)(a) GDPR.
The basic provision of the plugin on our website is based on our legitimate interest for marketing purposes, Art. 6(1)(f) GDPR. For further information on individual plugins, please check the appendix/“Tracking Tool Policy”.
2.2. Use of the services offered on our website
We offer a range of different services on our website. We must collect and process user or customer personal data in order to perform these.
2.2.1. Use case
We process email address data within the registration of your app. This data is initially processed for contract performance (Art. 6(1)(b) GDPR) as well as for the purposes of our legitimate interests (Art. 6 (1)(f) GDPR) to notify you in case of excessive data usage by you application.
2.2.2. Newsletter
You have the option of subscribing to a free newsletter on our website. When you subscribe, the data from the input screen is sent to us and processed:
The following data are also collected when you subscribe:
(1) Date and time of registration
During the subscription process, we obtain your consent to your data being processed and reference this privacy policy. No data are disclosed to third parties in connection with data processing for the distribution of newsletters. The data are used exclusively to distribute the newsletter. We process your data in connection with the newsletter in order to send news about topics from the Lufthansa world that we think are interesting. We also process and use the given email address for sending you personalised offers in connection with the newsletter. If a link in the newsletter takes you to our website, you also permit us to process and use your IP address, as well as geodata, web beacons and similar technologies, in order to verify whether the offers have met your requirements. Art. 6(1)(a) GDPR forms the legal basis for data processing following the user’s subscription to the newsletter if the user has given consent.
2.2.3. Statistical analysis
There is a possibility that your data may be analysed in a data warehouse to evaluate the preferences of our registered customers (“statistical analysis”) for the purposes of interest-led marketing, individual approaches and continuous optimisation of our business processes. We undertake this processing in order to acquire a better understanding of what our customers expect from us and to allow us to offer you communication that is tailored to you personally. This analysis also helps us with fraud detection, auditing and safeguarding security, which is why we perform this processing to protect our legitimate interests, Art. 6(1)(f) GDPR.
2.3. Our legitimate interest in processing personal data
If Art. 6(1)(f) GDPR forms the legal basis for the processing, our legitimate interests are, in addition to the purposes listed above:
2.4. Other processing commitments
If obliged to do so by law, we process personal data in order to meet duties of retention under commercial or tax law or to meet legal security requirements (such as Section 7 of the Aviation Security Act [LuftSiG]). For further information on retention periods, please refer to “Duration of the data processing”.
2.5. Obligation to provide personal data
The input fields which are mandatory to be filled out for performing the requested service are marked accordingly on the website. The input is either mandatory because of legal or contractual requirements.
3. Duration of the data processing
Your personal data are deleted as soon as they are no longer needed for the specified purposes. In certain circumstances, personal data are kept for the period of time during which claims against Lufthansa may be enforced (statutory limitation period of three to thirty years). Personal data are also saved to the extent that and for so long as Lufthansa is legally obliged to do so. Corresponding burdens of proof and duties of retention arise from, among others, the Commercial Code, Tax Code and Money Laundering Act. These prescribe retention periods up to ten years.
4. Right to object pursuant to Art. 21 GDPR
You have the right to object, on reasons relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process your personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or processing is necessary for the establishment, exercise or defence of legal claims.
Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
5. Disclosure of personal data to third parties
In order to offer you our products and services, based on our contractual obligations or in accordance with our legitimate interests, we may have to disclose your personal data to third parties internal or external to the Lufthansa Group. These recipients can be categorised as follows:
Personal data may be transmitted to third countries or international organisations as part of this. For your protection and the protection of your personal data, appropriate safeguards are provided for such data transmissions as per and in accordance with legal requirements (particularly, the use of EU standard contractual clauses) or an adequacy decision has been issued by the EU Commission (Art. 45 GDPR).
For information on EU standard contractual clauses, please visit [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=DE]. The EU Commission provides the relevant information relating to its adequacy decisions at [https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en#dataprotectionincountriesoutsidetheeu].
A copy of the security precautions used may also be requested from developer@lh-innovationhub.com
We are also legally obliged to provide personal data to German and international authorities, Art. 6(1)(c) GDPR together with local and international regulations and agreements.
6. Rights of the data subject
Lufthansa is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:
To exercise your right, please email developer@lh-innovationhub.com In order to process your request and for identification purposes, please note that we will process your personal data in accordance with Art. 6(1)(c) GDPR.
You also have the right to lodge a complaint with a supervisory authority. The relevant supervisory authority for Lufthansa is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Postfach 20 04 44
40102 Düsseldorf
Kavalleriestr. 2-4
40213 Düsseldorf
Phone: 0211/38424-0
Fax: 0211/38424-10
Email: poststelle@ldi.nrw.de
7. Consent
If you give your consent to us for processing your personal data, please note that you may withdraw this consent at any time.
If you gave this consent on the website, please visit the page where you originally gave consent or log in using your LH ID in order to withdraw consent in the settings.
If you have consented to receive our newsletter, you may withdraw this consent by using the “Unsubscribe” link in the newsletter.
In all other cases or if you have problems withdrawing your consent on the website, you can contact developer@lh-innovationhub.com
Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis – e.g. to perform a contract.
8. Disclaimer and limitations of these data protection notices
These data protection notices only apply to processing for the website developer.lufthansa.com . Other websites are not covered by these data protection notices and provide their own specific data protection notices.
Appendix – notices on the tracking and remarketing tools used
Lufthansa uses remarketing services to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimise and serve ads based on your past visits to our Service.
GoogleGoogle AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Mailchimp
When subscribing to our email newsletter, you may be asked to enter your email address and/or name or other details to help you with your experience. We are using MailChimp services for maintaining mailing lists and sending out newsletters. As a newsletter subscriber, IP address, the emails you open, and the links you click within those emails will be recorded, so that we can more accurately recommend and optimize content. It is therefore essential to transfer to MailChimp your email address, first name and last name (if the latter are provided). The Privacy Policy of MailChimp is available under the following link: https://mailchimp.com/legal/privacy