Privacy Statement of the SkyPriority Panel App
SkyTeam Airline Alliance Management Coöperatie U.A., a company registered in Amsterdam, the Netherlands (Chamber of Commerce registration number 34345101), whose address for visitors is at (1180 AJ) Amstelveen at Amsterdamseweg 55 (“SkyTeam”, “us”, “we”), is a global airline alliance that coordinates and provides commercial activities on behalf of and – to some extent – together with the SkyTeam Member airlines (Members) in the aviation industry. When you use this SkyPriority Panel App, it is important to us to process your personal data carefully and securely in a transparent manner. The processing of your personal data is subject to the rules of the General Data Protection Regulation (EU) 2016/679 (GDPR), and potentially to one or more EU member states’ national implementation acts of the GDPR, as well as the data protection laws and regulations of other countries (if applicable). This Privacy Statement serves to comply with our transparency obligations under the GDPR, namely to explain to you when we collect your personal data in the capacity of a controller under the GDPR, what personal data we collect, how we use such personal data, and how long we keep your personal data.
1. Who is responsible for the processing of your personal data?
SkyTeam is the controller, within the meaning of the GDPR, of the processing of your personal data indicated in this Privacy Statement.
Note that InSites Compages NV, with registered office at Evergemsesteenweg 195, 9032 Ghent (Belgium) and registered with the Crossroads Bank for Enterprises under the number BE0837.297.070 (hereinafter “Human8”) is acting on SkyTeam’s behalf as a data processor when carrying out market research activities relating to SkyTeam products and services, including SkyPriority and lounges.
As a data processor for SkyTeam, Human8 undertakes to respect the applicable data protection legislation and more specifically the GDPR.
Furthermore Human8 is a member of the European Society for Opinion and Marketing Research (“ESOMAR”), an international organisation that focuses on developing better market research methods and adheres to the professional standards which ESOMAR sets out for its members.
2. Processing of data: what, when, why, how and for how long?
| When do we collect personal data? | What personal data do we collect of you? | Why do we collect this personal data? | Legal ground for using your personal data? | How did we obtain your personal data? | How long do we retain your information? |
| If you participate in market research activities via the SkyPriority Panel App |
– Identification data: name, username, gender, age, country of residence, electronic identification data (such as IP address, cookies) – Contact data: email address. – Location data: mobile phone location (if enabled) – Flight information (date, route, airline, flight number) – Image recordings: photos, videos – Lifestyle and habits. – Other information provided by you. |
– To perform customer surveys to analyse and optimize our services and products. – To possibly provide a prize after you have indicated that you want to participate in the prize draw. – To get into and maintain in contact with you, including for direct marketing purposes. – To comply with legal obligations, a court order or to exercise or defend legal claims. |
Consent: – We will process your personal data if you provided your consent to participating to the market research activity. – You can withdraw your consent at any time, by contacting us. Withdrawing your consent will not affect the lawfulness of our use of your personal data before your withdrawal. Legitimate interests: – We may process your information as necessary for achieving our legitimate interests when performing our market research activities. For our interests we may for example gather, analyse and interpret information about our customers to find new opportunities to sell and develop products and services to satisfy the preferences and needs of our customers. |
– From yourself. – Third parties engaged by us in the context of customer research, such as Members or Human8. – Other third parties in incidental cases. |
– We will retain your personal identifiable data (name, email address, contact information) for the duration of time in which your account remains active. If you choose do delete your account, personal identifiable data will be deleted to anonymize the account. – All data previously provided in the SkyPriority Panel App will be retained, however this can never be linked back to your personal identifiable information. – In some cases, we may retain your data longer than is necessary for the purposes for which they are used, for example when we are legally obligated to retain personal data longer or when it is necessary regarding legal claims. |
| If you visit our SkyPriority Panel App | If you visit our SkyPriority Panel App, various cookies and similar technologies (hereinafter: “cookies”) are used. We only use functional and analytical, cookies and no personal data will be processed. |
– For the functioning and optimization of the SkyPriority Panel App – To generate user statistics and to further analyze your SkyPriority Panel App usage
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– The legal ground for processing your personal data through the functional and privacy-friendly analytical cookies is our legitimate interest to make our SkyPriority Panel App work properly. – For all other types of cookies, we will ask your consent via the “cookie banner”, which will be displayed when you visit the privacy statement page and/or the terms and conditions from our SkyPriority Panel App. |
– No personal data is being processed or collected. | – No personal data is being processed or collected. |
3. How do we transfer your personal data outside the EEA?
The processing of your personal data may entail the transfer of your personal data to a third country that does not provide the same level of protection as within the European Economic Area (EEA). This may be the case if we share your personal data with our Member airlines or with selected other third parties, with whom we have partnership agreements.
Where applicable, we have taken appropriate safeguards to transfer your personal data to a country located outside the EEA, if that country does not provide an adequate level of protection according to the applicable data protection laws, by relying on adequacy decisions issued by the European Commission or by entering into standard contractual clauses approved by the European Commission (with supplementary measures to the extent required). You can contact us if you would like to receive more information on the measures we have taken to safeguard your information in this respect.
4. How do we protect your personal data?
We are committed to ensuring that your personal data is kept secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate physical, technical and organizational measures to safeguard the information we collect and process.
5. What are your rights?
As a data subject, you have certain rights concerning our processing of your personal data. You may:
- Request access to your personal data. You have the right to ask us if we are processing your personal data, and, if so, provide you with a copy of that personal data.
- Request correction of your personal data. You have the right to rectify your personal data, if you believe that the personal data we have about you is incomplete or inaccurate. If we have shared your personal data with others, we will also inform them of the correction where possible.
- Request erasure of your personal data. You have the right to ask us to delete or remove your personal data in some circumstances. If we have shared your personal data with others, we will inform them of the erasure where possible. Due to the way we maintain certain services, it may take some time before backup copies are erased.
- Request to restrict our processing of your personal data. You have the right to ask us to block or suppress the processing of your personal data in certain circumstances, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted. If we have shared your personal data with others, we will inform them of the restriction where possible.
- Request to exercise your right to data portability. You have the right to obtain personal data you have provided to us in a structured, commonly used and machine-readable format in certain circumstances. This way you can use your personal data elsewhere or you can also ask us to transfer your personal data to a third party. Upon request and where this is technically feasible we will transmit your personal data directly to the other controller.
- Object to the processing of your personal data. You have the right to ask us to stop processing your personal data, if we are relying on legitimate interests to process your personal data, except if we can demonstrate compelling legal
In case of profiling as a purpose, it is not intended to have legal effects that would significantly affect the data subject. The consequences of this purpose is to categorize individuals in a general way for marketing purposes.
6. Our contact details
You may send us a request using the contact details below. We will handle your request carefully and in line with the applicable data protection rules.
Any privacy related questions, data subject requests and/or complaints can be addressed to the Human8 DPO:
- Via e-mail: dpo@wearehuman8.com
- Via telephone: +32 (0)9 2691500
- Via postal mail: attn. Human8 DPO, Evergemsesteenweg 195, B-9032 Wondelgem, Belgium.
You can also contact us directly if you have any questions:
SkyTeam Airline Alliance Management Coöperatie U.A.
Postbus 350
1180 AJ AMSTELVEEN
THE NETHERLANDS
skypriority@skyteam.com