Data Privacy Statement
Data Privacy Statement
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We are delighted that you have visited our website, where we offer you not only information about our company and services, but also personalized features. We are committed to transparency and integrity in processing your personal data. In processing personal data, we comply with requirements under data protection law, in particular the EU General Data Protection Regulation (“GDPR”) and the German Federal Data Protection Act (“BDSG”).
In this Data Privacy Statement, we explain what information (including personal data) we process during your visit and use of our aforementioned internet offering on our website https://lufthansa-cargo.com and its subpages ("Website") and which rights you have in relation to your personal data.
I. Who is responsible for processing the data?
The party responsible for the processing of personal data under data protection law (the “Controller”) is Lufthansa Cargo AG, Frankfurt Airport - Gate 21, Building 322, D-60546 Frankfurt am Main, Germany (e-mail: firstname.lastname@example.org). Where the words “we” or “us” are used in this Data Privacy Statement, they refer to the above company.
We have appointed the Data Protection Officer of the Lufthansa Group as our company’s Data Protection Officer. If you have any questions regarding the processing of your personal data, you can contact the Data Protection Officer at any time by post (FRA CJ/D, Airportring - LAC, 60546 Frankfurt) or e-mail (email@example.com).
II. What principles do we observe?
In compliance with requirements under data protection law, we process personal data only if we are permitted to do so under a statutory provision or you have given us your consent.
On this Website we can also record items of information that, taken on their own, do not allow us to directly draw conclusions about your person. Nevertheless, this information may constitute “personal data” within the meaning of data protection law in certain cases, in particular if it is combined with other data. In addition, we may also record information on this Website that does not enable us to identify you directly or indirectly; this is the case, for example, with aggregated information on all users of this Website.
III. What data do we process?
You can access our Website without directly providing personal data (such as your name, postal address or e-mail address). In this case, too, we have to process certain information to enable you to access our Website. Moreover, on this Website we use certain analytics methods and have integrated links to other Websites whose operators may process further (personal) data. Finally, on our Website we offer you the use of various services for the performance of which we require personal data from you. These are mostly your contact data, which we collect either when you contact us or when you register as a user of our various services. In detail, we process personal data on our Website as follows:
1. Log files:
When you visit this Website, our web server automatically stores the domain name or IP address of the requesting computer system (usually your internet access provider), including the date, time and length of your visit, the sub-sites/URLs you visit, and information on the applications and devices you use to view our Websites.
3. Embedded videos:
4. Social media content ("Flockler"):
5. Links to other Websites:
Our Website contains links to other offerings (including our presence on Facebook, YouTube, LinkedIn and Instagram. These are not social plugins (i.e. buttons which enable the operator of the offering in question to collect information on our Website’s users when the Website is called). However, please note that when you call the other offering, information (possibly including personal data) on your visit may be collected by the operator of the other offering. You can find more information in the data privacy statements of the operators of the offering.
6. Means of contacts:
On our Website, we point out various ways you can contact us. If you use one of these ways, we process the information we ask for and/or you give us in order to handle your inquiry. If necessary, this information may be stored for a longer period of time after completion of the processing for reasons of preservation of evidence.
7. Registration and user account:
On our Website we offer you the possibility of registering as a user, in particular so that you can use our e-services. However, registration as a user can also be carried out by us at your request if you confirm this registration to us. Only employees, contact persons and representatives (jointly termed “Contact Person(s)”) of existing customers and business partners (jointly termed “Business Partner(s)”) can register. Please note that we do not permit registration by Contact Persons who are minors in our General Terms and Conditions or special terms and conditions for use of our e-services. During registration, we collect not only details of the Business Partner, but also personal data on the Contact Person as defined specifically in the registration mask. Obligatory information is indicated as such. We may ask you to enter the data collected during registration again (in particular so that you can be identified) and collect further personal data if you use certain content or features on our Website.
For the administration of your user account we use the Customer Relationship Management ("CRM") system Microsoft Dynamics 365. The provider of Microsoft Dynamics 365 is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For more information about how Microsoft Dynamics 365 works, see the Microsoft Privacy Statement, available at https://privacy.microsoft.com/en-us/privacystatement.
8. Our Services:
The use of the services offered by us ("Services") is possible with and without registration:
- Services for registered users: A large part of our Services can only be used by registered Contact Persons from our Business Partners. By registering, we give you the opportunity, in particular, to request offers from us, to place, change and delete orders, to initiate collection and after-sales processes, to make claims and provide feedback, and to call up information on current or already completed orders for the respective Business Partner within the framework of an existing business relationship. In addition, we can also proactively inform you about current orders and will do so in any case if there are certain irregularities in the course of the execution of an order. Depending on the type of Service, we may ask for further information, exceeding the personal data of the Contact Person that was collected during registration. This data is also as defined in the online screen(s) for the e-service in question; here too, obligatory data is indicated as such.
- Services for users who have not registered: In addition to the services for registered users, you can also use parts of our services without registration. For example, we also provide certain features, such as a consignment tracking application, outside the section of our Website where registration is required. As part of these features, we may not only ask for information related purely to the company or an order, but also personal data (for example the name of the user or contact information such as an e-mail address).
You can also book many of our services by telephone, e-mail or in person with us or our service providers. If you book one of our Services, we process the information you provide and confirm to us for this purpose in order to be able to provide the corresponding Services to you. The information provided is usually contact information, such as names, address or email addresses. After completion of the processing, your data will be stored by us for a longer period of time to facilitate a further booking for you and for reasons of preservation of evidence.
In connection with your order, we may also offer you the possibility to provide information about the recipient of the consignment that we transport or a possible accompanying person; this information can as well refer to natural persons (for example, the recipient himself or a specific Contact Person in a legal entity).
Please ensure that the persons you have named are informed of the processing of their personal data in connection with an order, as required by law.
9. Lufthansa Cargo Developer Portal:
On the Lufthansa Cargo Developer Portal we offer you the possibility to apply for a key, which allows you to access Lufthansa Cargo APIs. If you register for a Key, we process the information we request and/or the information you provide in order to process your request.
10. E-mail newsletter:
On our Website we may also offer you the possibility of registering for our e-mail newsletter. The necessary information is as defined in the registration form and usually comprises – as mandatory data – your title, your given name and surname, your company and your e-mail address. Mandatory information is indicated as such.
For the distribution of our e-mail newsletter, we use the Customer-Relationship-Management ("CRM") system Microsoft Dynamics 365. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.
11. Customer surveys:
If you have given us your consent, we may contact you as part of our annual or transactional customer surveys. As part of the annual customer surveys, which we conduct to improve our services, we receive your information in anonymized form and evaluate it accordingly. In the context of transactional customer surveys, however, we do not anonymize your data. In this case, we ask you about a specific transaction in order to be able to respond to your feedback in this case. In the context of customer surveys, the following personal data in particular will be processed: First name, last name, gender, e-mail address and, if applicable, your postal address.
12. Manage subscriptions / promotional consents:
In our Subscription Center, we offer you the possibility to take out subscriptions (e.g. for receiving our newsletters) and to give us your consent to receive promotional information, as well as to view your existing subscriptions and the given consents and to adjust them at any time. If you give us your consent to send you advertising information, we will, for example, inform you about our company, our products and our events or, if necessary, carry out customer surveys with you. In the context of subscriptions and promotional consents, the following personal data in particular will be processed: First name, surname, gender, e-mail address and, if applicable, your postal address.
As part of our eServices, we offer you as a registered user an online consultation in the form of a chatbot on our Website. A chatbot is a computer program that interprets written text and automatically responds to written requests. To the extent necessary to process your request, your personal data will be processed in this process. We use your personal data exclusively to be able to respond to your personal request.
We may also offer a live chat function. If you use the live chat function of our chatbot, your personal data and the chat history will be transferred to an employee or to an external service provider to answer your request. To identify a chat session, we use a pseudonymized session and user ID. For more information about these IDs, see our Cookie Information. Your entries in the input mask of the chat will be transmitted to us and stored in order to answer your request. In this respect, the same applies as under III.6 Means of Contact. Furthermore, we use the chat data to improve and optimize the chatbot by analyzing it, e.g. with regard to categories of requests, abandonment rate, requests that cannot be matched, etc.
IV. For what purposes and on what legal basis do we process your data?
- Personal data that may be contained in the log files is processed to enable you to use our Website; that is done on the basis of Section 15 (1) of the German Telemedia Act (TMG) and on the basis of Article 6 paragraph 1 point (f) GDPR so as to safeguard our legitimate interests in operating our Website.
- The data collected using necessary cookies and the pseudonymous user profiles are processed for the purposes of tailoring our Website to users’ needs on the basis of Article 6 paragraph 1 point (f) GDPR so as to safeguard our legitimate interests in the use of our Website. The data collected using optional cookies (cookies of the categories "comfort", "statistics" and "performance") and the pseudonymous user profiles are processed for the purposes of analyzing the Website, advertising, and market research on the basis of your consent and Article 6 paragraph 1 point (a) GDPR.
- The processing of the data collected through the playing of videos embedded on our Website and the use of the Flockler-Plugins is carried out for the purpose of using and designing our Website in accordance with the requirements of Article 6 paragraph 1 f) DSGVO to safeguard our legitimate interest in the operation of our Website.
- Personal data provided to us as part of an inquiry directed to us using the channels specified on the Website is processed to deal with the inquiry so as to safeguard our legitimate interests in conducting an existing business relationship or performing our other business activities on the basis of Article 6 paragraph 1 point (f) GDPR.
- Personal data of our Business Partners’ Contact Persons or other natural persons (recipient of the consignment or recipient’s Contact Person) that is collected as part of registration or use of a user account is processed so as to safeguard our legitimate interests in conducting existing business relationships on the basis of Article 6 paragraph 1 point (f) GDPR.
- The processing of personal data collected from you in the course of using our Services is carried out on the basis of Article 6 paragraph 1 b) DSGVO in order to provide the corresponding contractual services. The storage of this data beyond the provision of the respective service is carried out to protect our legitimate interest in the execution of existing business relationships or in the assertion of legal claims and the defense in legal disputes, in each case on the basis of Article 6 paragraph 1 f) DSGVO.
- The processing of the personal data collected from you within the scope of the application for a key on our Lufthansa Cargo Developer Portal is carried out to protect our legitimate interest in the execution of existing business relations on the basis of Article 6 Paragraph 1 f) DSGVO.
- Personal data provided as part of registration for a newsletter, or in your participation in a customer survey, or personal data provided as part of your registration to receive promotional information, is processed on the basis of your consent and Article 6 paragraph 1 point (a) GDPR. Please note that you can withdraw the consent you have given us at any time with future effect, for example by clicking on the relevant link in each newsletter or emailing we send, via the Subscription Centre, or by sending a letter, fax or e-mail using one of the contact channels specified in Section I. of this Data Privacy Statement (kindly also refer to Article X b) below).
- Personal data provided to us in the course of the use of our chatbot is processed in order to answer the question(s) posed there and to improve and optimize our chatbot so as to safeguard our legitimate interests in conducting an existing business relationship or performing our other business activities on the basis of Article 6 paragraph 1 point (f) GDPR.
- We can also process the personal data collected in connection with the use of our Website to comply with legal obligations to which we are subject; this is done on the basis of Article 6 paragraph 1 point (c) GDPR.
- Where necessary, we also process personal data above and beyond the above-mentioned purposes to safeguard further legitimate interests or the interests of third parties; this is done on the basis of Article 6 paragraph 1 point (f) GDPR. Our legitimate interests include
a. establishing legal claims and defending ourselves in legal disputes;
b. preventing and investigating criminal acts; and
c. controlling and further development of our business activities, including risk management and operation of our IT systems.
V. Do I have an obligation to provide data?
The particulars required for registration, the user account and the e-services, for registering for the newsletter and for ordering our customer magazine are indicated as mandatory details in the relevant section of our Website (e.g. an online form); if you do not provide these mandatory details, we cannot enable you to use the feature in question.
If we collect personal data from you above and beyond that, we notify you at the time whether the information has to be provided under the law or a contract or is necessary so that a contract can be concluded. We usually indicate information that is provided voluntarily and does not have to be furnished pursuant to one of the above obligations or is not required to conclude a contract.
VI. Who receives personal data?
In general, personal data is processed inside our company. Only specific departments/organizational units can access personal data, depending on its nature. They include in particular the specialist departments tasked with providing our digital offerings (e.g. Websites) or the described business processes, and our IT department. A role and authorization concept restricts access at our company to the functions and the scope required for the purpose for which the data is processed.
We may also transfer personal data to third parties outside our company to the legally permissible extent. In particular, these external recipients may include
- affiliated companies in the Lufthansa Group to which we transfer personal data for internal administrative purposes and for the performance of central services (e.g. billing services);
- those third parties we use to provide our services (e.g. to carry out flights or load and unload cargo), insofar as the transfer is necessary to fulfil the contracts concluded with us, such as ground handling service providers at the airports we operate;
- service providers whom we have engaged (e.g. our transport-, IT-, CRM- or payment service providers etc. or partly also our ground handling service providers) and who, on the basis of a separate contractual agreement, provide us with services that may also involve processing personal data, as well as the subcontractors our service providers engage with our consent;
- non-public and public bodies (e.g. airports, customs or police authorities, etc.), where we are obliged to transfer your personal data pursuant to statutory obligations,
- recipients of a consignment we deliver for one of our Business Partners; the consignments may also contain personal data from you in individual cases if you have been named as the Contact Person in the provided consignment data;
- other Contact Persons at your organization if they are likewise registered to use our e-services; in this case, all Contact Persons within the organization of a Business Partner may be able to access details of all business transactions of that Business Partner (including information on your involvement in such a business transaction) using the e-services;
VII. Is automated decision-making used?
In principle, we do not use any automated decision-making (including profiling) within the meaning of Article 22 GDPR in connection with operation of our Website. If we use such methods in individual cases, we will notify you separately to the legally prescribed extent.
VIII. Is Personal data transferred to countries outside the EU/EEA?
In most cases, personal data is processed within the EU or the European Economic Area.
Since the Lufthansa Group operates globally and we also perform our services worldwide, we also possibly transfer information to recipients in what are termed “third countries”. “Third countries” are countries outside the European Union or not party to the Agreement on the European Economic Area where it cannot be readily assumed that they have a level of data protection comparable to that in the European Union. Recipients in third countries may be, for example, service providers we engage (such as our call center) or the foreign offices of our own we run as part of our international presence, but also non-public and public bodies (e.g. airports, customs or police authorities, etc.), in case we are obliged to transfer specific information in the course of the provision of our services pursuant to statutory obligations.
If the transferred information also includes personal data and we do not have a legal obligation to disclose such data, we ensure before transferring it that the necessary adequate level of data protection is ensured in the third country in question or at the recipient in the third country. That may be based in particular on an “adequacy decision” by the European Commission, in which an adequate level of data protection is ascertained for a specific third country as a whole. Alternatively, we can transfer data on the basis of EU standard contractual clauses agreed with a recipient. For information about the EU Standard Contract Terms, click here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en, and for information about the adequacy decisions click here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en#dataprotectionincountriesoutsidetheeu.
IX. For how long is personal data stored?
In general, we store personal data according to article 17 GDPR only for as long as they are necessary for the purposes mentioned, or if we have legitimate interests in storing it and they are not overridden by your interests in your data no longer being stored. Subsequently, such data will be deleted in order to comply with the principle of data minimization.
Even if we have no legitimate interests, we can continue to store your data if we are required to do so by law (such as to comply with retention obligations). We erase your personal data, also without any action on your part, as soon as we no longer need to know it in order to fulfill the purpose of processing or storage of it is otherwise legally impermissible.
As a rule
- log data is erased within seven days, unless it needs to be stored further for purposes envisaged under the law, such as detection of misuse and the identification and rectification of technical faults;
- data processed in connection with a business relationship is erased no later than by the end of the statutory retention periods or the applicable limitation periods;
- data stored in connection with a registration as a user is erased when the customer account is deleted, unless further retention of it is required to comply with statutory retention periods in connection with the business relationship in question. If applicable, information (including personal data) is also erased before the customer account is deleted if a shorter period of time is envisaged in the respective e-service, if such shorter period can be defined by you or the Business Partner in question or if the purpose for further processing such personal data ceases to apply otherwise;
- your entries in the chatbot are automatically deleted after their analysis for the optimization of our chatbot as described above under III.14, at the latest after 6 months.
Personal data we have to store in order to comply with retention obligations is stored until the obligation to retain it ends. If we store personal data solely to comply with retention obligations, it is usually blocked, meaning it can only be accessed when that is required for the purpose for which the data had to be retained.
X. What are your rights as a data subject?
a. Right of objection under Art. 21 DSGVO
As a data subject you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning yourself which is based on point (e) or (f) of Article 6 (1), including profiling based on those provisions. In the event of such an objection, we will no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds to further process the personal data, outweighing your interests, rights and freedoms, or (ii) the processing is used for effective exercise or defense of legal rights.
In case we process your personal data for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning yourself for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object processing for direct marketing purposes, the relevant personal data will no longer be processed for these purposes.
b. Withdrawal of consent
Please note that the consent you have withdrawn will only have effect for the future and has no influence on the lawfulness of processing based on consent before its withdrawal. In some cases, despite your withdrawal, we are entitled to process your personal data on a different legal basis - for example, to fulfil a contract.
c. Additional rights
As a data subject, you also have the right to
- access the personal data stored on you (Article 15 GDPR);
- have incorrect data rectified and to have incomplete data completed (Article 16 GDPR);
- demand erasure of personal data (Article 17 GDPR);
- demand restriction of processing (Article 18 GDPR); and
- demand data portability (Article 20 GDPR),
In order to exercise these rights, you can contact us at any time, e.g. by using the channels specified in Section I. of this Data Privacy Statement.
If you have questions relating to processing of data, you can also contact our Data Protection Officer, whose contact information you can also find in Section I. of this Data Privacy Statement.
As a data subject you also have the right to lodge a complaint with a supervisory authority responsible for data protection (Article 77 GDPR).
XI. Changes to the Data Privacy Statement
Due to the further development of our Website and our offers or due to changed legal or official requirements, it may become necessary to change this Data Privacy Statement.
If this results in fundamental changes for you or if legal provisions make this necessary, we will inform you of such changes (with a corresponding note when you go to our Website).
You can access and print out the current Data Privacy Statement on our Website at any time.
Status: May 2023
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