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Privacy Statement for AirPlus’ Website

Privacy Statement for AirPlus’ Website

Below is an overview of how your personal data is processed when you visit AirPlus’ website.


Who is the controller?

With this Privacy Statement, Lufthansa AirPlus Servicekarten GmbH (Dornhofstraße 10, 63263 Neu-Isenburg, Germany) (hereinafter, “AirPlus,”) would like to inform you about how your personal data is processed as part of AirPlus’ online offerings. You can access AirPlus’ online offerings directly at airplus.com (hereinafter, “this Website”).

In the context of this Privacy Statement, the term AirPlus Group refers to Lufthansa AirPlus Servicekarten GmbH (Germany), AirPlus International Srl (Italy), AirPlus International Ltd (UK), AirPlus International SA/NV (Belgium), AirPlus International Inc (U.S.A.)., AirPlus Payment Management Co., Ltd (China), AirPlus Int. Soluções de Pagamento (Brazil) and AirPlus International AG (Switzerland).


What is the purpose and legal basis of AirPlus’ processing of your data?

AirPlus processes personal data in compliance with the provisions of the EU’s General Data Protection Regulation (hereinafter, “GDPR”).

AirPlus processes personal data to meet its contractual obligations under Article 6 1 p. 1 b) of the GDPR. These obligations include, but are not limited to,

  • entering into agreements regarding specific AirPlus products;
  • dispatching agreement confirmations; and
  • providing you with the information you need to use your AirPlus products.

AirPlus processes your data to comply with its legitimate interests under Article 6 1 p. 1 f) of the GDPR. These legitimate interests include, but are not limited to,

  • providing you with the information you need to use your AirPlus products;
  • preventing fraud, for example, credit card abuse, identity fraud, or the fraudulent obtainment of special conditions or rates;
  • ensuring IT security and operation;
  • preparing statistics to enhance AirPlus’ online offerings including using web tracking that enable limited profiling (find more information on objecting to this type of data processing in the section titled Data processing when you use this Website); and
  • processing requests AirPlus received, for example, through contact forms or social media.

AirPlus processes your data based on your consent under Article 6 1) p.1 lit. a) of the GDPR. This processing includes, but is not limited to, dispatching AirPlus Group newsletters which offer

  • information regarding AirPlus’ services and products;
  • news concerning the travel and payment services industries;
  • invitations to participate in events, market research, or customer surveys; and
  • invitations to participate in web seminars (hereinafter, “Webinars”).

If you participate in any Webinars, your consent includes your agreement to the evaluation of your participation.

AirPlus also processes your data to meet its legal obligation under Article 6 1 p. 1 c) of the GDPR. These obligations include, but are not limited to,

  • combatting money laundering and preventing terrorism including collecting data concerning the beneficial owners of companies and identifying credit card applicants; and
  • transmitting data to authorities in compliance with its legal obligations.


Which data is being processed when you use this website?

a. Cookies

This Website uses small text files, referred to as cookies, which web portals save on visitors’ computer systems (computer, tablet or smartphone). Cookies can be used to store personal data. You can set your browser to prevent your activities from being traced through cookies (do-not-track, tracking protection list) or to prohibit third-party cookies from being stored in general. To object to the use of some web tracking solutions, you also will be required to set cookies. Because deleting all the cookies (automatically or manually) means deleting opt-out cookies as well, you may need to re-execute the opt-out functions you executed in the past.

AirPlus wants to offer you the opportunity to make informed decisions regarding cookies that are not mandatory for using the technical functions of this Website.

AirPlus differentiates between cookies that are mandatory for using the technical functions of this Website, and optional cookies.

To enable you to adjust your data protection settings for your visit to this Website in an individualised manner, AirPlus offers you the opportunity to define your preferences in these four categories: Operational Necessity, Statistics, Convenience and Personalization. The full scope of this Website will be available to you even if you object to the setting of cookies.

1. Operational Necessity category

Cookies in this category are mandatory for operating this Website and providing the functions thereof, for example, language selection and Portal login.

2. Statistics category

To continue enhancing its offerings and Website, AirPlus captures data to prepare statistics and conduct analyses. AirPlus uses the cookies in this category, for example, to determine the number of visitors to and the user-friendliness of specific pages of this Website and to optimise AirPlus-related content.

3. Personalization category

Cookies in this category are used to provide you with personalized content that matches your interests so that AirPlus’ offerings are particularly relevant to you.

To be able to adjust its advertising so that it is relevant to you and matches your current interests, AirPlus wants to draw conclusions concerning your current interests based on your visit to AirPlus pages and on your browsing behaviour. AirPlus uses third-party cookies and creates pseudonym usage profiles to address visitors returning to this Website (retargeting, remarketing) and to measure conversion rates. These third-party cookies and usage profiles then are analysed for advertising and monitoring purposes; they cannot be used to identify individual visitors.

AirPlus uses advertising cookies, for example, to

  1. store your visits to this Website to ascertain your interests;
  2. determine whether you clicked an advertisement;
  3. monitor the number of visitors who click specific advertisements;
  4. use third-party services to display advertisements tailored to your needs, interests or preferences;
  5. determine which advertisements and means of advertising prove efficient for AirPlus;
  6. display advertisements for products which you previously clicked or searched for;
  7. measure the number of advertisements displayed to avoid showing the same advertisements repeatedly; and
  8. display other interesting advertisements based on your use of this Website.

AirPlus uses the following cookies including third-party cookies:

 

Description of third-party cookies used for usage-based online advertising

AirPlus uses the following companies to collect data for the provision of usage-based online advertising. The tools used for tracking and remarketing are categorised as follows:

  • Google AdWords Remarketing – Personalisation category
  • Google Analytics – Personalisation category
  • DoubleClick (HubSpot) – Personalisation category
  • DoubleClick Search – Statistics category
  • Hotjar – Statistics category

Personalization category:

Google AdWords Remarketing

This Website uses the remarketing function offered by Google Inc. (hereinafter, “Google”). This function is implemented through a cookie and is used to present interest-related advertisements to visitors of this Website as part of Google’s advertising network. On this Website, visitors may be shown advertisements relating to content they previously accessed on other websites. According to Google, Google does not collect any personal data during this process. If you do not want Google’s remarketing function, you can deactivate it by adjusting the setting at http://www.google.com/settings/ads. For more information on Google’s remarketing activities and privacy statement, please go to http://www.google.com/privacy/ads/.

Google Analytics

This Website uses Google Analytics, a web analysis service offered by Google Ireland Limited, (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). The use includes the Universal Analytics operation which facilitates the association of data, sessions and interactions across devices with a pseudonym user ID to analyse users’ activities across devices.

Google Analytics uses small text files, referred to as cookies, which are saved on your computer to facilitate analysis of your use of this Website. Typically, the information generated by cookies regarding your use of this Website is transmitted to and saved on a Google server located in the United States; however, if IP anonymization is activated on this Website, Google truncates your IP address for transmission among member states of the European Union or to other member states of the Agreement on the European Economic Area. Only in exceptional cases will your full IP address be truncated after transmission to a Google server in the United States. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google. At AirPlus’ request, Google will use the information to evaluate your use of this Website, to compile reports on Website activity, and to provide AirPlus with other services relating to the use of this Website and the Internet. The aforementioned purposes constitute AirPlus’ legitimate interests in the data processing. Find more information on the terms of use and data protection at www.google.com/analytics/terms/us.html and https://policies.google.com/?hl=en.

You may refuse the storage of cookies by adjusting your browser settings accordingly. In addition, you can object to Google’s collection and processing of data generated by cookies relating to your use of this website (including your IP address). To do so, please download and install the browser add-on. Opt-out cookies are used to prevent your data from being collected when you visit this Website in the future. To prevent Universal Analytics from collecting your data across devices, please set the opt-out cookie in all the systems you are using. Click the link to set the opt-out cookie: Deactivate Google Analytics.

Double Click

Our websites use the functions of Google Analytics Remarketing in connection with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This function enables the target groups created with Google Analytics Remarketing to be linked with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-related, personalized advertising messages that were adapted to you depending on your previous usage and surfing behavior on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

Once you give your permission, Google will link your web and app browsing history to your Google Account for that purpose. This way, the same personalized advertising messages can be delivered to every device you sign in to with your Google Account.

To support this feature, Google Analytics collects Google authenticated user IDs that are temporarily linked to our Google Analytics data to define and create cross-device ad targeting.

You can permanently object to cross-device remarketing/targeting by disabling personalized advertising in your Google Account by following this link: www.google.com/settings/ads/onweb.

The summary of the data collected in your Google Account is based solely on your consent, which you can submit or revoke to Google (Art. 6 par. 1 lit. a DSGVO). For data collection operations that are not merged into your Google Account (for example, because you do not have a Google Account or have opposed the merge), the collection of data is based on Article 6(1)(f) of the DSGVO. The legitimate interest arises from the fact that the website operator has an interest in anonymous analysis of website visitors for advertising purposes.

Further information and the data protection regulations can be found in Google’s data protection declaration at: www.google.com/policies/technologies/ads.

HubSpot

This Website uses HubSpot, a web analyst service offered by HubSpot Inc. (Cambridge, MA 02141, U.S.A.). The software helps AirPlus analyze and measure user behaviour based on statistical evaluations and to improve its inbound marketing activities continuously. The software uses cookies (personalized cookies). You can object to the use of cookies by adjusting the respective settings in your browser. Find more information in Hubspot Inc.’s general terms and conditions and privacy statement available at http://www.hubspot.com/terms-of-service and http://www.hubspot.com/privacy-policy. If you want to prevent the HubSpot technology from collecting your data and AirPlus from processing this data, you can deactivate the function here (when you click the link, an opt-out cookie will be downloaded and installed automatically). HubSpot Inc. is bound by the EU-US Privacy Shield Framework and is in compliance with European data protection laws.

Hotjar

AirPlus uses Hotjar to gain a better understanding of its customers’ needs and to optimize its services continuously. Hotjar is a technology service that helps AirPlus to better understand its users’ experiences, for example, the time they spend on which pages or the links they click. This user feedback helps AirPlus improve this Website continuously. AirPlus uses Hotjar’s services including heat maps, visitor recordings, funnels and form analysis. Hotjar uses a tracking code and a cookie to receive data concerning the behaviour of AirPlus’ users and their devices. The following information is captured through Hotjar’s tracking code: the device’s IP address (captured and stored in an anonymized form only), size of the device’s screen, type of device (unique device codes), browser information, geographical location (country only) and the language preferences for displaying this Website. Hotjar saves this information in a pseudonym user profile. Hotjar does not associate this information with visitors to this Website. Instead, Hotjar shows the behaviour of visitors to this Website. Hotjar or AirPlus will not use this information to identify individual users or match it with other data concerning individual users. For details, please go to Hotjar’s privacy statement available at https://www.hotjar.com/legal/policies/privacy.

You can object to Hotjar’s creating a user profile, saving data concerning your use of this Website and using tracking cookies on other websites by clicking https://www.hotjar.com/legal/compliance/opt-out.

b. Customer Portal

If you want to use additional functions, you can register for AirPlus’ Customer Portal. AirPlus will use the data you provide at registration for authentication purposes only. Please ensure the mandatory information requested during the registration process is complete; otherwise, AirPlus will reject your registration.

AirPlus will notify you about important adjustments to its offerings, for example, or necessary technical adjustments by sending you an e-mail to the address you provide at registration.

c. Identification Portal

When you use AirPlus’ Identification Portal, AirPlus processes only the data you enter into the Identification Portal to meet its obligations under anti-money laundering laws, namely to identify the person acting on behalf of AirPlus’ contracting partner when entering into an agreement or to prevent money laundering and terrorism financing.

After you have entered your data and verified your e-mail address, a personal identifier (hereinafter, “PID”) will be created. The personal data provided by you will be stored in connection with the PID together with the additional data collected during identification by the entity you selected. If you enter into additional agreements with AirPlus in the future, entering your PID will suffice; you will not need to undergo the identification process again.

d. Contact form

On this Website you have the opportunity to communicate with AirPlus through a contact form. To be able to respond to your requests, AirPlus will collect the information you provided concerning the form of address, your last name, first name and e-mail address. If you provide your telephone number and check the Call-back box, AirPlus will be happy to call you in response to your requests. You are free to provide additional data to facilitate the allocation and processing of your requests by AirPlus.

All data collected in contact forms will be used exclusively to respond to your requests. To this end, your requests along with your data may have to be forwarded to the AirPlus company in charge of supporting you as a customer.

If you submit a request via a contact form, AirPlus will save the information you provide in the form, including your contact information, to process your request and, if applicable, to answer any follow-up questions you may have. AirPlus will not disclose this data to third parties.

e. Newsletter

You can subscribe to the AirPlus Group’s newsletter in the Newsletter section of this website.

The AirPlus Group’s newsletter provides you with

  • the latest information about AirPlus’ services and products;
  • news including about trends concerning the travel and payment services industries;
  • information about and invitations to selected events (trade fairs, customer events, training, etc.) hosted or attended by AirPlus;
  • invitations to participate in market research and/or customer surveys; and
  • invitations to participate in Webinars.

AirPlus processes the data you provide for dispatching AirPlus Group newsletters to you only with your consent. Your consent applies to the processing of personal data you provide including, but not limited to, your

  • e-mail address;
  • last and first name;
  • title, gender/form of address; and
  • newsletter language preference.

AirPlus uses the double opt-in process to confirm your subscription and your consent. AirPlus saves your confirmation as documentation and proof of your consent.

Your consent is obtained so AirPlus can process your personal data to dispatch the AirPlus Group newsletters and can customize the newsletters to meet your needs. To enhance its newsletter service continuously and to provide you with content tailored to your interests, AirPlus will evaluate your use of the newsletters in a statistical and individual manner (e.g., open and click rates). This means, for example, that AirPlus can obtain information regarding your special interests from the content on which you click in the AirPlus Group newsletters.

The AirPlus Group reserves the right to discontinue its dispatch of newsletter at any time.

If you participate in Webinars, your consent includes your agreement to the statistical and individual evaluation of your participation in any Webinars in which you do participate including, without limitation, how much attention you pay to the material offered and your level of satisfaction. This means AirPlus can determine at what time you leave the Webinar. Also, AirPlus can detect at any given time whether you are participating in the Webinar actively in a separate window or whether the Webinar is running in the background. Based on the results, AirPlus can determine when a Webinar participant’s interest diminishes. AirPlus uses this information to improve the contents, structure, and design of its Webinars continuously.

You can revoke your consent at any time with immediate effect. To do so, please note the information in the section titled Revoking your consent.


How long will your data be stored?

Your personal data will be erased once it is no longer needed for the purpose intended. Subject to legal regulations, AirPlus will store your data until the legal retention period expires. Depending on the legal basis, retention periods typically are between six and 10 years. In addition, your data will be stored until the legal statute of limitations expires (typically, three years) provided storing your data is required for asserting, exercising or defending legal claims. After this date, the respective data will be erased routinely.


Which recipients will your data be shared with?

Your personal data may be shared with persons in the categories specified below for the purposes described in this Privacy Statement and for the respective legal reasons (fulfilment of agreements, legitimate interests, consent, or legal obligations):

1. Data processors

Carefully selected partners who deliver services on behalf of AirPlus will be involved in the processing of your data. These service providers only will handle your personal data as data processors on behalf of AirPlus and according to AirPlus’ instructions.

AirPlus uses service providers in the following categories:

  • IT services providers (hosting and web infrastructure services) in Europe;
  • service providers for customer relationships (call center services, online advertising) in Europe and the United States; and
  • service providers for compliance with anti-money laundering regulations (anti-money laundering audits) in Europe.

For details regarding the transmission of data to service providers located in countries outside the European Union or the European Economic Area (hereinafter, “Third Countries”), please refer to the section titled Transmission of your data to Third Countries.

2. Third parties

AirPlus also may share your personal data with reliable third parties that support AirPlus with the provision of this Website, the Customer Portal, the Identification Portal and contract documents provided these third parties undertake to treat your personal data confidentially and to comply with the GDPR.

In addition, AirPlus may share your personal data with third parties in the following categories:

  • external auditors in the case of audits or investigations due to legal obligations or legitimate business interests;
  • external attorneys or courts as part of the assertion of legal claims;
  • authorities (e.g., Federal Financial Supervisory Authority and/or other national financial market supervisory authorities, financial authorities, the Bundeszentralamt für Steuern (Federal Central Tax Office) and/or other national tax authorities) to comply with the applicable laws; and
  • all of the AirPlus Group and the Lufthansa Group.

3. Transmission of your data to Third Countries

Your personal data will be transmitted to Third Countries only within the scope required to meet the respective purposes (e.g., reporting obligations under tax laws). Before personal data is transmitted to a processor or a third party in a Third Country, AirPlus will ensure that a GDPR-compliant transmission mechanism is in place (e.g., the sample clauses regarding the transmission of personal data to Third Countries provided by the European Commission). To obtain a copy of the applicable guarantees, please contact AirPlus at the information available under Contact at the end of this Privacy Statement.


What are your rights regarding data protection?

1. Data subjects’ rights

Every data subject has the right to information under Article 15 of the GDPR, the right to correction under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restrict the processing of data under Article 18 of the GDPR, the right to object under Article 21 of the GDPR (find more information in the section titled Your right to object under Article 21 of the GDPR), the right to portability of data under Article 20 of the GDPR, and the right to lodge a complaint with a supervisory authority under Article 77 of the GDPR, in particular, the supervisory authority responsible for your habitual residence or your country or the supervisory authority responsible for AirPlus named below:

Data Protection Officer of the State of Hesse
Gustav-Stresemann-Ring 1
65189 Wiesbaden
Germany
E-mail: poststelle@datenschutz.hessen.de
Telephone: +49 611 1408 – 0

If you wish to exercise your rights, please contact us at:

Lufthansa AirPlus Servicekarten GmbH
Data Protection Officer, JX JDO
Dornhofstraße 10
63263 Neu-Isenburg
Germany
E.mail: dataprotection@airplus.com


How can you revoke your consent?

You can revoke your consent to AirPlus processing your personal data at any time. Please note that your revocation will apply to the future only and will not concern any past activities or processing.

To revoke your consent to receiving AirPlus’ newsletter, please click on the Unsubscribe link included in each newsletter. In addition, you can contact AirPlus at the information indicated below under Contact.


Your right to object under Article 21 of the GDPR

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Article 6 1 f) of the GDPR, including profiling based on those provisions. Your objection notice does not need to be in a specific form. Please contact AirPlus at the information indicated below under Contact.


Social media functions

This Website includes several social media functions including, but not limited to,

  • functions you can use to forward or recommend AirPlus-related content (e.g., Share and Like buttons); and
  • links from AirPlus’ offerings to social media, for example, when you log into your personalised section on this Website (hereinafter, “Social Login”).

As part of its online offerings, AirPlus offers you the opportunity to distribute and recommend content in social media. When you visit this Website and use the recommendation functions, AirPlus will share the URL with the social media you selected.

This Website includes the following social media plug-ins equipped with the two-click solution:

  • Facebook
  • Twitter
  • YouTube
  • Xing
  • LinkedIn

With the two-click solution, your data will not be transmitted to the respective social media network company until after the respective plug-in button has been activated (consent).

To this end, this Website uses the social sharing button developed as part of c’t magazine’s Shariff project to protect visitors’ privacy against prying social media such as Facebook, Twitter, YouTube, Xing or LinkedIn. To share pages with friends, visitors only need to click on the Shariff button.

Thanks to the Shariff button you can use social media without unnecessarily compromising your privacy. Shariff replaces the conventional share buttons offered by social media and protects your browsing behaviour from prying eyes. Nonetheless, you only have to click the button if you want to share information.

Conventional social media buttons transmit your user data to the social media every time you access their pages and provide precise information regarding your browsing behaviour (user tracking) even if you are not logged in or have joined the respective social medium. In contrast, the Shariff button only establishes direct contact between the social medium and you, the visitor, when you actively click the button. In this way, Shariff prevents you from leaving a digital trace on every page you visit.

Please note that AirPlus has no knowledge of or influence on how social media handle information you shared and whether this information is provided to other websites. AirPlus suggests that you read the respective data protection notices carefully.


Who can you contact?

If you have any questions regarding data protection in connection with this Website or the services offered through this Website, please contact AirPlus’ Data Protection Officer at

Lufthansa AirPlus Servicekarten GmbH
Data Protection Officer, JX JDO
Dornhofstraße 10
63263 Neu-Isenburg
Germany
E-mail: dataprotection@airplus.com

If you contact us by e-mail, your communications will not be encoded.

In addition, you can contact AirPlus via the contact form or AirPlus’ social media pages.

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