Brussels Airlines Privacy Policy long notice

1. GENERAL PROVISIONS

1.1 Introduction

The protection of your personal data is of particular importance for Brussels Airlines.

This Privacy Policy applies to the personal data that we process about you as a natural person when you use our services and/or our products, when you visit our website or when you use our mobile app.

Brussels Airlines NV / SA with registered office at 1050 Brussels (Belgium), Jaargetijdenlaan 100-102/B30 Av. des Saisons, RPR/RPM Brussels (company number 0445692234) is the ‘controller’ for the processing of your personal data.

1.2 Contact

If you have any questions about this privacy policy or privacy at Brussels Airlines, you can contact our Data Protection Officer either by mail:
BRUSSELS AIRLINES
DATA PROTECTION OFFICER
AIRPORT BLD 26, GENERAL AVIATION – RINGBAAN
1831 MACHELEN
BELGIUM

Alternatively, by e-mail at privacy@brusselsairlines.com.

1.3 Updates

We regularly review our privacy policy and we will update it as needed. We will inform you about significant changes (for example on our website).

2. RIGHT OF CUSTOMERS

You can exercise the following rights by contacting us (See Contact section), in accordance with the conditions laid down in the applicable legislation:

  • You have the right to withdraw your consent for the processing of personal data, to the extent that the processing of your personal data was initially based upon your consent.
  • You have the right to obtain from us confirmation as to whether or not we process your personal data, and, where that is the case, you have the right to obtain a copy.
  • You have the right to obtain the rectification of inaccurate personal data.
  • You have the right to have incomplete personal data completed.
  • You have the right to erasure of your personal data if one of the following grounds applies:
    • Your personal data are no longer necessary in relation to the purposes for which they were collected or processed;
    • You have objected to the processing for direct marketing;
    • You have objected to the processing which is based on our legitimate interest;
  • We are not obliged to comply with your request for erasure in the following cases:
    • We have a legal obligation which requires the processing of your personal data;
    • The processing is necessary for the establishment, exercise or defense of legal claims.
  • You have the right to obtain restriction of the processing:
    • If you contest the accuracy of your personal data, for the period we need to verify the accuracy of your personal data.
    • If we no longer need your personal data, but you require them for the establishment, exercise or defense of legal claims.
    • If you have objected to the processing based on our legitimate interests, for the period we need to verify whether your legitimate grounds are valid.
  • You have the right to object to any processing for direct marketing.
  • You have the right to object to any processing based on our legitimate interest. However, we will continue the processing of your personal data if we can show that we have stronger legitimate grounds.
  • You have the right to seek the portability of your personal data processed by automated means, which you have communicated to us.
  • You also have the right to lodge a complaint with the supervisory authority in the European member state of your habitual residence, place of work or of the alleged infringement of applicable data protection legislation:

3. PROCESSING OF PERSONAL DATA

3.1 Why do we process your personal data?

The purposes for which we process your personal data depend on how you enter in contact with us.

A. You surf on our website

We process information about your device and about your use of our website, for the purposes:

  • Of information security (to for example ward off cyber-attacks),
  • For management of our website (to for example enable you to access the website from your device and to remember your choices),
  • For the better understanding of your needs and continuous improvement of our website, and for marketing.

This processing is based upon our legitimate interest. It is in our and your best interest to increase the efficiency of our website and to optimize our products and services.

We refer to our policy regarding cookies for more information about this.

B. You contact us

We process your personal data in order to answer and manage your request (e.g. request for information, subscription to our newsletter). This processing is based on your consent.

C. You purchase our products or services

We process your personal data for client management in order to provide you our products or services. Without your personal data, we cannot provide you the product or service you have purchased.

We process your personal data for passenger management, such as:

  • The ground management of passengers (at airport, during aircraft boarding, ticket reservation, luggage management), based upon our legal obligation.
  • Flight document preparation, based upon our legal obligation.
  • Issuing of passenger information lists for our cabin crews, based upon the performance of the contract to which you are a party. Without your personal data, we cannot perform this contract.
  • Administration of Visa and documents to enter specific countries, based upon the performance of the contract to which you are a party. Without your personal data, we cannot perform this contract.

We process your personal data for incident monitoring on flights, based upon our legal obligation.

We process your personal data for the management of claims, based upon our legitimate interest. It is in our interest to protect ourselves against material and immaterial damages. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see chapter “Rights of Customers”).

We process your personal data for the direct marketing of our products and services, based upon our legitimate interests. We believe that it is important to keep you, as our client, informed about our products and services. This processing involves compiling a profile. This profile has no effect on you, except to the extent that this processing activity might lead to the enhancement of customer experience and personalized offers, which is an advantage to you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see chapter “Rights of Customers”).

We process your personal data for following up on your solvency, based upon our legitimate interest. It is in our interest to strive for cost optimization (control and minimization) and to protect ourselves against damages. This processing may involve a profiling with the consequence that you may not be able to complete the purchase. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see chapter “Rights of Customers”).

We process your personal data for fraud prevention, based upon our legitimate interest. It is in our interest to protect ourselves against material and immaterial damages and to prevent unlawful activities and abuse of our products/services/resources. This processing may involve a profiling with the consequence that you may not be able to complete the purchase. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see chapter “Rights of Customers”).

We may aggregate your personal data and process such aggregate data for research and development, based on our legitimate interests (e.g. statistics about sales, market analysis, development of products/services). We believe that research and development can lead to enhancement of customer experience and improvement and innovation of our products/services, which will help the persons concerned by our products/services. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience, improvement and innovation of our products/services, which is an advantage for you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see chapter “Rights of Customers”).

3.2 With whom do we share your personal data?

We may transfer your personal data to our affiliates and commercial partners and to companies that process personal data in our name and on our behalf (known as ‘processors’):

  • Service providers in the field of ground handling, transport, marketing, customer feedback, IT, payment services and credit reference agencies,
  • Platforms for sending newsletters,
  • Operators of live help chats,
  • Companies of the Lufthansa Group,
  • Airlines outside the Lufthansa Group,
  • Partner companies for providing services such as hotel bookings, insurance services, car rentals,
  • Government agencies and authorities.

In accordance with the Belgian law on the use of passenger data, we are obliged to transfer certain passenger data to the Belgian government. More information can be found on https://crisiscentrum.be/nl/inhoud/passenger-name-record.

Fraud and Unruly Passengers controls

"Unruly Passengers" means passengers who show improper, aggressive or violent behavior towards other passengers or the crew or damage the aircraft.
Brussels Airlines is entitled to exchange personal data of its passengers within the Lufthansa Group as well as with other airlines for the documentation, analysis and prevention of fraud cases and "unruly passenger cases" and to process them in this regard.
In addition, if you have damaged or injured other passengers, Brussels Airlines may also disclose your personal data and information relating to the injury or injury to other third parties (such as public authorities, injured persons and insurances).

3.3 Are your personal data transferred outside the European Economic Area?

If you have booked a flight to a country outside the European Union for which there are no appropriate safeguards regarding your personal data, we are allowed to transfer your personal data to this country, as this is necessary for the execution of the contract with you (article 49.1 (b) GDPR).

Besides these aforementioned transfers of your personal data, we also transfer your personal data to countries outside the European Union as some of our affiliates, commercial partners or processors are established outside the European Union. Each transfer outside the European Union is based on appropriate safeguards (adequacy decision and/or standard data protection clauses of the European Union. You can contact us (see ‘”chapter Contact”) in order to obtain more information on the appropriate safeguards that we have taken for these transfers.

3.4 For how long is your personal data retained?

Your personal data is retained for as long as you are in contact with us and as long it is needed as required by law or to ensure the service we provided.


Last update: May 2018