Privacy Policy

Status: 01.10.2022

I. Privacy policy for our website

1. Name and contact of the responsible person pursuant to Art. 4 para. 7 GDPR

Company: Deutsche Lufthansa AG
Address: Venloer Straße 151-153, 50672 Cologne, Germany
E-mail: datenschutz@dlh.de

Data Protection Officer
The Data Protection Officer can be contacted at the above address and at datenschutz@dlh.de.

Please send a request for information to:
Deutsche Lufthansa AG
Datenauskunft
FRA CJ/D
60546 Frankfurt

or by e-mail to:
datenauskunft@dlh.de

If you contact us by e-mail, the communication will be unencrypted.

2. Processing overview

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

• Inventory data (e.g. names, addresses)
• Content data (e.g. entries in online forms)
• Contact data (e.g. e-mail, telephone numbers)
• Meta/communication data (e.g. device information, IP addresses)
• Usage data (e.g. websites visited, interest in content, access times)
• Location data (information about the geographical position of a device or person)
• Contract data (e.g. subject matter of contract, term, customer category)
• Payment data (e.g. bank details, invoices, payment history)

Categories of persons concerned

• Business and contract partners
• Interested parties
• Communication partners
• Customers
• Users (e.g. website visitors, users of online services)

Processing purposes

• Provision of our online offer and user friendliness
• Visitor action evaluation
• Office and organizational procedures
• Direct marketing (e.g. by e-mail or postal mail)
• Interest-based and behavioral marketing
• Contact requests and communication
• Conversion measurement (measuring the effectiveness of marketing activities)
• Remarketing
• Reach measurement (e.g. access statistics, recognition of returning visitors)
• Security measures
• Provision of contractual services and customer service
• Administration and response to inquiries

Relevant legal bases

In the following, we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection provisions in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

• Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
• Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
• Legal obligation (Art. 6 (1) p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

3. Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

4. Transfer and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

5. Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

6. Use of cookies

Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e., our online offering) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users’ consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: In terms of storage duration, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile app).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer).

Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information about the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system and end device used.

Cookie settings/opposition:
This website uses Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) to store your cookie consents.

Borlabs cookie does not process any personal data.

Borlabs cookie stores your consents and settings that you have chosen when entering the website.
Here you can change your selected cookie settings at any time:
Cookie Settings

7. Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

8. Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used on the one hand for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand, to ensure the utilization of the servers and their stability.

• Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g., website visitors, users of online services).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

9. Contact

When contacting us (e.g. via contact form, e-mail or telephone), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.
The response to the contact inquiries in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of the legitimate interests in responding to the inquiries.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners, interested parties.
• Purposes of processing: contact requests and communication, management and response to requests.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations.

10. Web analysis, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

In addition to web analysis, we may also use test procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

• Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavior-based profiling, use of cookies), visit action evaluation, profiling (creation of user profiles). Security measures: IP masking (pseudonymization of the IP address).
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Google Analytics: web analytics, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Option to object (Opt-out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices ‚(types of processing as well as data processed).

11. Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.

12. Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

13. Your rights as a data subject

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to revoke any consent given at any time.
• Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
• Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transfer to another controller.
• Complaint to the supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

The supervisory authority responsible for Lufthansa is:
The Officer for Data Protection and Freedom of Information of the State of Hesse
PO box 3163
65021 Wiesbaden

Phone: +49 611 1408 – 0
Fax: +49 611 1408 – 900 / 901
E-mail: poststelle@datenschutz.hessen.de

II. Privacy policy for our customers

1. Name and contact of the responsible person pursuant to Art. 4 para. 7 GDPR

Company: Deutsche Lufthansa AG
Address: Venloer Straße 151-153, 50672 Cologne, Germany
E-mail: datenschutz@dlh.de

Data Protection Officer
The Data Protection Officer can be contacted at the above address and at datenschutz@dlh.de.

Please send a request for information to:
Deutsche Lufthansa AG
Datenauskunft
FRA CJ/D
60546 Frankfurt

or by e-mail to:
datenauskunft@dlh.de

If you contact us by e-mail, the communication will be unencrypted.

2. We process the following personal data:

• Name
• Address
• Contact data of contact persons in the company (first name, last name)
• Communication data (telephone number, mobile number, e-mail address, fax number)
• Customer number as well as order and delivery data for the purpose of initiation
• Order and contract data
• Billing and payment data (bank details)

3. We process personal data

• for the fulfilment of the business purpose such as pre-contractual measures (e.g. for the preparation of offers, processing of enquiries)
• to fulfil contractual obligations (order, order and payment processing, invoicing)
• to deliver services (Art. 6 para. 1 lit. b GDPR)
• to maintain business contact and to inform the business partner
• for processing (e.g. due to tax law requirements), (Art. 6 para. 1 lit. c GDPR).

4. The legal bases for data processing are:

The stored data was collected within the framework of our contractual relationship and for the initiation of contracts as well as individual orders, or it arose within the framework of the business relationship and initiation of business. The data is stored for the fulfilment and processing of the orders placed with us as well as the documentation and archiving obligations under commercial and tax law. The collection also takes place from entries in the ERP system, signatures from e-mail and documents. In this respect, the processing of your data takes place on the basis of Article 6 Paragraph 1, lit. b,c,f GDPR.

5. The transmission of personal data to third parties only takes place on your behalf and with your consent.

We pass on personal data to the following recipients within the framework of the business relationship:

Public bodies that receive data on the basis of statutory regulations:
Financial authorities

Internal units involved in the execution of the respective business processes:
Management, Accounting, Marketing, Sales and IT

External contractors (service companies) in accordance with Art. 28 GDPR to handle the processing of data on our behalf:
IT service provider

Group-affiliated companies or other external bodies for the fulfilment of the above-mentioned purposes, insofar as the data subject has declared his or her written consent, this is necessary for the fulfilment of the contract or a transfer is permissible for predominant legitimate interest:
Suppliers for direct delivery, Tax consultants and auditors, Lawyers

6. Data transfer to third countries (countries outside the European Economic Area – EEA)

Data is only transferred to third countries (countries outside the European Economic Area – EEA) if this is necessary for the execution of the business relationship (e.g. payment orders) or if you have given us your consent or if this is otherwise legally permissible.

In this case, we take measures to ensure the protection of your data, for example through contractual regulations. We only transfer data to recipients who ensure the protection of your data in accordance with the provisions of the GDPR for transfers to third countries (Art. 44 to 49 GDPR).

7. Personal data

We store the personal data for the duration of the statutory retention periods. As a rule, this is 10 years plus a waiting period of a further 4 years to cover cases of possible expiry suspension. After 14 years, we check whether there are reasons for further storage.

8. Your rights as a data subject

• Right to information according to Art. 15 GDPR
• Right to rectification according to Art. 16 GDPR
• Right to erasure („being forgotten“) according to Art. 17 GDPR
• Right to restriction of processing according to Art. 18 GDPR
• Right to transfer your data in a structured, common and machine-readable format according to Art. 20 GDPR

Insofar as we carry out processing for certain purposes of your personal data on the basis of your consent, you have the right to revoke your consent at any time in accordance with Art. 7 (3) GDPR. Upon receipt of your revocation, we will stop processing data for the purposes for which you gave us your consent. The lawfulness of the processing prior to receipt of your revocation remains unaffected.

Right to object: If we process your personal data for the protection of legitimate interests within the meaning of Art. 6 (1) subparagraph 1 letter f GDPR, you have the right to object to this processing on grounds relating to your particular situation in accordance with Art. 21 (1) GDPR. You may object to processing for direct marketing purposes at any time without giving reasons pursuant to Art. 21 (2) GDPR. To exercise your right to object, simply send us an informal message (e.g. by e-mail to datenauskunft@dlh.de) stating which data processing you object to.

In addition, you have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in conjunction with section 19 BDSG, you have the right to lodge a complaint with a supervisory authority.

The supervisory authority responsible for Lufthansa is:

The Officer for Data Protection and Freedom of Information of the State of Hesse
PO box 3163
65021 Wiesbaden

Phone: +49 611 1408 – 0
Fax: +49 611 1408 – 900 / 901
E-mail: poststelle@datenschutz.hessen.de