Privacy statement of the Miles & More programme

Transcription

1 Privacy statement of the Miles & More programme We know just how important the protection of your personal data is for you. It is a high priority for us to gain your trust by the careful and responsible treatment of your personal data. In this privacy statement we explain to you what information is collected, processed and used in connection with your participation in the Miles & More customer loyalty programme ( Miles & More ). The operators and publishers of Miles & More are Miles & More GmbH ( MMG ) and Deutsche Lufthansa AG ( Lufthansa ). Unless stated otherwise in this privacy statement, We refers to Lufthansa and MMG as the bodies responsible for the collection, processing and use of your personal data within the meaning of the Federal Data Protection Act ( BDSG ). Complete information relating to these companies can be found in their respective imprints at and Information about contacting the LH Group data protection officer can be found at the end of this privacy statement. 1. Master data When you apply to participate in Miles & More, we collect some of your personal data in the application form. Specifically these are your last name, first name, sex, address, date of birth, address and a telephone number. Furthermore, along with your application or in the course of your membership of Miles & More, you can communicate other data to us of your own volition, for example, a mobile telephone number, your preferred language for correspondence or other interests or preferences. These data you provide are referred to by us as Master Data. During your membership, this Master Data will be used primarily to clearly identify you as a member. 2. Miles & More card number When you open your mileage account we provide you with a Miles & More card number. The Miles & More card number will be assigned to your Master Data; it also serves to clearly identify you as a member. 3. Programme Data When you earn or redeem miles in the context of Miles & More, we record the so-called Programme Data. When you earn miles, the Programme Data collects all the information required for mileage credit and the administration, ongoing development and marketing of Miles & More. In this case, these

2 data include the operator, joint operator or Miles & More partner company where you earn miles, as well as information relating to the services from which the mileage credit originated. When you give your Miles & More card number to an airline to earn miles, the Programme Data also collects other information relating to your booking, particularly information about flight routes, the flight date, the flight number, the airline operating the flight and the booking class. When you earn miles with another joint operator or Miles & More partner company, the Programme Data collects details of the requested services relating to miles (for example, goods and services from a joint operator or a Miles & More partner company). When you earn miles with the Miles & More credit card, the Programme Data collects details of the spending carried out with the Miles & More credit card with a trader. When you redeem miles, the programme data collects details of the awards requested (for a flight, the specific type of flight award, the flight route, the flight date and other information related to the booking, for another award, for example, the type of award, product information and the date the award was purchased), as well as the number of miles spent. By saving these data, we can ensure the effective tracking of account movements, detailed information when requested, and the rapid processing of any possible complaints you may make. 4. Status Data In order to manage the status assigned by the operators or joint operators (for example, Frequent Traveller, Senator or HON Circle Member), we also save data, which are required to manage this status, such as the kind of status or the number of Status or HON Circle miles earned by you ( Status Data ). 5. Treatment of your personal data We collect, process and use your personal data, for example, for master, programme and status data within the context of Miles & More particularly to process your application for membership of Miles & More, to be able to send you your Miles & More card and other information, enable you to earn and redeem miles, especially to be able to credit the miles earned by you with operators and Miles & More partner companies to your mileage account and to debit the miles used when you request an award. also allows us to check that when you earn miles, the correct number of miles is credited, and that when you debit the account for an award, the correct number of miles is calculated when you fulfil the appropriate criteria of your Miles & More status card, to be able to send you other information relating to your status, administer, continue to develop and market Miles & More. To do this, we only use summarised ( (aggregated) data,

3 be able to inform you about current extensions or modifications to Miles & More, be able to send you individual offers relating to Miles & More as long as you have given us separate permission to do so; in this case we can avoid sending you information which is not relevant to you, and as far as possible, avoid repeating past submissions we have already made to you (for example, on our website or in our app). 6. Data transmission in the context of Miles & More 6.1 Joint Operators The operators of Miles & More can appoint selected partner companies in certain countries which may market Miles & More as their own programme ( joint operator ). Joint operators are Adria Airways Air Dolomiti Austrian Airlines Brussels Airlines Croatia Airlines LOT Polish Airlines Luxair Swiss International Air Lines. In the following cases we may transfer data for the administration, ongoing development and marketing of Miles & More to the joint operators as their own programme: if you have registered with Miles & More via a joint operator; the Master Data, the Miles & More card number or a user name, as well as your Programme Data relating to the joint operator s services, may be passed to the joint operator. if the joint operator is an airline and your residence is located within the home market of this joint operator, we may pass on the Master Data, Miles & More card number and Programme Data to the joint operator. if the joint operator is an airline and you take flights operated by this joint operator, we may pass on your master data and programme data to the joint operator. if you have gained a status with a joint operator, in addition to the Master Data and the Programme Data related to the services provided by the joint operator, your Status Data may also be passed on to the joint operator. 6.2 Miles & More partner companies With Miles & More partner companies, which are not joint operators, data is only transferred if and insofar as you have requested a service via us from a Miles & More partner company (for example, an award).

4 6.3 Lufthansa Group Airlines Airlines within the Lufthansa Group (as listed at have combined their customer loyalty activities. The member s Master Data and the Status and Programme Data obtained by a Lufthansa Group airline are managed in a joint database for all Lufthansa Group airlines. Without your separate consent (see also clause 7), these data may be processed and used in an anonymised form (that is, with no possibility of a particular member being identified) for analysis purposes, and for the management, ongoing development and marketing of Miles & More. 7. Consent We can give you the option of giving us separate consent for receiving information from us about your mileage balance and our Miles & More newsletters, the combined offers we have put together for you to earn and redeem miles in exchange for services from operators, joint operators and Miles & More partner companies, market research questionnaires to improve Miles & More and offers from operators, joint operators and Miles & More partner companies or issuing information put together for you regarding offers from individual operators, joint operators and Miles & More partner companies. This kind of consent can be granted by you, for example, in your application to participate in Miles & More, on our website, or in a Miles & More communication medium or another advertising medium. If you have given your consent, we can analyse your Master and Programme Data and the analytical data collected if you make use of our offers (for example, our websites, app, newsletter or means of communication) in order to send you relevant, personalised information to suit your interests. We will only collect, process and use other personal data from other sources such as websites operated by third parties for the compilation of personalised information if you have given the corresponding consent to do so. You can customise your communication settings in your customer profile at or wholly or partly revoke your consent from Miles & More GmbH (for example, at the Miles & More Service Centre, in writing to the address provided in the legal notice of our website or to the LH Group data protection officer (contact details provided at the end of this privacy statement). Please note that, should you revoke your consent, you will not receive any further information from us (with the exception of information of legal relevance to the Miles & More programme) and you will have to inform yourself in your customer profile about your mileage account balance (including early warnings of mileage expiration). 8. Miles & More credit card When you apply for a Miles & More credit card, the issuing bank will collect more personal data (for example, job, marital status and income) These supplementary data will be processed and

5 used exclusively by the issuing bank, and are not transferred to the operator or the joint operator. We only receive the Programme Data arising from the use of the Miles & More credit card and your Miles & More card number or other data for assigning the Programme Data to you as Master Data, which are required to be a member. If you have given the issuing bank comprehensive consent to do so, the issuing bank can also pass on your other personal data to us. 9. Miles & More website, app and communication media More information about the treatment of (personal) data collected via our website, app or our online communication media can be found in the separate privacy statement for the website, app and communication media at Access, corrections Upon request, we are happy to inform you whether your personal data have been saved and, if so, which data. If, despite our best efforts to ensure that the data saved are accurate and up-todate, incorrect information is stored, we will correct it at your request. In your customer profile on our website, you can check the current status of the majority of your Master Data yourself. Please update your personal data immediately after any changes occur (for example, your postal address, address or telephone number). 11. Data security We use technical and organisational security measures to protect your data that we process against accidental or deliberate manipulation, loss, deletion or access by unauthorised persons. Our security measures are being improved continuously as new technology develops. We store your personal data on servers in Germany, in a European Union member state or in states which are a party to the Agreement on the European Economic Area. When service providers are used, personal data may also be communicated to other countries in compliance with the applicable data protection regulations. 12. Updating We check this privacy statement regularly and we will update it as necessary. Where there are significant changes made to our data protection policies, we will inform you (for example, on our website or in our app). 13. Data protection officers The Lufthansa Group data protection officer is also the data protection officer for Miles & More GmbH. If you have questions about data protection at Miles & More, please contact Dr. Barbara

6 Kirchberg-Lennartz (for example, by post: Group data protection officer, FRA RD, Frankfurt/Main or by