DATA PROTECTION POLICY LOOP

Version 1.0

This policy applies to the personal data that we process about you as a natural person when you participate in the LOOP loyalty program. This policy does not apply if we process anonymous or business data.

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

We process your personal data for the following purposes:

  • to reward you with special offers and special needs if applicable (if you are a good customer of Brussels Airlines);
  • to send you our newsletters, including information on your membership status;
  • for the direct marketing of our products and services. This processing may involve compiling a profile.

You can exercise the following rights, in accordance with the conditions laid down in the applicable legislation:

  • withdrawing your consent for the processing of personal data, to the extent that the processing of your personal data was initially based upon your consent.
  • seeking access to, or any correction, or restriction of your personal data.
  • seeking deletion of your personal data if one of the additional grounds applies.
  • objecting to any processing for direct marketing.
  • seeking the portability of your personal data, which you have communicated to us and that we have processed based on your consent.
  • lodging 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.

If you wish to know more about how we process your personal data when you participate in the LOOP loyalty program, you can read our complete LOOP loyalty program data protection policy hereunder.

 

Who processes your personal data?

We are Brussels Airlines NV / SA, with registered office at 1050 Brussels (Belgium), Jaargetijdenlaan 100-102/B30 Av. des Saisons, RPR/RPM Brussels (company number 0445692234).

We are the ‘controller’ for the processing of your personal data.

 

Contact details of our Data Protection Officer

If you have any questions about this privacy policy, privacy of Brussels Airlines, and/or questions about processing of your personal data within the LOOP loyalty programme, you can contact our Data Protection Officer:

  • by regular post: Brussels Airlines Data Protection Officer, Brussels Airlines, Airport Building 26, General Aviation Zone – Ringbaan, 1831 Diegem;
  • by e-mail: privacy@brusselsairlines.com

What do we expect from you?

We expect that you only communicate personal data about yourself to us. If you also communicate personal data about other people to us, then you must ensure that you are entitled to do so.

We also expect that the personal data that you communicate to us is correct and that, if specific personal data changes, you promptly inform us of this change.

Why do we process your personal data?

We process your personal data for the following purposes:

  • to reward you with special offers and special needs if applicable. This processing is based on legitimate interest as an outcome of an execution of the contract.
  • To send you our newsletters, including information about your membership status.
  • We also use cookies as unique identifiers that we transfer to your device to enable our systems to recognise your device and to provide features such as identifying you when sign-in to our website. This allows us to recognise you as a LOOP member with an account.
  • for the direct marketing of our products and services, based upon our legitimate interest or your consent, as the case may be. 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 ‘What are your rights’).

With whom do we share your personal data?

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

  • 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,
  • Government agencies and authorities.

Is your personal data transferred outside the European Union?

We do not transfer your personal data to other companies outside the European Union. We might share your personal data within Brussels airlines activities with presence outside the EU to facilitate the use of your LOOP membership, including call centers. Each transfer outside the EU is based on appropriate safeguards.

For how long is your personal data retained?

Your personal data is retained for as long as you are a participant in the LOOP Program and for up to maximum ten years after the end of your LOOP Program Participation to fulfil retention periods under commercial and tax law and to retain evidence as part of the provisions on limitation periods. If you choose to opt out from the programme communication emailing, we will no longer hold your data for such purposes.

 

What are your rights?

You can contact us to exercise the following rights, 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. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • 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 of the personal data undergoing processing.
  • 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;
    • We process your personal data unlawfully;
    • Your personal data have to be erased for compliance with a legal obligation.
  • We are not obliged to comply with your request of erasure in the following cases: 
    • The processing of your personal data is necessary for exercising our right of freedom of expression and information;
    • 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 process your personal data unlawfully, instead of the erasure 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.
  • You have the right to seek the portability of your personal data processed by automated means, which you have communicated to us in the context of a processing based on consent or based on the execution of the contract.
  • You have the right to object to any processing for direct marketing.

You can exercise these rights by contacting us at the address stated in the section ‘Who processes your personal data’ or by contacting our Data Protection Officer (‘Contact details of our data protection officer’).

Belgian Supervisory Authority

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.

In Belgium the supervisory authority is:

Last update: September 2018